Application number: 1-1326-97308 for Key GTLD Holding Inc

Key GTLD Holding Inc

1619 Broadway
19th FLoor
New York NY 10019
UA

0019174215467

Matthew Russotti

Consultant

513 745 2810

mrussotti@wolfe-sbmc.com

Ms. Laurie Kunkel

Consultant

513 746 2800

lkunkel@wolfe-sbmc.com

Corporation

Delaware

Not Available

Key Brand Entertainment

John Gore
President and Chief Financial Officer

John Gore
President and Chief Financial Officer
Liam Lynch
Executive Vice President
Seth Popper
Secretary
ThomasC. McGrath
Assistant Secretary

theater

Not Available

Applicant’s gTLD application is a non-IDN application. Applicant is unaware of any known operational or rendering problems related to the applied for gTLD.

The mission of .theater is to provide diverse internet users an enhanced online experience while enriching society with artistic and cultural diversity through high quality content, information and authentic connected experiences centered on live theater, musicals, opera, ballet and other performing arts, Broadway, and other related concepts, topics and activities. .theater will be a branded top level domain operated by KBE GTLD Holding Inc., a wholly-owned subsidiary of Key Brand Entertainment (KBE), and intends to function, per the ICANN-Registry Operator Registry Agreement, as a Specification 9 exempt system that will seek to provide internet users with the confidence that all of the programming, information, social media, shopping and lifestyle opportunities found on the .theater branded top level domain is authentic, genuine, safe, trusted, and secure and affiliated with the KBE’s broadway.com brand.

The goal of .theater is to provide high quality, authentic information and online experiences for individuals interested in live theater, musicals, opera, ballet and other performing arts, Broadway, and other related concepts, topics and activities. The reputation of KBE, through its operation of broadway.com, is well recognized as a single source for high quality access to tickets, content, information and programming related to live theater. The level of service to its customers is highly regarded as the single most trusted source for Broadway and live theater entertainment.

Internet users will benefit because .theater will provide an enhanced online experience from the existing broadway.com through its ability to build more personalized experiences for internet users seeking artistic and cultural diversity. .theater will provide Applicant greater control over the domain as a registry operator, enabling the domain to be operated with the same exceptional values KBE has shown to users through the operation of broadway.com. Additionally, new communities can be identified and formed to connect internet users with others interested in theater and other performing arts and entertainment.

.theater intends to function, per the ICANN-Registry Operator Registry Agreement, as a Specification 9 exempt system and will carefully monitor and safeguard the user experience to provide users confidence that they will experience the same high quality content, information, experiences and security that they would with the well-known, famous brand broadway.com that they know and trust. New users will quickly come to recognize that .theater stands for authentic, high quality, trusted sources for information about live theater and other performing arts, entertainment, experiences, products and services.

.theater will provide users who navigate within .theater privacy protection similar to what is currently provided on broadway.com. Applicant will annually review and audit these policies to ensure that best practices are being utilized to protect the safety, security and confidentiality of its users.

.theater will further enhance brand consistency by creating numerous subdomains under the .theater TLD that have not been available under the existing top level domain namespace. Further, the .theater TLD creates the possibility that these to-be-created subdomains will be more precisely targeted to internet users that will use them, more focused on content associated with the TLD under which they will reside, and more relevant to the TLD.

.theater intends to function, per the ICANN-Registry Operator Registry Agreement, as a Specification 9 exempt system. All second level domains will be for the benefit of .theater users and its affiliates. All other subdomain names intended to be used within .theater registry will be controlled and managed by KBE GTLD Holding Inc., for the benefit of itself or affiliates.

It is the intent of the Applicant to request an exemption from the new gTLD Code of Conduct per Section 6 of Specification 9 of the Registry Operator Code of Conduct. As such, Applicant intends to function in such a way that all domain name registrations in the TLD shall be registered to and maintained by Applicant and Applicant will not sell, distribute or transfer control of domain name registrations to any party that is not an Affiliate of Applicant as defined in the ICANN-Registry Operator Registry Agreement. All domain name registrations intended to be used within Applicant’s registry will be registered to and controlled and maintained by Applicant and for the benefit of Applicant and its users, parents, sisters and Affiliates. 

In the event that Applicant is not granted an exemption from Specification 9, Applicant will partner with a corporate registrar with expertise in running a registry to support such efforts. Applicant intends to partner with its current corporate registrar or one of similar technical capability and expertise and allocate the appropriate funds and human resources to ensure that both itself, as the registry operator, and its selected registrar are at all times in compliance with ICANN guidelines.

No

Not Available

No

The Applicant will initially reserve country names from use in the second and other levels of the TLD, and other such names designated by ICANN and pursuant to Specification 5 and ICANN’s ongoing policies and regulations. In this regard, Applicant will at all times comply with ICANN’s geographic and all other reservation requirements as outlined in the Registry Agreement and Applicant’s reserved name list mentioned below. Applicant’s TLD will be operated as a Specification 9 exempt system, and the Applicant may, over time, utilize the reserved country names in the second and other country levels in order to organize content within the domain in a meaningful way. However, in such event, before the Applicant begins using such initially reserved country names, Applicant will provide a window during which governments, ICANN, public authorities or IGOs may submit a demand to block names with national or geographic significance at the second level of the TLD at no cost to the blocking authority. In the event of such occurrence, Applicant will at all times comply with all ICANN mandates and shall establish a notice mechanism and blocking procedure to effectuate such action. 

All geographic and geopolitical names contained in the ISO 3166-1 list from time to time shall initially be reserved at both the second level and at all other levels within the TLD at which the Applicant provides for registrations. All names shall be reserved both in English and in all related official languages as may be directed by ICANN or the GAC. In addition, Applicant shall reserve names of territories, distinct geographic locations, and other geographic and geopolitical names as ICANN may direct from time to time. Such names shall be reserved from registration during any sunrise period, and shall be registered in ICANNʹs name prior to start-up and open registration in the TLD. Applicant shall post and maintain an updated listing of all such names on its website, which list shall be subject to change at ICANNʹs direction. Upon determination by ICANN of appropriate standards and qualifications for registration following input from interested parties in the Internet community, such names may be approved for registration to the appropriate authoritative body.

Pursuant to any ICANN directive allowing release after the blocking period has concluded, a contact will be delegated and information posted to enable governments, public authorities, or IGOs to challenge abuses of names with national or geographic significance at the second level of the TLD during the operation of the TLD. Challenges will be reviewed on their merits and resolved in a way that demonstrates that the Applicant respects sensitivities regarding terms with national, cultural, geographic and religious significance while enabling Applicant to provide content to users in a logical and organized fashion.

Additionally, Verisign, as Applicant’s back-end registry provider, provides a mechanism through their registry solution for reserving second-level domain names that prevents them from being registered. This functionality includes a list of strings that the system will not allow to be registered. Strings can be added and removed from this list as needed.

For the protection of geographic names for the Applicant’s TLD, the country and territory names contained in the following internationally recognized lists shall be blocked initially:

* The short form (in English) of all country and territory names, including the European Union, contained on the International Organization for Standardization (ISO) 3166-1 list located at: 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 (UNGEGN), Technical Reference Manual for the Standardization of Geographical Names, Part III Names of Countries of the World: http:⁄⁄unstats.un.org⁄unsd⁄geoinfo⁄UNGEGN⁄publications.html 

* 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. The most recent list of country names approved by the Working Group was submitted on behalf of UNGEGN for the Ninth UN Conference on the Standardization of Geographical Names in August 2007: E⁄CONF.98⁄89 Add.1 http:⁄⁄unstats.un.org⁄unsd⁄geoinfo⁄ungegn⁄docs⁄9th-uncsgn-docs⁄econf⁄9th_UNCSGN_e-conf-98-89-add1.pdf 

As new versions of these three internationally recognized lists are published, Verisign will update the list of names reserved by the Verisign registry system to reflect any changes.

In addition to providing protection for geographic names, this reserved name functionality will be used to reserve other names specifically ineligible for delegation.

For example, Section 2.2.1.2.3 of the Applicant Guidebook lists strings associated with the International Olympic Committee and the International Red Cross and Red Crescent organizations to be prohibited from delegation per the Government Advisory Committee (GAC) request.

All the strings on these lists as well as any others put forth by the GAC and approved by ICANN will be included in the list of reserved names.

There are no plans at this time to release any of the reserved names. If, however, Applicant intends to release any of the names at a future date, we will follow the appropriate procedures, outlined in Section 5 of Specification 5, on the release of reserved names.

1 CUSTOMARY REGISTRY SERVICES
As the Applicant’s selected provider of backend registry services, Verisign provides a comprehensive system and physical security solution that is designed to ensure a TLD is protected from unauthorized disclosure, alteration, insertion, or destruction of registry data. Verisign’s system addresses all areas of security including information and policies, security procedures, the systems development lifecycle, physical security, system hacks, break-ins, data tampering, and other disruptions to operations. Verisign’s operational environments not only meet the security criteria specified in its customer contractual agreements, thereby preventing unauthorized access to or disclosure of information or resources on the Internet by systems operating in accordance with applicable standards, but also are subject to multiple independent assessments as detailed in the response to Question 30, Security Policy. Verisign’s physical and system security methodology follows a mature, ongoing lifecycle that was developed and implemented many years before the development of the industry standards with which Verisign currently complies. Please see the response to Question 30, Security Policy, for details of the security features of Verisign’s registry services. 
Verisign’s registry services fully comply with relevant standards and best current practice RFCs published by the Internet Engineering Task Force (IETF), including all successor standards, modifications, or additions relating to the DNS and name server operations including without limitation RFCs 1034, 1035, 1982, 2181, 2182, 2671, 3226, 3596, 3597, 3901, 4343, and 4472. Moreover, Verisign’s Shared Registration System (SRS) supports the following IETF Extensible Provisioning Protocol (EPP) specifications, where the Extensible Markup Language (XML) templates and XML schemas are defined in RFC 3915, 5730, 5731, 5732, 5733, and 5734. By strictly adhering to these RFCs, Verisign helps to ensure its registry services do not create a condition that adversely affects the throughput, response time, consistency, or coherence of responses to Internet servers or end systems. Besides its leadership in authoring RFCs for EPP, Domain Name System Security Extensions (DNSSEC), and other DNS services, Verisign has created and contributed to several now well-established IETF standards and is a regular and long-standing participant in key Internet standards forums.
Figure 23 1 summarizes the technical and business components of those registry services, customarily offered by a registry operator (i.e., Verisign), that support this application. These services are currently operational and support both large and small Verisign-managed registries. Customary registry services are provided in the same manner as Verisign provides these services for its existing gTLDs.
Through these established registry services, Verisign has proven its ability to operate a reliable and low-risk registry that supports millions of transactions per day. Verisign is unaware of any potential security or stability concern related to any of these services. 
Registry services defined by this application are not intended to be offered in a manner unique to the new generic top-level domain (gTLD) nor are any proposed services unique to this application’s registry. 
As further evidence of Verisign’s compliance with ICANN mandated security and stability requirements, Verisign allocates the applicable RFCs to each of the five customary registry services (items A – E above). For each registry service, Verisign also provides evidence in Figure 23 2 of Verisign’s RFC compliance and includes relevant ICANN prior-service approval actions. 

1.1 Critical Operations of the Registry 
i. Receipt of Data from Registrars Concerning Registration of Domain Names and Name Servers 
See Item A in Figure 23 1 and Figure 23 2. 
ii. Provision to Registrars Status Information Relating to the Zone Servers
Verisign is the Applicant’s selected provider of backend registry services. Verisign registry services provisions to registrars status information relating to zone servers for the TLD. The services also allow a domain name to be updated with clientHold, serverHold status, which removes the domain name server details from zone files. This ensures that DNS queries of the domain name are not resolved temporarily. When these hold statuses are removed, the name server details are written back to zone files and DNS queries are again resolved. Figure 23 3 describes the domain name status information and zone insertion indicator provided to registrars. The zone insertion indicator determines whether the name server details of the domain name exist in the zone file for a given domain name status. Verisign also has the capability to withdraw domain names from the zone file in near-real time by changing the domain name statuses upon request by customers, courts, or legal authorities as required. 
iii. Dissemination of TLD Zone Files
See Item B in Figure 23 1 and Figure 23 2. 
iv. Operation of the Registry Zone Servers
Verisign is the Applicant’s selected provider of backend registry services. Verisign, as a company, operates zone servers and serves DNS resolution from 76 geographically distributed resolution sites located in North America, South America, Africa, Europe, Asia, and Australia. Currently, 17 DNS locations are designated primary sites, offering greater capacity than smaller sites comprising the remainder of the Verisign constellation. Verisign also uses Anycast techniques and regional Internet resolution sites to expand coverage, accommodate emergency or surge capacity, and support system availability during maintenance procedures. Verisign operates the Applicant’s gTLD from a minimum of eight of its primary sites (two on the East Coast of the United States, two on the West Coast of the United States, two in Europe, and two in Asia) and expands resolution sites based on traffic volume and patterns. Further details of the geographic diversity of Verisign’s zone servers are provided in the response to Question 34, Geographic Diversity. Moreover, additional details of Verisign’s zone servers are provided in the response to Question 32, Architecture and the response to Question 35, DNS Service. 
v. Dissemination of Contact and Other Information Concerning Domain Name Server Registrations
See Item C in Figure 23 1 and Figure 23 2. 
2 OTHER PRODUCTS OR SERVICES THE REGISTRY OPERATOR IS REQUIRED TO PROVIDE BECAUSE OF THE ESTABLISHMENT OF A CONSENSUS POLICY
Verisign, the Applicant’s selected provider of backend registry services, is a proven supporter of ICANN’s consensus-driven, bottom-up policy development process whereby community members identify a problem, initiate policy discussions, and generate a solution that produces effective and sustained results. Verisign currently provides all of the products or services (collectively referred to as services) that the registry operator is required to provide because of the establishment of a Consensus Policy. For this TLD, Verisign implements these services using the same proven processes and procedures currently in-place for all registries under Verisign’s management. Furthermore, Verisign executes these services on computing platforms comparable to those of other registries under Verisign’s management. Verisign’s extensive experience with consensus policy required services and its proven processes to implement these services greatly minimize any potential risk to Internet security or stability. Details of these services are provided in the following subsections. It shall be noted that consensus policy services required of registrars (e.g., Whois Reminder, Expired Domain) are not included in this response. This exclusion is in accordance with the direction provided in the question’s Notes column to address registry operator services. 
2.1 Inter-Registrar Transfer Policy (IRTP)
Technical Component: In compliance with the IRTP consensus policy, Verisign, the Applicant’s selected provider of backend registry services, has designed its registration systems to systematically restrict the transfer of domain names within 60 days of the initial create date. In addition, Verisign has implemented EPP and “AuthInfo” code functionality, which is used to further authenticate transfer requests. The registration system has been designed to enable compliance with the five-day Transfer grace period and includes the following functionality:
• Allows the losing registrar to proactively ‘ACK’ or acknowledge a transfer prior to the expiration of the five-day Transfer grace period
• Allows the losing registrar to proactively ‘NACK’ or not acknowledge a transfer prior to the expiration of the five-day Transfer grace period 
• Allows the system to automatically ACK the transfer request once the five-day Transfer grace period has passed if the losing registrar has not proactively ACK’d or NACK’d the transfer request.
Business Component: All requests to transfer a domain name to a new registrar are handled according to the procedures detailed in the IRTP. Dispute proceedings arising from a registrarʹs alleged failure to abide by this policy may be initiated by any ICANN-accredited registrar under the Transfer Dispute Resolution Policy. Applicant’s compliance office serves as the first-level dispute resolution provider pursuant to the associated Transfer Dispute Resolution Policy. As needed Verisign is available to offer policy guidance as issues arise. 
Security and Stability Concerns: Verisign is unaware of any impact, caused by the service, on throughput, response time, consistency, or coherence of the responses to Internet servers or end-user systems. By implementing the IRTP in accordance with ICANN policy, security is enhanced as all transfer commands are authenticated using the AuthInfo code prior to processing. 
ICANN Prior Approval: Verisign has been in compliance with the IRTP since November 2004 and is available to support the Applicant in a consulting capacity as needed. 
Unique to the TLD: This service is not provided in a manner unique to this TLD.
2.2 Add Grace Period (AGP) Limits Policy
Technical Component: Verisign’s registry system monitors registrars’ Add grace period deletion activity and provides reporting that permits the Applicant to assess registration fees upon registrars that have exceeded the AGP thresholds stipulated in the AGP Limits Policy. Further, Applicant accepts and evaluates all exemption requests received from registrars and determines whether the exemption request meets the exemption criteria. Applicant maintains all AGP Limits Policy exemption request activity so that this material may be included within Applicant’s Monthly Registry Operator Report to ICANN.
Registrars that exceed the limits established by the policy may submit exemption requests to the applicant for consideration. Applicant’s compliance office reviews these exemption requests in accordance with the AGP Limits Policy and renders a decision. Upon request, the applicant submits associated reporting on exemption request activity to support reporting in accordance with established ICANN requirements.
Business Component: The Add grace period (AGP) is restricted for any gTLD operator that has implemented an AGP. Specifically, for each operator: 
• During any given month, an operator may not offer any refund to an ICANN-accredited registrar for any domain names deleted during the AGP that exceed (i) 10% of that registrarʹs net new registrations (calculated as the total number of net adds of one-year through ten-year registrations as defined in the monthly reporting requirement of Operator Agreements) in that month, or (ii) fifty (50) domain names, whichever is greater, unless an exemption has been granted by an operator. 
• Upon the documented demonstration of extraordinary circumstances, a registrar may seek from an operator an exemption from such restrictions in a specific month. The registrar must confirm in writing to the operator how, at the time the names were deleted, these extraordinary circumstances were not known, reasonably could not have been known, and were outside the registrarʹs control. Acceptance of any exemption will be at the sole and reasonable discretion of the operator; however ʺextraordinary circumstancesʺ that reoccur regularly for the same registrar will not be deemed extraordinary. 
In addition to all other reporting requirements to ICANN, the Applicant identifies each registrar that has sought an exemption, along with a brief description of the type of extraordinary circumstance and the action, approval, or denial that the operator took. 
Security and Stability Concerns: Verisign is unaware of any impact, caused by the policy, on throughput, response time, consistency, or coherence of the responses to Internet servers or end-user systems.
ICANN Prior Approval: Verisign, the applicant’s backend registry services provider, has had experience with this policy since its implementation in April 2009 and is available to support the applicant in a consulting capacity as needed. 
Unique to the TLD: This service is not provided in a manner unique to this TLD.
2.3 Registry Services Evaluation Policy (RSEP)
Technical Component: Verisign, the Applicant’s selected provider of backend registry services, adheres to all RSEP submission requirements. Verisign has followed the process many times and is fully aware of the submission procedures, the type of documentation required, and the evaluation process that ICANN adheres to. 
Business Component: In accordance with ICANN procedures detailed on the ICANN RSEP website (http:⁄⁄www.icann.org⁄en⁄registries⁄rsep⁄), all gTLD registry operators are required to follow this policy when submitting a request for new registry services.
Security and Stability Concerns: As part of the RSEP submission process, Verisign, Applicant’s backend registry services provider, identifies any potential security and stability concerns in accordance with RSEP stability and security requirements. Verisign never launches services without satisfactory completion of the RSEP process and resulting approval.
ICANN Prior Approval: Not applicable.
Unique to the TLD: gTLD RSEP procedures are not implemented in a manner unique to this TLD.
3 PRODUCTS OR SERVICES ONLY A REGISTRY OPERATOR IS CAPABLE OF PROVIDING BY REASON OF ITS DESIGNATION AS THE REGISTRY OPERATOR
Verisign, the Applicant’s selected backend registry services provider, has developed a Registry-Registrar Two-Factor Authentication Service that complements traditional registration and resolution registry services. In accordance with direction provided in Question 23, Verisign details below the technical and business components of the service, identifies any potential threat to registry security or stability, and lists previous interactions with ICANN to approve the operation of the service. The Two-Factor Authentication Service is currently operational, supporting multiple registries under ICANN’s purview. 
Applicant is unaware of any competition issue that may require the registry service(s) listed in this response to be referred to the appropriate governmental competition authority or authorities with applicable jurisdiction. ICANN previously approved the service(s), at which time it was determined that either the service(s) raised no competitive concerns or any applicable concerns related to competition were satisfactorily addressed.
3.1 Two-Factor Authentication Service
Technical Component: The Registry-Registrar Two-Factor Authentication Service is designed to improve domain name security and assist registrars in protecting the accounts they manage. As part of the service, dynamic one-time passwords augment the user names and passwords currently used to process update, transfer, and⁄or deletion requests. These one-time passwords enable transaction processing to be based on requests that are validated both by “what users know” (i.e., their user name and password) and “what users have” (i.e., a two-factor authentication credential with a one-time-password).
Registrars can use the one-time-password when communicating directly with Verisign’s Customer Service department as well as when using the registrar portal to make manual updates, transfers, and⁄or deletion transactions. The Two-Factor Authentication Service is an optional service offered to registrars that execute the Registry-Registrar Two-Factor Authentication Service Agreement.
Business Component: There is no charge for the Registry-Registrar Two-Factor Authentication Service. It is enabled only for registrars that wish to take advantage of the added security provided by the service.
Security and Stability Concerns: Verisign is unaware of any impact, caused by the service, on throughput, response time, consistency, or coherence of the responses to Internet servers or end-user systems. The service is intended to enhance domain name security, resulting in increased confidence and trust by registrants.
ICANN Prior Approval: ICANN approved the same Two-Factor Authentication Service for Verisign’s use on .com and .net on 10 July 2009 (RSEP Proposal 2009004) and for .name on 16 February 2011 (RSEP Proposal 2011001). 
Unique to the TLD: This service is not provided in a manner unique to this TLD.

1 ROBUST PLAN FOR OPERATING A RELIABLE SRS
1.1 High-Level Shared Registration System (SRS) System Description
Verisign, the Applicant’s selected provider of backend registry services, provides and operates a robust and reliable SRS that enables multiple registrars to provide domain name registration services in the top-level domain (TLD). Verisign’s proven reliable SRS serves approximately 915 registrars, and Verisign, as a company, has averaged more than 140 million registration transactions per day. The SRS provides a scalable, fault-tolerant platform for the delivery of gTLDs through the use of a central customer database, a web interface, a standard provisioning protocol (i.e., Extensible Provisioning Protocol, EPP), and a transport protocol (i.e., Secure Sockets Layer, SSL). 
The SRS components include:
• Web Interface: Allows customers to access the authoritative database for accounts, contacts, users, authorization groups, product catalog, product subscriptions, and customer notification messages.
• EPP Interface: Provides an interface to the SRS that enables registrars to use EPP to register and manage domains, hosts, and contacts.
• Authentication Provider: A Verisign developed application, specific to the SRS, that authenticates a user based on a login name, password, and the SSL certificate common name and client IP address. 
The SRS is designed to be scalable and fault tolerant by incorporating clustering in multiple tiers of the platform. New nodes can be added to a cluster within a single tier to scale a specific tier, and if one node fails within a single tier, the services will still be available. The SRS allows registrars to manage the TLD domain names in a single architecture.
To flexibly accommodate the scale of its transaction volumes, as well as new technologies, Verisign employs the following design practices:
• Scale for Growth: Scale to handle current volumes and projected growth.
• Scale for Peaks: Scale to twice base capacity to withstand “registration add attacks” from a compromised registrar system.
• Limit Database CPU Utilization: Limit utilization to no more than 50 percent during peak loads.
• Limit Database Memory Utilization: Each user’s login process that connects to the database allocates a small segment of memory to perform connection overhead, sorting, and data caching. Verisign’s standards mandate that no more than 40 percent of the total available physical memory on the database server will be allocated for these functions. 
Verisign’s SRS is built upon a three-tier architecture as illustrated in Figure 24 1 and detailed here: 
• Gateway Layer: The first tier, the gateway servers, uses EPP to communicate with registrars. These gateway servers then interact with application servers, which comprise the second tier.
• Application Layer: The application servers contain business logic for managing and maintaining the registry business. The business logic is particular to each TLD’s business rules and requirements. The flexible internal design of the application servers allows Verisign to easily leverage existing business rules to apply to the TLD. The application servers store the Applicant’s data in the registry database, which comprises the third and final tier. This simple, industry-standard design has been highly effective with other customers for whom Verisign provides backend registry services.
• Database Layer: The database is the heart of this architecture. It stores all the essential information provisioned from registrars through the gateway servers. Separate servers query the database, extract updated zone and Whois information, validate that information, and distribute it around the clock to Verisign’s worldwide domain name resolution sites.
Scalability and Performance. Verisign, the Applicant’s selected backend registry services provider, implements its scalable SRS on a supportable infrastructure that achieves the availability requirements in Specification 10. Verisign employs the design patterns of simplicity and parallelism in both its software and systems, based on its experience that these factors contribute most significantly to scalability and reliable performance. Going counter to feature-rich development patterns, Verisign intentionally minimizes the number of lines of code between the end user and the data delivered. The result is a network of restorable components that provide rapid, accurate updates. Figure 24 2 depicts EPP traffic flows and local redundancy in Verisign’s SRS provisioning architecture. As detailed in the figure, local redundancy is maintained for each layer as well as each piece of equipment. This built-in redundancy enhances operational performance while enabling the future system scaling necessary to meet additional demand created by this or future registry applications. 
Besides improving scalability and reliability, local SRS redundancy enables Verisign to take down individual system components for maintenance and upgrades, with little to no performance impact. With Verisign’s redundant design, Verisign can perform routine maintenance while the remainder of the system remains online and unaffected. For the TLD registry, this flexibility minimizes unplanned downtime and provides a more consistent end-user experience. 
1.2 Representative Network Diagrams
Figure 24 3 provides a summary network diagram of the Applicant’s selected backend registry services provider’s (Verisign’s) SRS. This configuration at both the primary and alternate-primary Verisign data centers provides a highly reliable backup capability. Data is continuously replicated between both sites to ensure failover to the alternate-primary site can be implemented expeditiously to support both planned and unplanned outages. 
1.3 Number of Servers
As the Applicant’s selected provider of backend registry services, Verisign continually reviews its server deployments for all aspects of its registry service. Verisign evaluates usage based on peak performance objectives as well as current transaction volumes, which drive the quantity of servers in its implementations. Verisign’s scaling is based on the following factors:
• Server configuration is based on CPU, memory, disk IO, total disk, and network throughput projections.
• Server quantity is determined through statistical modeling to fulfill overall performance objectives as defined by both the service availability and the server configuration. 
• To ensure continuity of operations for the TLD, Verisign uses a minimum of 100 dedicated servers per SRS site. These servers are virtualized to meet demand. 

1.4 Description of Interconnectivity with Other Registry Systems
Figure 24 4 provides a technical overview of the Applicant’s selected backend registry services provider’s (Verisign’s) SRS, showing how the SRS component fits into this larger system and interconnects with other system components. 
1.5 Frequency of Synchronization Between Servers
As Applicant’s selected provider of backend registry services, Verisign uses synchronous replication to keep the Verisign SRS continuously in sync between the two data centers. This synchronization is performed in near-real time, thereby supporting rapid failover should a failure occur or a planned maintenance outage be required.
1.6 Synchronization Scheme
Verisign uses synchronous replication to keep the Verisign SRS continuously in sync between the two data centers. Because the alternate-primary site is continuously up, and built using an identical design to the primary data center, it is classified as a “hot standby.” 
2 SCALABILITY AND PERFORMANCE ARE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY
Verisign is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies. 
Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the TLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to the Applicant fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.
3 TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION
Verisign, the Applicant’s selected provider of backend registry services, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services provided to the Applicant fully accounts for this personnel-related cost, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response. 

Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force. (Current statistics are publicly available in Verisign’s quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100 percent of the time for more than 13 years for .com, proving Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s TLD service offerings. 
Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support SRS performance:
• Application Engineers: 19
• Database Administrators: 8 
• Database Engineers: 3
• Network Administrators: 11 
• Network Architects: 4 
• Project Managers: 25
• Quality Assurance Engineers: 11 
• SRS System Administrators: 13 
• Storage Administrators: 4
• Systems Architects: 9

To implement and manage the TLD as described in this application, Verisign, the Applicant’s selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area. 
When usage projections indicate a need for additional staff, Verisign’s internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed gTLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internet’s largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.
4 EVIDENCE OF COMPLIANCE WITH SPECIFICATION 6 AND 10 TO THE REGISTRY AGREEMENT
Section 1.2 (EPP) of Specification 6, Registry Interoperability and Continuity Specifications. Verisign, the Applicant’s selected backend registry services provider, provides these services using its SRS, which complies fully with Specification 6, Section 1.2 of the Registry Agreement. In using its SRS to provide backend registry services, Verisign implements and complies with relevant existing RFCs (i.e., 5730, 5731, 5732, 5733, 5734, and 5910) and intends to comply with RFCs that may be published in the future by the Internet Engineering Task Force (IETF), including successor standards, modifications, or additions thereto relating to the provisioning and management of domain names that use EPP. In addition, Verisign’s SRS includes a Registry Grace Period (RGP) and thus complies with RFC 3915 and its successors. Details of the Verisign SRS’ compliance with RFC SRS⁄EPP are provided in the response to Question 25, Extensible Provisioning Protocol. Verisign does not use functionality outside the base EPP RFCs, although proprietary EPP extensions are documented in Internet-Draft format following the guidelines described in RFC 3735 within the response to Question 25. Moreover, prior to deployment, the Applicant will provide to ICANN updated documentation of all the EPP objects and extensions supported in accordance with Specification 6, Section 1.2.
Specification 10, EPP Registry Performance Specifications. Verisign’s SRS meets all EPP Registry Performance Specifications detailed in Specification 10, Section 2. Evidence of this performance can be verified by a review of the .com and .net Registry Operator’s Monthly Reports, which Verisign files with ICANN. These reports detail Verisign’s operational status of the .com and .net registries, which use an SRS design and approach comparable to the one proposed for this TLD. These reports provide evidence of Verisign’s ability to meet registry operation service level agreements (SLAs) comparable to those detailed in Specification 10. The reports are accessible at the following URL: http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄. 
In accordance with EPP Registry Performance Specifications detailed in Specification 10, Verisignʹs SRS meets the following performance attributes:
• EPP service availability: ≤ 864 minutes of downtime (≈98%)
• EPP session-command round trip time (RTT): ≤4000 milliseconds (ms), for at least 90 percent of the commands
• EPP query-command RTT: ≤2000 ms, for at least 90 percent of the commands
• EPP transform-command RTT: ≤4000 ms, for at least 90 percent of the commands

1 COMPLETE KNOWLEDGE AND UNDERSTANDING OF THIS ASPECT OF REGISTRY TECHNICAL REQUIREMENTS
Verisign, the Applicant’s selected backend registry services provider, has used Extensible Provisioning Protocol (EPP) since its inception and possesses complete knowledge and understanding of EPP registry systems. Its first EPP implementation— for a thick registry for the .name generic top-level domain (gTLD)—was in 2002. Since then Verisign has continued its RFC-compliant use of EPP in multiple TLDs, as detailed in Figure 25 1. 
Verisign’s understanding of EPP and its ability to implement code that complies with the applicable RFCs is unparalleled. Mr. Scott Hollenbeck, Verisign’s director of software development, authored the Extensible Provisioning Protocol and continues to be fully engaged in its refinement and enhancement (U.S. Patent Number 7299299 – Shared registration system for registering domain names). Verisign has also developed numerous new object mappings and object extensions following the guidelines in RFC 3735 (Guidelines for Extending the Extensible Provisioning Protocol). Mr. James Gould, a principal engineer at Verisign, led and co-authored the most recent EPP Domain Name System Security Extensions (DNSSEC) RFC effort (RFC 5910).
All registry systems for which Verisign is the registry operator or provides backend registry services use EPP. Upon approval of this application, Verisign will use EPP to provide the backend registry services for this gTLD. The .com, .net, and .name registries for which Verisign is the registry operator use an SRS design and approach comparable to the one proposed for this gTLD. Approximately 915 registrars use the Verisign EPP service, and the registry system performs more than 140 million EPP transactions daily without performance issues or restrictive maintenance windows. The processing time service level agreement (SLA) requirements for the Verisign-operated .net gTLD are the strictest of the current Verisign managed gTLDs. All processing times for Verisign-operated gTLDs can be found in ICANN’s Registry Operator’s Monthly Reports at http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄. 
Verisign has also been active on the Internet Engineering Task Force (IETF) Provisioning Registry Protocol (provreg) working group and mailing list since work started on the EPP protocol in 2000. This working group provided a forum for members of the Internet community to comment on Mr. Scott Hollenbeck’s initial EPP drafts, which Mr. Hollenbeck refined based on input and discussions with representatives from registries, registrars, and other interested parties. The working group has since concluded, but the mailing list is still active to enable discussion of different aspects of EPP.
1.1 EPP Interface with Registrars
Verisign, the Applicant’s selected backend registry services provider, fully supports the features defined in the EPP specifications and provides a set of software development kits (SDK) and tools to help registrars build secure and stable interfaces. Verisign’s SDKs give registrars the option of either fully writing their own EPP client software to integrate with the Shared Registration System (SRS), or using the Verisign-provided SDKs to aid them in the integration effort. Registrars can download the Verisign EPP SDKs and tools from the registrar website (http:⁄⁄www.Verisign.com⁄domain-name-services⁄current-registrars⁄epp-sdk⁄index.html). 
The EPP SDKs provide a host of features including connection pooling, Secure Sockets Layer (SSL), and a test server (stub server) to run EPP tests against. One tool—the EPP tool—provides a web interface for creating EPP Extensible Markup Language (XML) commands and sending them to a configurable set of target servers. This helps registrars in creating the template XML and testing a variety of test cases against the EPP servers. An Operational Test and Evaluation (OT&E) environment, which runs the same software as the production system so approved registrars can integrate and test their software before moving into a live production environment, is also available. 
2 TECHNICAL PLAN SCOPE⁄SCALE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY
Verisign, the Applicant’s selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies. 
Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the TLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to the Applicant fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.
3 TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION
Verisign, the Applicant’s selected backend registry services provider, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to the Applicant fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response. 
Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force. (Current statistics are publicly available in Verisign’s quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100 percent of the time for more than 13 years for .com, proving Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s TLD service offerings. 
Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support the provisioning of EPP services:
• Application Engineers: 19 
• Database Engineers: 3 
• Quality Assurance Engineers: 11 

To implement and manage the TLD as described in this application, Verisign, the Applicant’s selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area. 
When usage projections indicate a need for additional staff, Verisign’s internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed TLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internet’s largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.
4 ABILITY TO COMPLY WITH RELEVANT RFCS 
Verisign, the Applicant’s selected backend registry services provider, incorporates design reviews, code reviews, and peer reviews into its software development lifecycle (SDLC) to ensure compliance with the relevant RFCs. Verisign’s dedicated QA team creates extensive test plans and issues internal certifications when it has confirmed the accuracy of the code in relation to the RFC requirements. Verisign’s QA organization is independent from the development team within engineering. This separation helps Verisign ensure adopted processes and procedures are followed, further ensuring that all software releases fully consider the security and stability of the TLD. 
For the TLD, the Shared Registration System (SRS) complies with the following IETF EPP specifications, where the XML templates and XML schemas are defined in the following specifications:
• EPP RGP 3915 (http:⁄⁄www.apps.ietf.org⁄rfc⁄rfc3915.html): EPP Redemption Grace Period (RGP) Mapping specification for support of RGP statuses and support of Restore Request and Restore Report (authored by Verisign’s Scott Hollenbeck)
• EPP 5730 (http:⁄⁄tools.ietf.org⁄html⁄rfc5730): Base EPP specification (authored by Verisign’s Scott Hollenbeck)
• EPP Domain 5731 (http:⁄⁄tools.ietf.org⁄html⁄rfc5731): EPP Domain Name Mapping specification (authored by Verisign’s Scott Hollenbeck)
• EPP Host 5732 (http:⁄⁄tools.ietf.org⁄html⁄rfc5732): EPP Host Mapping specification (authored by Verisign’s Scott Hollenbeck)
• EPP Contact 5733 (http:⁄⁄tools.ietf.org⁄html⁄rfc5733): EPP Contact Mapping specification (authored by Verisign’s Scott Hollenbeck)
• EPP TCP 5734 (http:⁄⁄tools.ietf.org⁄html⁄rfc5734): EPP Transport over Transmission Control Protocol (TCP) specification (authored by Verisign’s Scott Hollenbeck)
• EPP DNSSEC 5910 (http:⁄⁄tools.ietf.org⁄html⁄rfc5910): EPP Domain Name System Security Extensions (DNSSEC) Mapping specification (authored by Verisign’s James Gould and Scott Hollenbeck)
5 PROPRIETARY EPP EXTENSIONS
Verisign, the Applicant’s selected backend registry services provider, uses its SRS to provide registry services. The SRS supports the following EPP specifications, which Verisign developed following the guidelines in RFC 3735, where the XML templates and XML schemas are defined in the specifications:
• IDN Language Tag (http:⁄⁄www.verisigninc.com⁄assets⁄idn-language-tag.pdf): EPP internationalized domain names (IDN) language tag extension used for IDN domain name registrations
• RGP Poll Mapping (http:⁄⁄www.verisigninc.com⁄assets⁄whois-info-extension.pdf): EPP mapping for an EPP poll message in support of Restore Request and Restore Report
• Whois Info Extension (http:⁄⁄www.verisigninc.com⁄assets⁄whois-info-extension.pdf): EPP extension for returning additional information needed for transfers
• EPP ConsoliDate Mapping (http:⁄⁄www.verisigninc.com⁄assets⁄consolidate-mapping.txt): EPP mapping to support a Domain Sync operation for synchronizing domain name expiration dates
• NameStore Extension (http:⁄⁄www.verisigninc.com⁄assets⁄namestore-extension.pdf): EPP extension for routing with an EPP intelligent gateway to a pluggable set of backend products and services
• Low Balance Mapping (http:⁄⁄www.verisigninc.com⁄assets⁄low-balance-mapping.pdf): EPP mapping to support low balance poll messages that proactively notify registrars of a low balance (available credit) condition
As part of the 2006 implementation report to bring the EPP RFC documents from Proposed Standard status to Draft Standard status, an implementation test matrix was completed. Two independently developed EPP client implementations based on the RFCs were tested against the Verisign EPP server for the domain, host, and contact transactions. No compliance-related issues were identified during this test, providing evidence that these extensions comply with RFC 3735 guidelines and further demonstrating Verisign’s ability to design, test, and deploy an RFC-compliant EPP implementation.
5.1 EPP Templates and Schemas
The EPP XML schemas are formal descriptions of the EPP XML templates. They are used to express the set of rules to which the EPP templates must conform in order to be considered valid by the schema. The EPP schemas define the building blocks of the EPP templates, describing the format of the data and the different EPP commands’ request and response formats. The current EPP implementations managed by Verisign, the Applicant’s selected backend registry services provider, use these EPP templates and schemas, as will the proposed TLD. For each proprietary XML template⁄schema Verisign provides a reference to the applicable template and includes the schema.


XML templates⁄schema for idnLang-1.0
• Template: The templates for idnLang-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄idn-language-tag.pdf. 
• Schema: This schema describes the extension mapping for the IDN language tag. The mapping extends the EPP domain name mapping to provide additional features required for the provisioning of IDN domain name registrations.

〈?xml version=ʺ1.0ʺ encoding=ʺUTF-8ʺ?〉

〈schema targetNamespace=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄idnLang-1.0ʺ
 xmlns:idnLang=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄idnLang-1.0ʺ
 xmlns=ʺhttp:⁄⁄www.w3.org⁄2001⁄XMLSchemaʺ
 elementFormDefault=ʺqualifiedʺ〉

〈annotation〉
 〈documentation〉
 Extensible Provisioning Protocol v1.0 domain name
 extension schema for IDN Lang Tag.
 〈⁄documentation〉
〈⁄annotation〉

〈!--
Child elements found in EPP commands.
--〉
 〈element name=ʺtagʺ type=ʺlanguageʺ⁄〉

 〈!--
 End of schema.
 --〉
〈⁄schema〉

XML templates⁄schema for rgp-poll-1.0
• Template: The templates for rgp-poll-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄rgp-poll-mapping.pdf.
• Schema: This schema describes the extension mapping for poll notifications. The mapping extends the EPP base mapping to provide additional features for registry grace period (RGP) poll notifications.

〈?xml version=ʺ1.0ʺ encoding=ʺUTF-8ʺ?〉

〈schema targetNamespace=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄rgp-poll-1.0ʺ
 xmlns:rgp-poll=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄rgp-poll-1.0ʺ
 xmlns:eppcom=ʺurn:ietf:params:xml:ns:eppcom-1.0ʺ
 xmlns:rgp=ʺurn:ietf:params:xml:ns:rgp-1.0ʺ
 xmlns=ʺhttp:⁄⁄www.w3.org⁄2001⁄XMLSchemaʺ
 elementFormDefault=ʺqualifiedʺ〉

〈!--
Import common element types.
--〉
〈import namespace=ʺurn:ietf:params:xml:ns:eppcom-1.0ʺ
 schemaLocation=ʺeppcom-1.0.xsdʺ⁄〉
〈import namespace=ʺurn:ietf:params:xml:ns:rgp-1.0ʺ
 schemaLocation=ʺrgp-1.0.xsdʺ⁄〉

〈annotation〉
 〈documentation〉
 Extensible Provisioning Protocol v1.0
 Verisign poll notification specification for registry grace period
 poll notifications.
 〈⁄documentation〉
〈⁄annotation〉

〈!--
Child elements found in EPP commands.
--〉
〈element name=ʺpollDataʺ type=ʺrgp-poll:pollDataTypeʺ⁄〉

〈!--
Child elements of the 〈notifyData〉 element for the
redemption grace period.
--〉
〈complexType name=ʺpollDataTypeʺ〉
 〈sequence〉
 〈element name=ʺnameʺ type=ʺeppcom:labelTypeʺ⁄〉
 〈element name=ʺrgpStatusʺ type=ʺrgp:statusTypeʺ⁄〉
 〈element name=ʺreqDateʺ type=ʺdateTimeʺ⁄〉
 〈element name=ʺreportDueDateʺ type=ʺdateTimeʺ⁄〉
 〈⁄sequence〉
〈⁄complexType〉
〈
!--
End of schema.
--〉
〈⁄schema〉

XML templates⁄schema for whoisInf-1.0
• Template: The templates for whoisInf-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄whois-info-extension.pdf.
• Schema: This schema describes the extension mapping for the Whois Info extension. The mapping extends the EPP domain name mapping to provide additional features for returning additional information needed for transfers.

〈?xml version=ʺ1.0ʺ encoding=ʺUTF-8ʺ?〉

〈schema targetNamespace=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄whoisInf-1.0ʺ
 xmlns:whoisInf=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄whoisInf-1.0ʺ
 xmlns:eppcom=ʺurn:ietf:params:xml:ns:eppcom-1.0ʺ
 xmlns=ʺhttp:⁄⁄www.w3.org⁄2001⁄XMLSchemaʺ
 elementFormDefault=ʺqualifiedʺ〉

〈import namespace=ʺurn:ietf:params:xml:ns:eppcom-1.0ʺ
 schemaLocation=ʺeppcom-1.0.xsdʺ⁄〉

〈annotation〉
 〈documentation〉
 Extensible Provisioning Protocol v1.0
 extension schema for Whois Info
 〈⁄documentation〉
〈⁄annotation〉

〈!--
Possible Whois Info extension root elements.
--〉
〈element name=ʺwhoisInfʺ type=ʺwhoisInf:whoisInfTypeʺ⁄〉
〈element name=ʺwhoisInfDataʺ type=ʺwhoisInf:whoisInfDataTypeʺ⁄〉

〈!--
Child elements for the 〈whoisInf〉 extension which
is used as an extension to an info command.
--〉
〈complexType name=ʺwhoisInfTypeʺ〉
 〈sequence〉
 〈element name=ʺflagʺ type=ʺbooleanʺ⁄〉
 〈⁄sequence〉
〈⁄complexType〉

〈!--
Child elements for the 〈whoisInfData〉 extension which
is used as an extension to the info response.
--〉
〈complexType name=ʺwhoisInfDataTypeʺ〉
 〈sequence〉
 〈element name=ʺregistrarʺ type=ʺstringʺ⁄〉
 〈element name=ʺwhoisServerʺ type=ʺeppcom:labelTypeʺ
 minOccurs=ʺ0ʺ⁄〉
 〈element name=ʺurlʺ type=ʺtokenʺ minOccurs=ʺ0ʺ⁄〉
 〈element name=ʺirisServerʺ type=ʺeppcom:labelTypeʺ
 minOccurs=ʺ0ʺ⁄〉
 〈⁄sequence〉
 〈⁄complexType〉

〈⁄schema〉

XML templates⁄schema for sync-1.0 (consoliDate)
• Template: The templates for sync-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄consolidate-mapping.txt.
• Schema: This schema describes the extension mapping for the synchronization of domain name registration period expiration dates. This service is known as ʺConsoliDate.ʺ The mapping extends the EPP domain name mapping to provide features that allow a protocol client to end a domain name registration period on a specific month and day.

 〈?xml version=ʺ1.0ʺ encoding=ʺUTF-8ʺ?〉

 〈schema targetNamespace=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄sync-1.0ʺ
 xmlns:sync=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄sync-1.0ʺ
 xmlns=ʺhttp:⁄⁄www.w3.org⁄2001⁄XMLSchemaʺ
 elementFormDefault=ʺqualifiedʺ〉

 〈annotation〉
 〈documentation〉
 Extensible Provisioning Protocol v1.0 domain name
 extension schema for expiration date synchronization.
 〈⁄documentation〉
 〈⁄annotation〉

 〈!--
 Child elements found in EPP commands.
 --〉
 〈element name=ʺupdateʺ type=ʺsync:updateTypeʺ⁄〉

 〈!--
 Child elements of the 〈update〉 command.
 --〉
 〈complexType name=ʺupdateTypeʺ〉
 〈sequence〉
 〈element name=ʺexpMonthDayʺ type=ʺgMonthDayʺ⁄〉
 〈⁄sequence〉
 〈⁄complexType〉

 〈!--
 End of schema.
 --〉
 〈⁄schema〉

XML templates⁄schema for namestoreExt-1.1
• Template: The templates for namestoreExt-1.1 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄namestore-extension.pdf.
• Schema: This schema describes the extension mapping for the routing with an EPP intelligent gateway to a pluggable set of backend products and services. The mapping extends the EPP domain name and host mapping to provide a sub-product identifier to identify the target sub-product that the EPP operation is intended for.

〈?xml version=ʺ1.0ʺ encoding=ʺUTF-8ʺ?〉

〈schema targetNamespace=ʺhttp:⁄⁄www.Verisign-grs.com⁄epp⁄namestoreExt-1.1ʺ
 xmlns=ʺhttp:⁄⁄www.w3.org⁄2001⁄XMLSchemaʺ
 xmlns:namestoreExt=ʺhttp:⁄⁄www.Verisign-grs.com⁄epp⁄namestoreExt-1.1ʺ
 elementFormDefault=ʺqualifiedʺ〉

〈annotation〉
 〈documentation〉
 Extensible Provisioning Protocol v1.0 Namestore extension schema
 for destination registry routing.
 〈⁄documentation〉
〈⁄annotation〉

〈!-- General Data types. --〉
〈simpleType name=ʺsubProductTypeʺ〉
 〈restriction base=ʺtokenʺ〉
 〈minLength value=ʺ1ʺ⁄〉
 〈maxLength value=ʺ64ʺ⁄〉
 〈⁄restriction〉
〈⁄simpleType〉

〈complexType name=ʺextAnyTypeʺ〉
 〈sequence〉
 〈any namespace=ʺ##otherʺ maxOccurs=ʺunboundedʺ⁄〉
 〈⁄sequence〉
〈⁄complexType〉

〈!-- Child elements found in EPP commands and responses. --〉
〈element name=ʺnamestoreExtʺ type=ʺnamestoreExt:namestoreExtTypeʺ⁄〉

〈!-- Child elements of the 〈product〉 command. --〉
〈complexType name=ʺnamestoreExtTypeʺ〉
 〈sequence〉
 〈element name=ʺsubProductʺ
 type=ʺnamestoreExt:subProductTypeʺ⁄〉
 〈⁄sequence〉
〈⁄complexType〉

〈!-- Child response elements. --〉
〈element name=ʺnsExtErrDataʺ type=ʺnamestoreExt:nsExtErrDataTypeʺ⁄〉

〈!-- 〈prdErrData〉 error response elements. --〉
〈complexType name=ʺnsExtErrDataTypeʺ〉
 〈sequence〉
 〈element name=ʺmsgʺ type=ʺnamestoreExt:msgTypeʺ⁄〉
 〈⁄sequence〉
 〈⁄complexType〉

〈!-- 〈prdErrData〉 〈msg〉 element. --〉
〈complexType name=ʺmsgTypeʺ〉
 〈simpleContent〉
 〈extension base=ʺnormalizedStringʺ〉
 〈attribute name=ʺcodeʺ
 type=ʺnamestoreExt:prdErrCodeTypeʺ use=ʺrequiredʺ⁄〉
 〈attribute name=ʺlangʺ type=ʺlanguageʺ default=ʺenʺ⁄〉
 〈⁄extension〉
 〈⁄simpleContent〉
〈⁄complexType〉

〈!-- 〈prdErrData〉 error response codes. --〉
〈simpleType name=ʺprdErrCodeTypeʺ〉
 〈restriction base=ʺunsignedShortʺ〉
 〈enumeration value=ʺ1ʺ⁄〉
 〈⁄restriction〉
〈⁄simpleType〉

〈!-- End of schema. --〉
〈⁄schema〉

XML templates⁄schema for lowbalance-poll-1.0
• Template: The templates for lowbalance-poll-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄low-balance-mapping.pdf.
• Schema: This schema describes the extension mapping for the account low balance notification. The mapping extends the EPP base mapping so an account holder can be notified via EPP poll messages whenever the available credit for an account reaches or goes below the credit threshold.

〈?xml version=ʺ1.0ʺ encoding=ʺUTF-8ʺ?〉

〈schema targetNamespace=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄lowbalance-poll-1.0ʺ
 xmlns:lowbalance-poll=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄lowbalance-poll-1.0ʺ
 xmlns:eppcom=ʺurn:ietf:params:xml:ns:eppcom-1.0ʺ
 xmlns=ʺhttp:⁄⁄www.w3.org⁄2001⁄XMLSchemaʺ
 elementFormDefault=ʺqualifiedʺ〉

〈!-- Import common element types.--〉
〈import namespace=ʺurn:ietf:params:xml:ns:eppcom-1.0ʺ
 schemaLocation=ʺeppcom-1.0.xsdʺ⁄〉

〈annotation〉
 〈documentation〉
 Extensible Provisioning Protocol v1.0
 Verisign poll notification specification for low balance notifications.
 〈⁄documentation〉
〈⁄annotation〉

〈!--Child elements found in EPP commands.--〉
〈element name=ʺpollDataʺ type=ʺlowbalance-poll:pollDataTypeʺ⁄〉

〈!--Child elements of the 〈notifyData〉 element for the low balance.--〉
〈complexType name=ʺpollDataTypeʺ〉
 〈sequence〉
 〈element name=ʺregistrarNameʺ type=ʺeppcom:labelTypeʺ⁄〉
 〈element name=ʺcreditLimitʺ type=ʺnormalizedStringʺ⁄〉
 〈element name=ʺcreditThresholdʺ
 type=ʺlowbalance-poll:thresholdTypeʺ⁄〉
 〈element name=ʺavailableCreditʺ type=ʺnormalizedStringʺ⁄〉
 〈⁄sequence〉
〈⁄complexType〉

〈complexType name=ʺthresholdTypeʺ〉
 〈simpleContent〉
 〈extension base=ʺnormalizedStringʺ〉
 〈attribute name=ʺtypeʺ
 type=ʺlowbalance-poll:thresholdValueTypeʺ
 use=ʺrequiredʺ⁄〉
 〈⁄extension〉
 〈⁄simpleContent〉
〈⁄complexType〉

〈simpleType name=ʺthresholdValueTypeʺ〉
 〈restriction base=ʺtokenʺ〉
 〈enumeration value=ʺFIXEDʺ⁄〉
 〈enumeration value=ʺPERCENTʺ⁄〉
 〈⁄restriction〉
〈⁄simpleType〉

〈!-- End of schema.--〉
〈⁄schema〉

6 PROPRIETARY EPP EXTENSION CONSISTENCY WITH REGISTRATION LIFECYCLE 
The Applicant’s selected backend registry services provider’s (Verisign’s) proprietary EPP extensions, defined in Section 5 above, are consistent with the registration lifecycle documented in the response to Question 27, Registration Lifecycle. Details of the registration lifecycle are presented in that response. As new registry features are required, Verisign develops proprietary EPP extensions to address new operational requirements. Consistent with ICANN procedures Verisign adheres to all applicable Registry Services Evaluation Process (RSEP) procedures. 

1 COMPLETE KNOWLEDGE AND UNDERSTANDING OF THIS ASPECT OF REGISTRY TECHNICAL REQUIREMENTS
Verisign, the Applicant’s selected backend registry services provider, has operated the Whois lookup service for the gTLDs and ccTLDs it manages since 1991, and will provide these proven services for the TLD registry. In addition, it continues to work with the Internet community to improve the utility of Whois data, while thwarting its application for abusive uses.
1.1 High-Level Whois System Description
Like all other components of the Applicant’s selected backend registry services provider’s (Verisign’s) registry service, Verisign’s Whois system is designed and built for both reliability and performance in full compliance with applicable RFCs. Verisign’s current Whois implementation has answered more than five billion Whois queries per month for the TLDs it manages, and has experienced more than 250,000 queries per minute in peak conditions. The proposed gTLD uses a Whois system design and approach that is comparable to the current implementation. Independent quality control testing ensures Verisign’s Whois service is RFC-compliant through all phases of its lifecycle. 
Verisignʹs redundant Whois databases further contribute to overall system availability and reliability. The hardware and software for its Whois service is architected to scale both horizontally (by adding more servers) and vertically (by adding more CPUs and memory to existing servers) to meet future need.
Verisign can fine-tune access to its Whois database on an individual Internet Protocol (IP) address basis, and it works with registrars to help ensure their services are not limited by any restriction placed on Whois. Verisign provides near real-time updates for Whois services for the TLDs under its management. As information is updated in the registration database, it is propagated to the Whois servers for quick publication. These updates align with the near real-time publication of Domain Name System (DNS) information as it is updated in the registration database. This capability is important for the TLD registry as it is Verisign’s experience that when DNS data is updated in near real time, so should Whois data be updated to reflect the registration specifics of those domain names.
Verisign’s Whois response time has been less than 500 milliseconds for 95 percent of all Whois queries in .com, .net, .tv, and .cc. The response time in these TLDs, combined with Verisign’s capacity, enables the Whois system to respond to up to 30,000 searches (or queries) per second for a total capacity of 2.6 billion queries per day.
The Whois software written by Verisign complies with RFC 3912. Verisign uses an advanced in-memory database technology to provide exceptional overall system performance and security. In accordance with RFC 3912, Verisign provides a website at whois.nic.〈TLD〉 that provides free public query-based access to the registration data. 
Verisign currently operates both thin and thick Whois systems. 
Verisign commits to implementing a RESTful Whois service upon finalization of agreements with the IETF (Internet Engineering Task Force).
Provided Functionalities for User Interface
To use the Whois service via port 43, the user enters the applicable parameter on the command line as illustrated here:
• For domain name: whois EXAMPLE.TLD
• For registrar: whois ʺregistrar Example Registrar, Inc.ʺ
• For name server: whois ʺNS1.EXAMPLE.TLDʺ or whois ʺname server (IP address)ʺ

To use the Whois service via the web-based directory service search interface:
• Go to http:⁄⁄whois.nic.〈TLD〉
• Click on the appropriate button (Domain, Registrar, or Name Server)
• Enter the applicable parameter:
o Domain name, including the TLD (e.g., EXAMPLE.TLD)
o Full name of the registrar, including punctuation (e.g., Example Registrar, Inc.)
o Full host name or the IP address (e.g., NS1.EXAMPLE.TLD or 198.41.3.39)
• Click on the Submit button.
Provisions to Ensure That Access Is Limited to Legitimate Authorized Users and Is in Compliance with Applicable Privacy Laws or Policies
To further promote reliable and secure Whois operations, Verisign, the Applicant’s selected backend registry services provider, has implemented rate-limiting characteristics within the Whois service software. For example, to prevent data mining or other abusive behavior, the service can throttle a specific requestor if the query rate exceeds a configurable threshold. In addition, QoS technology enables rate limiting of queries before they reach the servers, which helps protect against denial of service (DoS) and distributed denial of service (DDoS) attacks. 
Verisign’s software also permits restrictions on search capabilities. For example, wild card searches can be disabled. If needed, it is possible to temporarily restrict and⁄or block requests coming from specific IP addresses for a configurable amount of time. Additional features that are configurable in the Whois software include help files, headers and footers for Whois query responses, statistics, and methods to memory map the database. Furthermore, Verisign is European Union (EU) Safe Harbor certified and has worked with European data protection authorities to address applicable privacy laws by developing a tiered Whois access structure that requires users who require access to more extensive data to (i) identify themselves, (ii) confirm that their use is for a specified purpose and (iii) enter into an agreement governing their use of the more extensive Whois data. 
1.2 Relevant Network Diagrams
Figure ‎26 1 provides a summary network diagram of the Whois service provided by Verisign, the Applicant’s selected backend registry services provider. The figure details the configuration with one resolution⁄Whois site. For this TLD Verisign provides Whois service from 6 of its 17 primary sites based on the proposed gTLD’s traffic volume and patterns. A functionally equivalent resolution architecture configuration exists at each Whois site. 
1.3 IT and Infrastructure Resources
Figure ‎26 2 summarizes the IT and infrastructure resources that Verisign, the Applicant’s selected backend registry services provider, uses to provision Whois services from Verisign primary resolution sites. As needed, virtual machines are created based on actual and projected demand.

1.4 Description of Interconnectivity with Other Registry Systems
Figure ‎26 3 provides a technical overview of the registry system provided by Verisign, the Applicant’s selected backend registry services provider, and shows how the Whois service component fits into this larger system and interconnects with other system components. 
1.5 Frequency of Synchronization Between Servers
Synchronization between the SRS and the geographically distributed Whois resolution sites occurs approximately every three minutes. Verisign, the Applicant’s selected backend registry services provider, uses a two-part Whois update process to ensure Whois data is accurate and available. Every 12 hours an initial file is distributed to each resolution site. This file is a complete copy of all Whois data fields associated with each domain name under management. As interactions with the SRS cause the Whois data to be changed, these incremental changes are distributed to the resolution sites as an incremental file update. This incremental update occurs approximately every three minutes. When the new 12-hour full update is distributed, this file includes all past incremental updates. Verisign’s approach to frequency of synchronization between servers meets the Performance Specifications defined in Specification 10 of the Registry Agreement for new gTLDs. 
2 TECHNICAL PLAN SCOPE⁄SCALE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY
Verisign, the Applicant’s selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies. 
Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the TLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to the Applicant fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.
3 TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION
Verisign, the Applicant’s selected backend registry services provider, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to the Applicant fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response. 
Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force. (Current statistics are publicly available in Verisign’s quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100 percent of the time for more than 13 years for .com, proving Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s TLD service offerings. 
Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support Whois services:
• Application Engineers: 19
• Database Engineers: 3
• Quality Assurance Engineers: 11

To implement and manage the TLD as described in this application, Verisign, the Applicant’s selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area. 
When usage projections indicate a need for additional staff, Verisign’s internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed gTLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internet’s largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.
4 COMPLIANCE WITH RELEVANT RFC
The Applicant’s selected backend registry services provider’s (Verisign’s) Whois service complies with the data formats defined in Specification 4 of the Registry Agreement. Verisign will provision Whois services for registered domain names and associated data in the top-level domain (TLD). Verisign’s Whois services are accessible over Internet Protocol version 4 (IPv4) and Internet Protocol version 6 (IPv6), via both Transmission Control Protocol (TCP) port 43 and a web-based directory service at whois.nic.〈TLD〉, which in accordance with RFC 3912, provides free public query-based access to domain name, registrar, and name server lookups. Verisign’s proposed Whois system meets all requirements as defined by ICANN for each registry under Verisign management. Evidence of this successful implementation, and thus compliance with the applicable RFCs, can be verified by a review of the .com and .net Registry Operator’s Monthly Reports that Verisign files with ICANN. These reports provide evidence of Verisign’s ability to meet registry operation service level agreements (SLAs) comparable to those detailed in Specification 10. The reports are accessible at the following URL: http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄. 
5 COMPLIANCE WITH SPECIFICATIONS 4 AND 10 OF REGISTRY AGREEMENT
In accordance with Specification 4, Verisign, the Applicant’s selected backend registry services provider, provides a Whois service that is available via both port 43 in accordance with RFC 3912, and a web-based directory service at whois.nic.〈TLD〉 also in accordance with RFC 3912, thereby providing free public query-based access. Verisign acknowledges that ICANN reserves the right to specify alternative formats and protocols, and upon such specification, Verisign will implement such alternative specification as soon as reasonably practicable.
The format of the following data fields conforms to the mappings specified in Extensible Provisioning Protocol (EPP) RFCs 5730 – 5734 so the display of this information (or values returned in Whois responses) can be uniformly processed and understood: domain name status, individual and organizational names, address, street, city, state⁄province, postal code, country, telephone and fax numbers, email addresses, date, and times.
Specifications for data objects, bulk access, and lookups comply with Specification 4 and are detailed in the following subsections, provided in both bulk access and lookup modes. 
Bulk Access Mode. This data is provided on a daily schedule to a party designated from time to time in writing by ICANN. The specification of the content and format of this data, and the procedures for providing access, shall be as stated below, until revised in the ICANN Registry Agreement. 
The data is provided in three files:
• Domain Name File: For each domain name, the file provides the domain name, server name for each name server, registrar ID, and updated date.
• Name Server File: For each registered name server, the file provides the server name, each IP address, registrar ID, and updated date.
• Registrar File: For each registrar, the following data elements are provided: registrar ID, registrar address, registrar telephone number, registrar email address, Whois server, referral URL, updated date, and the name, telephone number, and email address of all the registrarʹs administrative, billing, and technical contacts.

Lookup Mode. Figures ‎26 4 through Figure ‎26 6 provide the query and response format for domain name, registrar, and name server data objects.
5.1 Specification 10, RDDS Registry Performance Specifications
The Whois service meets all registration data directory services (RDDS) registry performance specifications detailed in Specification 10, Section 2. Evidence of this performance can be verified by a review of the .com and .net Registry Operator’s Monthly Reports that Verisign files monthly with ICANN. These reports are accessible from the ICANN website at the following URL: http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄. 

In accordance with RDDS registry performance specifications detailed in Specification 10, Verisignʹs Whois service meets the following proven performance attributes:
• RDDS availability: 864 min of downtime (98%)
• RDDS query RTT: 2000 ms, for at least 95% of the queries
• RDDS update time: 60 min, for at least 95% of the probes
6 SEARCHABLE WHOIS
Verisign, the Applicant’s selected backend registry services provider, provides a searchable Whois service for the TLD. Verisign has experience in providing tiered access to Whois for the .name registry, and uses these methods and control structures to help reduce potential malicious use of the function. The searchable Whois system currently uses Apache’s Lucene full text search engine to index relevant Whois content with near-real time incremental updates from the provisioning system.
Features of the Verisign searchable Whois function include:

• Provision of a web-based searchable directory service
• Ability to perform partial match, at least, for the following data fields: domain name, contacts and registrant’s name, and contact and registrant’s postal address, including all the sub-fields described in EPP (e.g., street, city, state, or province)
• Ability to perform exact match, at least, on the following fields: registrar ID, name server name, and name server’s IP address (only applies to IP addresses stored by the registry, i.e., glue records)
• Ability to perform Boolean search supporting, at least, the following logical operators to join a set of search criteria: AND, OR, NOT 
• Search results that include domain names that match the selected search criteria

Verisign’s implementation of searchable Whois is EU Safe Harbor certified and includes appropriate access control measures that help ensure that only legitimate authorized users can use the service. Furthermore, Verisign’s compliance office monitors current ICANN policy and applicable privacy laws or policies to help ensure the solution is maintained within compliance of applicable regulations. Features of these access control measures include: 

• All unauthenticated searches are returned as thin results.
• Registry system authentication is used to grant access to appropriate users for thick Whois data search results.
• Account access is granted by the Applicant’s defined TLD admin user.

Potential Forms of Abuse and Related Risk Mitigation. Leveraging its experience providing tiered access to Whois for the .name registry and interacting with ICANN, data protection authorities, and applicable industry groups, Verisign, the Applicant’s selected backend registry services provider, is knowledgeable of the likely data mining forms of abuse associated with a searchable Whois service. Figure ‎26 7 summarizes these potential forms of abuse and Verisign’s approach to mitigate the identified risk.

1 COMPLETE KNOWLEDGE AND UNDERSTANDING OF REGISTRATION LIFECYCLES AND STATES
Starting with domain name registration and continuing through domain name delete operations, the Applicant’s selected backend registry services provider’s (Verisign’s) registry implements the full registration lifecycle for domain names supporting the operations in the Extensible Provisioning Protocol (EPP) specification. The registration lifecycle of the domain name starts with registration and traverses various states as specified in the following sections. The registry system provides options to update domain names with different server and client status codes that block operations based on the EPP specification. The system also provides different grace periods for different billable operations, where the price of the billable operation is credited back to the registrar if the billable operation is removed within the grace period. Together Figure 27 1 and Figure 27 2 define the registration states comprising the registration lifecycle and explain the trigger points that cause state-to-state transitions. States are represented as green rectangles within Figure 27 1.
1.1 Registration Lifecycle of Create⁄Update⁄Delete
The following section details the create⁄update⁄delete processes and the related renewal process that Verisign, the Applicant’s selected backend registry services provider, follows. For each process, this response defines the process function and its characterization, and as appropriate provides a process flow chart. 
Create Process. The domain name lifecycle begins with a registration or what is referred to as a Domain Name Create operation in EPP. The system fully supports the EPP Domain Name Mapping as defined by RFC 5731, where the associated objects (e.g., hosts and contacts) are created independent of the domain name.
Process Characterization. The Domain Name Create command is received, validated, run through a set of business rules, persisted to the database, and committed in the database if all business rules pass. The domain name is included with the data flow to the DNS and Whois resolution services. If no name servers are supplied, the domain name is not included with the data flow to the DNS. A successfully created domain name has the created date and expiration date set in the database. Creates are subject to grace periods as described in Section 1.3 of this response, Add Grace Period, Redemption Grace Period, and Notice Periods for Renewals or Transfers. 
The Domain Name Create operation is detailed in Figure 27 3 and requires the following attributes:
• A domain name that meets the string restrictions.
• A domain name that does not already exist.
• The registrar is authorized to create a domain name in the TLD.
• The registrar has available credit.
• A valid Authorization Information (Auth-Info) value.
• Required contacts (e.g., registrant, administrative contact, technical contact, and billing contact) are specified and exist.
• The specified name servers (hosts) exist, and there is a maximum of 13 name servers.
• A period in units of years with a maximum value of 10 (default period is one year).
Renewal Process. The domain name can be renewed unless it has any form of Pending Delete, Pending Transfer, or Renew Prohibited.

A request for renewal that sets the expiry date to more than ten years in the future is denied. The registrar must pass the current expiration date (without the timestamp) to support the idempotent features of EPP, where sending the same command a second time does not cause unexpected side effects.
Automatic renewal occurs when a domain name expires. On the expiration date, the registry extends the registration period one year and debits the registrar account balance. In the case of an auto-renewal of the domain name, a separate Auto-Renew grace period applies. Renewals are subject to grace periods as described in Section 1.3 of this response, Add Grace Period, Redemption Grace Period, and Notice Periods for Renewals or Transfers.
Process Characterization. The Domain Name Renew command is received, validated, authorized, and run through a set of business rules. The data is updated and committed in the database if it passes all business rules. The updated domain name’s expiration date is included in the flow to the Whois resolution service. 
The Domain Name Renew operation is detailed in Figure 27 4 and requires the following attributes:
• A domain name that exists and is sponsored by the requesting registrar.
• The registrar is authorized to renew a domain name in the TLD.
• The registrar has available credit.
• The passed current expiration date matches the domain name’s expiration date.
• A period in units of years with a maximum value of 10 (default period is one year). A domain name expiry past ten years is not allowed.
Registrar Transfer Procedures. A registrant may transfer his⁄her domain name from his⁄her current registrar to another registrar. The database system allows a transfer as long as the transfer is not within the initial 60 days, per industry standard, of the original registration date. 
The registrar transfer process goes through many process states, which are described in detail below, unless it has any form of Pending Delete, Pending Transfer, or Transfer Prohibited.
A transfer can only be initiated when the appropriate Auth-Info is supplied. The Auth-Info for transfer is only available to the current registrar. Any other registrar requesting to initiate a transfer on behalf of a registrant must obtain the Auth-Info from the registrant.
The Auth-Info is made available to the registrant upon request. The registrant is the only party other than the current registrar that has access to the Auth-Info. Registrar transfer entails a specified extension of the expiry date for the object. The registrar transfer is a billable operation and is charged identically to a renewal for the same extension of the period. This period can be from one to ten years, in one-year increments.
Because registrar transfer involves an extension of the registration period, the rules and policies applying to how the resulting expiry date is set after transfer are based on the renewal policies on extension.
Per industry standard, a domain name cannot be transferred to another registrar within the first 60 days after registration. This restriction continues to apply if the domain name is renewed during the first 60 days. Transfer of the domain name changes the sponsoring registrar of the domain name, and also changes the child hosts (ns1.sample.xyz) of the domain name (sample .xyz). 
The domain name transfer consists of five separate operations:
• Transfer Request (Figure 27 5): Executed by a non-sponsoring registrar with the valid Auth-Info provided by the registrant. The Transfer Request holds funds of the requesting registrar but does not bill the registrar until the transfer is completed. The sponsoring registrar receives a Transfer Request poll message.
• Transfer Cancel (Figure 27 6): Executed by the requesting registrar to cancel the pending transfer. The held funds of the requesting registrar are reversed. The sponsoring registrar receives a Transfer Cancel poll message.
• Transfer Approve (Figure 27 7): Executed by the sponsoring registrar to approve the Transfer Request. The requesting registrar is billed for the Transfer Request and the sponsoring registrar is credited for an applicable Auto-Renew grace period. The requesting registrar receives a Transfer Approve poll message.
• Transfer Reject (Figure 27 8): Executed by the sponsoring registrar to reject the pending transfer. The held funds of the requesting registrar are reversed. The requesting registrar receives a Transfer Reject poll message.
• Transfer Query (Figure 27 9): Executed by either the requesting registrar or the sponsoring registrar of the last transfer.

The registry auto-approves a transfer if the sponsoring registrar takes no action. The requesting registrar is billed for the Transfer Request and the sponsoring registrar is credited for an applicable Auto-Renew grace period. The requesting registrar and the sponsoring registrar receive a Transfer Auto-Approve poll message. 
Delete Process. A registrar may choose to delete the domain name at any time. 
Process Characterization. The domain name can be deleted, unless it has any form of Pending Delete, Pending Transfer, or Delete Prohibited.
A domain name is also prohibited from deletion if it has any in-zone child hosts that are name servers for domain names. For example, the domain name “sample.xyz” cannot be deleted if an in-zone host “ns.sample.xyz” exists and is a name server for “sample2.xyz.”
If the Domain Name Delete occurs within the Add grace period, the domain name is immediately deleted and the sponsoring registrar is credited for the Domain Name Create. If the Domain Name Delete occurs outside the Add grace period, it follows the Redemption grace period (RGP) lifecycle.
Update Process. The sponsoring registrar can update the following attributes of a domain name:
• Auth-Info
• Name servers
• Contacts (i.e., registrant, administrative contact, technical contact, and billing contact)
• Statuses (e.g., Client Delete Prohibited, Client Hold, Client Renew Prohibited, Client Transfer Prohibited, Client Update Prohibited)

Process Characterization. Updates are allowed provided that the update includes the removal of any Update Prohibited status. The Domain Name Update operation is detailed in Figure 27 10. 
A domain name can be updated unless it has any form of Pending Delete, Pending Transfer, or Update Prohibited.

1.2 Pending, Locked, Expired, and Transferred 
Verisign, the Applicant’s selected backend registry services provider, handles pending, locked, expired, and transferred domain names as described here. When the domain name is deleted after the five-day Add grace period, it enters into the Pending Delete state. The registrant can return its domain name to active any time within the five-day Pending Delete grace period. After the five-day Pending Delete grace period expires, the domain name enters the Redemption Pending state and then is deleted by the system. The registrant can restore the domain name at any time during the Redemption Pending state.
When a non-sponsoring registrar initiates the domain name transfer request, the domain name enters Pending Transfer state and a notification is mailed to the sponsoring registrar for approvals. If the sponsoring registrar doesn’t respond within five days, the Pending Transfer expires and the transfer request is automatically approved.
EPP specifies both client (registrar) and server (registry) status codes that can be used to prevent registry changes that are not intended by the registrant. Currently, many registrars use the client status codes to protect against inadvertent modifications that would affect their customers’ high-profile or valuable domain names. 
Verisign’s registry service supports the following client (registrar) and server (registry) status codes:
• clientHold
• clientRenewProhibited
• clientTransferProhibited
• clientUpdateProhibited
• clientDeleteProhibited
• serverHold
• serverRenewProhibited
• serverTransferProhibited
• serverUpdateProhibited
• serverDeleteProhibited 
1.3 Add Grace Period, Redemption Grace Period, and Notice Periods for Renewals or Transfers
Verisign, the Applicant’s selected backend registry services provider, handles Add grace periods, Redemption grace periods, and notice periods for renewals or transfers as described here.
• Add Grace Period: The Add grace period is a specified number of days following the initial registration of the domain name. The current value of the Add grace period for all registrars is five days. 
• Redemption Grace Period: If the domain name is deleted after the five-day grace period expires, it enters the Redemption grace period and then is deleted by the system. The registrant has an option to use the Restore Request command to restore the domain name within the Redemption grace period. In this scenario, the domain name goes to Pending Restore state if there is a Restore Request command within 30 days of the Redemption grace period. From the Pending Restore state, it goes either to the OK state, if there is a Restore Report Submission command within seven days of the Restore Request grace period, or a Redemption Period state if there is no Restore Report Submission command within seven days of the Restore Request grace period. 
• Renew Grace Period: The Renew⁄Extend grace period is a specified number of days following the renewal⁄extension of the domain name’s registration period. The current value of the Renew⁄Extend grace period is five days. 
• Auto-Renew Grace Period: All auto-renewed domain names have a grace period of 45 days. 
• Transfer Grace Period: Domain names have a five-day Transfer grace period. 
1.4 Aspects of the Registration Lifecycle Not Covered by Standard EPP RFCs
The Applicant’s selected backend registry services provider’s (Verisign’s) registration lifecycle processes and code implementations adhere to the standard EPP RFCs related to the registration lifecycle. By adhering to the RFCs, Verisign’s registration lifecycle is complete and addresses each registration-related task comprising the lifecycle. No aspect of Verisign’s registration lifecycle is not covered by one of the standard EPP RFCs and thus no additional definitions are provided in this response.
2 CONSISTENCY WITH ANY SPECIFIC COMMITMENTS MADE TO REGISTRANTS AS ADAPTED TO THE OVERALL BUSINESS APPROACH FOR THE PROPOSED gTLD
The registration lifecycle described above applies to this TLD as well as other TLDs managed by Verisign, the Applicant’s selected backend registry services provider; thus Verisign remains consistent with commitments made to its registrants. No unique or specific registration lifecycle modifications or adaptations are required to support the overall business approach for the TLD. 
To accommodate a range of registries, Verisign’s registry implementation is capable of offering both a thin and thick Whois implementation, which is also built upon Verisign’s award-winning ATLAS infrastructure.
3 COMPLIANCE WITH RELEVANT RFCs
The Applicant’s selected backend registry services provider’s (Verisign’s) registration lifecycle complies with applicable RFCs, specifically RFCs 5730 – 5734 and 3915. The system fully supports the EPP Domain Name Mapping as defined by RFC 5731, where the associated objects (e.g., hosts and contacts) are created independent of the domain name.

In addition, in accordance with RFCs 5732 and 5733, the Verisign registration system enforces the following domain name registration constraints:
• Uniqueness⁄Multiplicity: A second-level domain name is unique in the TLD database. Two identical second-level domain names cannot simultaneously exist in the TLD. Further, a second-level domain name cannot be created if it conflicts with a reserved domain name.
• Point of Contact Associations: The domain name is associated with the following points of contact. Contacts are created and managed independently according to RFC 5733. 
• Registrant
• Administrative contact
• Technical contact
• Billing contact
• Domain Name Associations: Each domain name is associated with:
• A maximum of 13 hosts, which are created and managed independently according to RFC 5732
• An Auth-Info, which is used to authorize certain operations on the object
• Status(es), which are used to describe the domain name’s status in the registry
• A created date, updated date, and expiry date

4 DEMONSTRATES THAT TECHNICAL RESOURCES REQUIRED TO CARRY THROUGH THE PLANS FOR THIS ELEMENT ARE ALREADY ON HAND OR READILY AVAILABLE
Verisign, the Applicant’s selected backend registry services provider, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to the Applicant fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response. 
Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force. (Current statistics are publicly available in Verisign’s quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100 percent of the time for more than 13 years for .com, proving Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s TLD service offerings.

Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support the registration lifecycle:
• Application Engineers: 19 
• Customer Support Personnel: 36 
• Database Administrators: 8 
• Database Engineers: 3 
• Quality Assurance Engineers: 11 
• SRS System Administrators: 13 

To implement and manage the TLD as described in this application, Verisign, the Applicant’s selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area. 
When usage projections indicate a need for additional staff, Verisign’s internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed gTLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internet’s largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.

1. COMPREHENSIVE ABUSE POLICIES, WHICH INCLUDE CLEAR DEFINITIONS OF WHAT CONSTITUTES ABUSE IN THE TLD, AND PROCEDURES THAT WILL EFFECTIVELY MINIMIZE POTENTIAL FOR ABUSE IN THE TLD
Applicant intends to request from ICANN an exemption from Specification 9 of the ICANN-Registry Operator Registry Agreement. As such, Applicant intends to function in such a way that all domain name registrations in the TLD shall be registered to and maintained by Applicant and Applicant will not sell, distribute or transfer control of domain name registrations to any party that is not an Affiliate of Applicant as defined in the ICANN-Registry Operator Registry Agreement. All domain name registrations intended to be used within Applicant’s registry will be registered to and controlled and maintained by Applicant and for the benefit of Applicant and its users, parents, sisters and Affiliates. 

In the event that Applicant is not granted an exemption from Specification 9, Applicant will partner with a corporate registrar with expertise in running a registry to support such efforts. Applicant intends to partner with its current corporate registrar or one of similar technical capability and expertise and allocate the appropriate funds and human resources to ensure that both itself, as the registry operator, and its selected registrar are at all times in compliance with ICANN guidelines.

Several measures for discouraging domain name abuse in the Applicant’s TLD and the registration in the Applicant’s TLD of domain names that infringe the intellectual property rights of others are detailed within this section, in the response to question #29 and throughout other portions of the application. Additionally, it is noted that a major concern of other TLDs, namely, trademark infringement, is of lesser concern as such relates to the Applicant’s TLD. There will be little to no risk of domain name abuse and improper registration of any infringing subdomains or the like in the TLD and Applicant believes sufficient protection for famous names and trademarks will be provided for because of the fact that: (i) Applicant’s TLD intends to function as a Specification 9 exempt TLD and, thus, all registrations will be approved by and registered only to Applicant; (ii) Applicant will implement and comply with all ICANN-mandated rights protection mechanisms (see response to question #29), and (iii) Applicant’s current policies will prohibit any registrations by any party that is not the Applicant and registrations will be associated with Applicant and its users, parents, sisters and Affiliates, and more particularly, the content and branded material associated with those entities. For that reason, in any case, Applicant believes that there will be little to no likelihood of confusion between the trademark holder and Applicant. As users come to know Applicant’s TLD, they will come to understand that any and all content associated with the TLD is also associated with Applicant and its users, parents, sisters and Affiliates, and no other party.

This means that there will be little pressure on current trademark holders to believe that they have to defensively obtain all of their trademarks within the TLD. One event in which a trademark right may be affected is the unlikely instance in which a commonly known name which is identical or confusingly similar to a trademark is registered. In this event, a trademark holder may submit a request to Applicant to remove the registration or cease use of the subdomain. Applicant is committed to making every attempt to resolve such disputes in a fair and equitable manner and demonstrating the high value Applicant places on intellectual property rights, including rights associated with trademarks. Alternatively, or in addition, the trademark holder is free to file a URS, UDRP or any other dispute resolution action pursuant to the ICANN-approved new gTLD guidelines. Applicant will comply with any and all decisions and orders issued by the adjudicating bodies of these dispute resolution authorities and procedures. In particular, protection for trademark holders will be provided, without limitation, during the implementation phase of the Trademark Clearinghouse in compliance with protection mechanisms related to the requirements of Specification 7 of the Registry Agreement, the Trademark Clearinghouse and any other relevant rights protections mechanisms.

Furthermore, Applicant will provide to ICANN in this application and publish on its website the abuse policy and contact details (as included below and including a valid email and mailing address) to be responsible or addressing matters requiring attention and to handle inquiries related to malicious conduct in the TLD in a timely manner.

Additionally, a reserved list of names will be employed to prevent inappropriate name registrations. This list may be updated periodically based on ICANN directives and guidance. This list will include, among others, ICANN’s list of reserved names in the Registry Agreement, and certain geographic identifiers as enumerated in the response to question #22. The list of names reserved from reservation is enumerated below:

• ICANN and IANA-related names (reserved at second and at all other levels)
o aso 
o gnso 
o icann 
o internic 
o ccnso 
o afrinic 
o apnic 
o arin 
o example 
o gtld-servers 
o iab 
o iana 
o iana-servers 
o iesg 
o ietf 
o irtf 
o istf 
o lacnic 
o latnic 
o rfc-editor 
o ripe 
o root-servers 
• Single-character and two-character labels (reserved at the second level)
• Tagged domains – labels with hyphens in the third and fourth character positions
• Registry operations names – (reserved at the second level) reserved for use in connection with the operation of the registry for the Registry TLD. Registry Operator may use them, but upon conclusion of Registry Operator’s designation as operator of the registry for the Registry TLD they shall be transferred as specified by ICANN:
o NIC
o WHOIS
o WWW
• TLD labels (e.g., aero, arpa, biz, com, etc.) 
• Geographic and Geopolitical Names. All geographic and geopolitical names contained in the ISO 3166-1 list from time to time shall initially be reserved at both the second level and at all other levels within the TLD at which the Registry Operator provides for registrations. All names shall be reserved both in English and in all related official languages as may be directed by ICANN or the GAC.

o In addition, Registry Operator shall reserve names of territories, distinct geographic locations, and other geographic and geopolitical names as ICANN may direct from time to time. Such names may be reserved from registration during any sunrise period, and may be registered in ICANNʹs name prior to start-up and open registration in the TLD. Registry Operator may post and maintain an updated listing of all such names on its website, which list may be subject to change at ICANNʹs direction. Upon determination by ICANN of appropriate standards and qualifications for registration following input from interested parties in the Internet community, such names may be approved for registration to the appropriate authoritative body.

The Applicant’s TLD will comply with all applicable trademark and anti-cybersquatting legislation. In the event of an inconsistency between such legislation and the procedures of Applicant’s TLD, Applicant will revise its procedures to be in compliance therewith. 

Should Applicant function as a Specification 9 exempt Registry Operator, Applicant will restrict the transfer of registrations of domain names within its TLD to third parties.

1.1 Abuse Prevention and Mitigation Implementation Plan 
In addition to developing ICANN policies and the Applicant policies as articulated above, below and pursuant to the attached Abuse Prevention and Mitigation Implementation Plan, the registration process will limit abusive registration practices commonly associated with TLDs in which abusive registrants use false contact information to evade identification or legal process. Applicant’s TLD intends to function, per the ICANN-Registry Operator Registry Agreement, as a Specification 9 exempt TLD whereby all domain name registrations in the TLD shall be registered to and maintained by Applicant and Applicant will not sell, distribute or transfer control of domain name registrations to any party that is not an Affiliate of Applicant as defined in the ICANN-Registry Operator Registry Agreement. All domain name registrations intended to be used within Applicant’s registry will be registered to and controlled and maintained by Applicant and its verified and authenticated Affiliates and for the benefit of Applicant and its users, parents, sisters and Affiliates. All registrations must be requested through one of Applicant’s internal channels and must be verified and approved before registration. The verification process will be in operation on an ongoing basis. The verification process is designed to establish that a prospective registrant meets the registration criteria.
a. A variety of automated and manual procedures will be utilized for verification, including a cross-check of registration against information held by Applicant.
b. Eligibility of prospective registrants will be verified prior to the addition of a name to the Applicant’s TLD zone file, including but not limited to, review of the request for registration by Applicant’s compliance staff who will attempt to manually verify the affiliation of the prospective registrant with the Applicant.
c. Applicant will verify contact⁄WHOIS data for prospective registrants prior to the addition of a name to the Applicant’s TLD zone file.
d. Applicant will maintain verified contact data for the actual registrant as well as for any proxy services utilized by registrant. Proxy services eligible for use are limited to services that have demonstrated responsible and responsive business services.
e. Prospective registrants must represent and warrant that neither the registration of the desired string, nor the manner in which the registration will be used, infringes the legal rights of third parties.
f. Prospective registrants will disclose their intended use for the domain. Registration will be refused to those who do not indicate at least one acceptable use of the domain. Acceptable uses of the TLD include, but are not limited to the bona fide use or bona fide intent to use the domain name or any content, software, materials, graphics or other information thereon to permit Internet users to access one or more host computers through the DNS:
• to exchange goods, services or property of any kind;
• in the ordinary course of trade or business; or
• to facilitate the exchange of goods, services, information, or property of any kind, or the ordinary course of trade or business.
Additionally, Applicant will implement a number of mechanisms pursuant to all ICANN guidelines and the Registry Agreement for those who are not affiliated with the Applicant to protect their intellectual property.
a. Pre-Reservation Service: Applicant may enable existing holders of a trademark to block Applicant’s TLD registrations that correspond to their existing registrations in other ICANN recognized TLDs. 
b. Trademark Clearinghouse: Trademark owners will have an extended period in which they can register their trademarks with the Trademark Clearinghouse. Once registration begins, if a registrant attempts to register a name that has been registered with the Trademark Clearinghouse, the prospective registrant will be notified of the existence of the registration with the Trademark Clearinghouse.
Dispute Resolution Procedures: Registered domains will be subject to challenge under ordinary domain dispute procedures set forth by ICANN, including but not limited to, Uniform Domain-Name Dispute-Resolution Policy (UDRP), Uniform Rapid Suspension system (URS), Trademark Post-Delegation Dispute Procedure (PDDRP), and Registration Restriction Dispute Resolution Procedure (RRDRP). Applicant agrees to implement and adhere to any remedies imposed by decision makers under such procedures.
1.2 Policies for Handling Complaints Regarding Abuse
Applicant 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 Applicant, 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 Applicant or its registrar in connection with a domain name registration.
During review of any complaint, Applicant will consider the standards set forth in the ICANN UDRP, in addition to the following modifications:
a. Evidence that a domain name is identical or confusingly similar to a trademark or service mark in which the complainant has rights can include evidence that the domain name is “...confusingly similar to a trademark, service mark or trade name in which the complainant has rights or the name under which the complainant does business....” This will grant standing to an entity based upon the entity’s trade name or name under which it does business.
b. Evidence that a domain has been registered and is being used in bad faith will require a showing that the domain has been registered and⁄or is being used in bad faith. This will allow a claim based upon bad faith on the part of the registrant during either registration or use.
c. Additional indicia of bad faith use will be considered. These indicia will include (1) use of the domain name inconsistent with the Code, and (2) use of the domain name in connection with a list of prohibited uses, which will include pornography, hacks⁄cracks content, etc. The list of prohibited uses may be compiled by Applicant and outside advisors.
d. Enumerated circumstances for proving a right and legitimate interest will include trade names and names under which business is done where trademarks and service marks currently are noted. A showing of bad faith registration or use, however, will be considered as prima facie evidence of no legitimate interest.
Applicant also reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a dispute.
All reports of abuse should be sent to an email address that will be publicly identified by Applicant for receiving reports of abuse.
1.3 Proposed Measures for Removal of Orphan Glue Records
Although orphan glue records often support correct and ordinary operation of the Domain Name System (DNS), registry operators will be required to remove orphan glue records (as defined at http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf) when provided with evidence in written form that such records are present in connection with malicious conduct. Applicant’s selected backend registry services provider’s (Verisign’s) registration system is specifically designed to not allow orphan glue records. Registrars are required to delete⁄move all dependent DNS records before they are allowed to delete the parent domain.
To prevent orphan glue records, Verisign performs the following checks before removing a domain or name server: 

Checks during domain delete: 
• Parent domain delete is not allowed if any other domain in the zone refers to the child name server. 
• If the parent domain is the only domain using the child name server, then both the domain and the glue record are removed from the zone.

Check during explicit name server delete: 
• Verisign confirms that the current name server is not referenced by any domain name (in-zone) before deleting the name server. 

Zone-file impact:
• If the parent domain references the child name server AND if other domains in the zone also reference it AND if the parent domain name is assigned a serverHold status, then the parent domain goes out of the zone but the name server glue record does not. 
• If no domains reference a name server, then the zone file removes the glue record.

1.4 Resourcing Plans
Details related to resourcing plans for the initial implementation and ongoing maintenance of the Applicant’s abuse plan are provided in Section 2 of this response. 
1.5 Measures to Promote WHOIS Accuracy
Applicant will maintain a shared registration system for Applicant’s selected registrar. WHOIS access will be facilitated in compliance with ICANN policies, including without limitation the Registry Agreement. It is anticipated that information will be provided which is consistent with the WHOIS information currently provided in other TLDs, including identification of the registrant and contact information therefore, administrative, technical and billing contacts, creation and expiration date and DNS settings. One way that Applicant may ensure compliance with all applicable policies is to mandate that all requests for domains will be required to come from a verified internal corporate channel to ensure that the requestor is affiliated with Applicant. Such requests will be subject to an internal review and approval process that may be amended from time to time. In addition, Applicant may provide for additional measures, such as to conduct audits (e.g., compliance with requirements to make WHOIS available, and with the annual WHOIS Data Reminder Policy (WDRP)); investigate complaints of non-compliance (e.g., responses to WHOIS Data Problem Service (WDPRS) notifications); develop documented internal processes and training for personnel assigned by Applicant to complete WHOIS data to ensure that data is provided completely and accurately.

At this point, Applicant anticipates that registrant information will be protected or made available as required by ICANN, applicable law or other regulatory bodies. For technical details regarding how a complete, up-to-date, reliable and conveniently accessible WHOIS database will be provided, see response to question #26.

Applicant ensures that the WHOIS database and access thereto will comply with emerging ICANN privacy policies, if and when they become approved.
1.5.1 Authentication of Registrant Information 
Applicant intends to function, per the ICANN-Registry Operator Registry Agreement, as a Specification 9 exempt TLD whereby all domain name registrations in the TLD shall be registered to and maintained by Applicant and Applicant will not sell, distribute or transfer control of domain name registrations to any party that is not an Affiliate of Applicant as defined in the ICANN-Registry Operator Registry Agreement. All domain name registrations intended to be used within Applicant’s registry will be registered to and controlled and maintained by Applicant and for the benefit of Applicant and its users, parents, sisters and Affiliates. See also section 1.1 above.
1.5.2 Regular Monitoring of Registration Data for Accuracy and Completeness
Applicant intends to function, per the ICANN-Registry Operator Registry Agreement, as a Specification 9 exempt TLD whereby all domain name registrations in the TLD shall be registered to and maintained by Applicant and Applicant will not sell, distribute or transfer control of domain name registrations to any party that is not an Affiliate of Applicant as defined in the ICANN-Registry Operator Registry Agreement. All domain name registrations intended to be used within Applicant’s registry will be registered to and controlled and maintained by Applicant and for the benefit of Applicant and its users, parents, sisters and Affiliates. As the only registrations permitted will be from the Applicant entity, the monitoring of the accuracy of registration data will be reasonable and Applicant will periodically (on at least an annual basis) monitor the accuracy and completeness of such information. Verisign, Applicant’s selected backend registry services provider, has established policies and procedures to encourage registrar compliance with ICANN’s WHOIS accuracy requirements. Verisign provides the following services to Applicant for incorporation into its full-service registry operations.
Verisign, the Applicant’s selected backend registry services provider, has established policies and procedures to encourage registrar compliance with ICANN’s WHOIS accuracy requirements. Verisign provides the following services to the Applicant for incorporation into its full-service registry operations.
Registrar self-certification. Applicant intends to function, per the ICANN-Registry Operator Registry Agreement, as a Specification 9 exempt TLD whereby all domain name registrations in the TLD shall be registered to and maintained by Applicant and Applicant will not sell, distribute or transfer control of domain name registrations to any party that is not an Affiliate of Applicant as defined in the ICANN-Registry Operator Registry Agreement. All domain name registrations intended to be used within Applicant’s registry will be registered to and controlled and maintained by Applicant and for the benefit of Applicant and its users, parents, sisters and Affiliates.

WHOIS data reminder process. Verisign regularly reminds registrars of their obligation to comply with ICANN’s WHOIS Data Reminder Policy, which was adopted by ICANN as a consensus policy on 27 March 2003 (http:⁄⁄www.icann.org⁄en⁄registrars⁄wdrp.htm). Verisign sends a notice to all registrars once a year reminding them of their obligation to be diligent in validating the WHOIS information provided during the registration process, to investigate claims of fraudulent WHOIS information, and to cancel domain name registrations for which WHOIS information is determined to be invalid. Notwithstanding the above, Applicant intends to function, per the ICANN-Registry Operator Registry Agreement, as a Specification 9 exempt TLD whereby all domain name registrations in the TLD shall be registered to and maintained by Applicant and Applicant will not sell, distribute or transfer control of domain name registrations to any party that is not an Affiliate of Applicant as defined in the ICANN-Registry Operator Registry Agreement. All domain name registrations intended to be used within Applicant’s registry will be registered to and controlled and maintained by Applicant and for the benefit of Applicant and its users, parents, sisters and Affiliates.
1.5.3 Use of Registrars
Applicant intends to function, per the ICANN-Registry Operator Registry Agreement, as a Specification 9 exempt TLD whereby all domain name registrations in the TLD shall be registered to and maintained by Applicant and Applicant will not sell, distribute or transfer control of domain name registrations to any party that is not an Affiliate of Applicant as defined in the ICANN-Registry Operator Registry Agreement. All domain name registrations intended to be used within Applicant’s registry will be registered to and controlled and maintained by Applicant and for the benefit of Applicant and its users, parents, sisters and Affiliates. 

At the appropriate time, between post-submission of this application and prior to the Applicant’s TLD launch, Applicant will identify, determine and engage the proper service provider (e.g. Applicant-approved registrar and⁄or selected backend registry services provider, Verisign) to support its provision of registration and abuse policies. Any engagement for the implementation and provision of such services shall be in compliance with all ICANN-mandated regulations, agreements, guidance and policies, as it is of paramount importance of the Applicant to protect the rights of all rightsholders.
1.6 Malicious or Abusive Behavior Definitions, Metrics, and Service Level Requirements for Resolution
Pursuant to the attached Abuse Prevention and Mitigation Implementation Plan, Applicant shall implement the following anti-abuse policy as a guideline:

The following definitions and policy (“Applicant Domain Anti-Abuse Policy”) shall be in effect between Applicant and its registrar:

Abusive use(s) of domain names in this TLD should not be tolerated. The nature of such abuses creates security and stability issues for the registry, registrars and registrants, as well as for users of the Internet in general. Applicant defines abusive use as the wrong or excessive use of power, position or ability, and includes, without limitation, the following:

• Illegal or fraudulent actions;
• Spam: The use of electronic messaging systems to send unsolicited bulk messages. The term applies to email spam and similar abuses such as instant messaging spam, mobile messaging spam, and the spamming of websites and Internet forums. An example, for purposes of illustration, would be the use of email in denial-of-service attacks;
• Phishing: The use of counterfeit web pages that are designed to trick recipients into divulging sensitive data such as usernames, passwords, or financial data;
• Pharming: The redirecting of unknowing users to fraudulent sites or services, typically through DNS hijacking or poisoning;
• Willful distribution of malware: The dissemination of software designed to infiltrate or damage a computer system without the ownerʹs informed consent. Examples include, without limitation, computer viruses, worms, keyloggers, and trojan horses;
• Fast-flux hosting: Use of fast-flux techniques to disguise the location of websites or other Internet services, or to avoid detection and mitigation efforts, or to host illegal activities. Fast-flux techniques use DNS to frequently change the location on the Internet to which the domain name of an Internet host or name server resolves. Fast-flux hosting may be used only with prior permission of LDH;
• Botnet command and control: Services run on a domain name that are used to control a collection of compromised computers or ʺzombies,ʺ or to direct denial-of-service attacks (DDoS attacks);
• Distribution of child pornography; and
• Illegal Access to Other Computers or Networks: Illegally accessing computers, accounts, or networks belonging to another party, or attempting to penetrate security measures of another individualʹs system (often known as ʺhackingʺ). Also, any activity that might be used as a precursor to an attempted system penetration (e.g., port scan, stealth scan, or other information gathering activity).

Applicant 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 Applicant, 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 Applicant or its registrar in connection with a domain name registration.

Applicant also reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a dispute.

Abusive uses, as defined above, undertaken with respect to domain names in this TLD shall give rise to the right of Applicant to take such actions as per its RRA in its sole discretion.

All reports of abuse should be sent to an email address that will be publicly identified by Applicant for receiving reports of abuse.
1.7 Controls to Ensure Proper Access to Domain Functions
Applicant intends to function, per the ICANN-Registry Operator Registry Agreement, as a Specification 9 exempt TLD whereby all domain name registrations in the TLD shall be registered to and maintained by Applicant and Applicant will not sell, distribute or transfer control of domain name registrations to any party that is not an Affiliate of Applicant as defined in the ICANN-Registry Operator Registry Agreement. All domain name registrations intended to be used within Applicant’s registry will be registered to and controlled and maintained by Applicant and for the benefit of Applicant and its users, parents, sisters and Affiliates. Access to domain functions will be limited to Applicant and its engaged service provider partners by implementing and complying with their established safeguards and access features as articulated below.
1.7.1 Multi-Factor Authentication
To ensure proper access to domain functions, the Applicant incorporates Verisign’s Registry-Registrar Two-Factor Authentication Service into its full-service registry operations. The service is designed to improve domain name security and assist registrars in protecting the accounts they manage by providing another level of assurance that only authorized personnel can communicate with the registry. As part of the service, dynamic one-time passwords (OTPs) augment the user names and passwords currently used to process update, transfer, and⁄or deletion requests. These one-time passwords enable transaction processing to be based on requests that are validated both by “what users know” (i.e., their user name and password) and “what users have” (i.e., a two-factor authentication credential with a one-time-password).
Registrars can use the one-time-password when communicating directly with Verisign’s Customer Service department as well as when using the registrar portal to make manual updates, transfers, and⁄or deletion transactions. The Two-Factor Authentication Service is an optional service offered to registrars that execute the Registry-Registrar Two-Factor Authentication Service Agreement. As shown in Figure 28-1, the registrars’ authorized contacts use the OTP to enable strong authentication when they contact the registry. There is no charge for the Registry-Registrar Two-Factor Authentication Service. It is enabled only for registrars that wish to take advantage of the added security provided by the service. 
1.7.2 Requiring Multiple, Unique Points of Contact
Unique points of contact (POC) and their respective actions will be determined by Applicant at the appropriate time prior to the implementation of the gTLD.
1.7.3 Requiring the Notification of Multiple, Unique Points of Contact
Unique points of contact (POC) and their respective actions will be determined by Applicant at the appropriate time prior to the implementation of the gTLD.
2. TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION
Resource Planning
Applicant projects it will use the following personnel roles to support the implementation of the policies articulated in this section:
o 1 senior level executive
o 1 marketing⁄business manager
o 1 technical manager
o 1 administrative professional

To implement and manage Applicant’s gTLD as described in this application, Applicant can scale as needed, and utilize resources provided by our parent company, as defined above. In particular, personnel currently involved in the operation of parent entity’s existing .com business can assist with the needs of this new gTLD and may be transitioned over to supporting the gTLD as the .com businesses wind down in favor of the new gTLD. In addition to these individuals, Applicant parent entity will support implementation of these policies through the provision of their resources as well as additional outside resources on an as-needed basis. Support from our parent company will include access to a law department, finance department, information systems, technical support, human resources and such other administrative support that may be required. In particular, we anticipate using outside advisors and lawyers to assist in managing any disputes which must be resolved. Once the top level domain has been awarded, we do not anticipate disputes beyond what is frequently encountered in operating the .com. However, given the expanded opportunities associated with operating the top level domain, we have increased the likelihood of disputes, take down notices or such other matters and increased the .com dispute resolution budget. We will utilize outside advisors to provide the additional talent and resources and specialized knowledge that we cannot cost effectively maintain internally. Projected costs associated with these resources are further discussed in the response to Question 47 below. 
Resource Planning Specific to Backend Registry Activities
Verisign, the Applicant’s selected backend registry services provider, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to the Applicant fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response. 
Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force. (Current statistics are publicly available in Verisign’s quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100 percent of the time for more than 13 years for .com, proving Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s TLD service offerings.
Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support abuse prevention and mitigation:
• Application Engineers: 19
• Business Continuity Personnel: 3
• Customer Affairs Organization: 9
• Customer Support Personnel: 36
• Information Security Engineers: 11
• Network Administrators: 11
• Network Architects: 4
• Network Operations Center (NOC) Engineers: 33
• Project Managers: 25
• Quality Assurance Engineers: 11
• Systems Architects: 9

To implement and manage the TLD as described in this application, Verisign, the Applicant’s selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area. 
When usage projections indicate a need for additional staff, Verisign’s internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed gTLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internet’s largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.
3. POLICIES AND PROCEDURES IDENTIFY AND ADDRESS THE ABUSIVE USE OF REGISTERED NAMES AT START-UP AND ON AN ONGOING BASIS
3.1 Start-Up Anti-Abuse Policies and Procedures
a. Pre-Reservation Service: Applicant may enable existing holders of a trademark to block Applicant registrations that correspond to their existing registrations in other ICANN recognized TLDs. 
b. Trademark Clearinghouse: Trademark owners will have an extended period in which they can register their trademarks with the Trademark Clearinghouse. Once registration begins, if a registrant attempts to register a name that has been registered with the Trademark Clearinghouse, the prospective registrant will be notified of the existence of the registration with the Trademark Clearinghouse.
3.2 Ongoing Anti-Abuse Policies and Procedures
3.2.1 Policies and Procedures That Identify Malicious or Abusive Behavior
Verisign, the Applicant’s selected backend registry services provider, provides the following service to the Applicant for incorporation into its full-service registry operations.
Malware scanning service. Registrants are often unknowing victims of malware exploits. Verisign has developed proprietary code to help identify malware in the zones it manages, which in turn helps registrars by identifying malicious code hidden in their domain names. 
Verisign’s malware scanning service helps prevent websites from infecting other websites by scanning web pages for embedded malicious content that will infect visitors’ websites. Verisign’s malware scanning technology uses a combination of in-depth malware behavioral analysis, anti-virus results, detailed malware patterns, and network analysis to discover known exploits for the particular scanned zone. If malware is detected, the service sends the registrar a report that contains the number of malicious domains found and details about malicious content within its TLD zones. Reports with remediation instructions are provided to help registrars and registrants eliminate the identified malware from the registrant’s website. 
3.2.2 Policies and Procedures That Address the Abusive Use of Registered Names
Suspension processes. In addition to the safeguards and mechanisms additionally provided for above and below and those required by ICANN and applicable law, rightsholders will have the opportunity to provide written notification of claimed abuse and Applicant will investigate notices of abuse and take appropriate actions pursuant to the policies articulated herein and those required by ICANN and applicable law.
Dispute Resolution Procedures: Registered domains will be subject to challenge under ordinary domain dispute procedures set forth by ICANN, including but not limited to, Uniform Domain-Name Dispute-Resolution Policy (UDRP), Uniform Rapid Suspension system (URS), Trademark Post-Delegation Dispute Procedure (PDDRP), and Registration Restriction Dispute Resolution Procedure (RRDRP). Applicant agrees to implement and adhere to any remedies imposed by decision makers under such procedures. 
Compliance with Court Orders and Law Enforcement Requests: Applicant reserves the right, but disclaims any obligation or responsibility, to (a) refuse to post or communicate or remove any submission from any Applicant site that is deemed to be abusive and (b) identify any user to third parties, and⁄or disclose to third parties any submission or personally identifiable information, when we believe in good faith that such identification or disclosure will either (i) facilitate compliance with laws, including, for example, compliance with a court order or subpoena, or (ii) help to enforce these policies and⁄or other Applicant rules or regulations, and⁄or protect the safety or security of any person or property, including any Applicant site. Moreover, we retain all rights to remove Submissions at any time for any reason or no reason whatsoever. Applicant reserves the right to provide information to third parties pursuant to a contractual or legal obligation.
Takedown Procedures: Applicant will comply with the terms set forth in the Uniform Rapid Suspension (URS) procedure, Trademark Post-Delegation Dispute Procedure (PDDRP), and Registration Restriction Dispute Resolution Procedure (RRDRP). Applicant agrees to implement and adhere to any remedies imposed by decision makers under such procedures. Takedown or Suspension requests provided directly to Applicant must demonstrate the following:
• The complaint must include complainant’s name, address, and email or telephone number (preferably both), and any legal counsel actively representing you in the matter, including their contact information.
• The complaint must include specific details concerning the alleged Terms violation, including but not limited to: (i) exact URL(s) where we can see the violation, (ii) for matters where URLs cannot be used (i.e., spam and⁄or phishing allegations), copies of files used as part of the violation and evidence as to their origins (i.e., emails including full headers), and (iii) any other supporting evidence such as screen shots and⁄or server log files.
• The terms violation must currently be in active and verifiable use at the time we investigate the matter. 
• Applicant will suspend a registered domain on orders from a court or authority in an ICANN-approved dispute resolution procedure. The domain name will be unsuspended in view of an executive proceeding on the matter rejecting the request for suspension or upon a showing that the matter has been resolved in favor of the registrant. Appeals will be handled through the authority issuing the suspension request.

Suspension processes conducted by backend registry services provider. In the case of domain name abuse, the Applicant will determine whether to take down the subject domain name. Verisign, the Applicant’s selected backend registry services provider, will follow the following auditable processes (shown in Figure 28-2) to comply with the suspension request.
Verisign Suspension Notification. The Applicant submits the suspension request to Verisign for processing, documented by:
• Threat domain name
• Registry incident number 
• Incident narrative, threat analytics, screen shots to depict abuse, and⁄or other evidence
• Threat classification 
• Threat urgency description
• Recommended timeframe for suspension⁄takedown 
• Technical details (e.g., WHOIS records, IP addresses, hash values, anti-virus detection results⁄nomenclature, name servers, domain name statuses that are relevant to the suspension) 
• Incident response, including surge capacity 

Verisign Notification Verification. When Verisign receives a suspension request from the Applicant, it performs the following verification procedures:
• Validate that all the required data appears in the notification.
• Validate that the request for suspension is for a registered domain name.
• Return a case number for tracking purposes.
Suspension Rejection. If required data is missing from the suspension request, or the domain name is not registered, the request will be rejected and returned to the Applicant with the following information:
• Threat domain name
• Registry incident number 
• Verisign case number
• Error reason

4. WHEN EXECUTED IN ACCORDANCE WITH THE REGISTRY AGREEMENT, PLANS WILL RESULT IN COMPLIANCE WITH CONTRACTUAL REQUIREMENTS
The Applicant’s proposed Abuse Prevention and Mitigation Implementation Plan is and shall be consistent with the draft Registry Agreement provided by ICANN, including all Specifications, and when executed, Applicant will be compliant with the contractual requirements of the Registry Agreement, including relevant specifications, as well as any and all emerging ICANN policies, if and when they become approved. In the event that Applicant’s proposed Abuse Prevention and Mitigation Implementation Plan is not consistent with the Registry Agreement, Applicant will amend the Abuse Prevention and Mitigation Implementation Plan to result in compliance.
5. TECHNICAL PLAN SCOPE⁄SCALE THAT IS CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY
Scope⁄Scale Consistency
Applicant intends to function, per the ICANN-Registry Operator Registry Agreement, as a Specification 9 exempt TLD whereby all domain name registrations in the TLD shall be registered to and maintained by Applicant and Applicant will not sell, distribute or transfer control of domain name registrations to any party that is not an Affiliate of Applicant as defined in the ICANN-Registry Operator Registry Agreement. All domain name registrations intended to be used within Applicant’s registry will be registered to and controlled and maintained by Applicant and for the benefit of Applicant and its users, parents, sisters and Affiliates. Applicant does not intend to register in excess of around one thousand registrations at most. Within that context, Applicant will continue to ensure that the execution and implementation of these policies are consistent with the plan, objective and size of the registry. 
Scope⁄Scale Consistency Specific to Backend Registry Activities
Verisign, the Applicant’s selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies. 
Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the TLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to the Applicant fully accounts for cost related to this infrastructure, which is provided as “Other Operating Cost” (Template 1, Line I.L) within the Question 46 financial projections response.

1. Mechanisms Designed to Prevent Abusive Registrations
Rights protection is a core objective of Applicant. Applicant will implement and adhere to any rights protection mechanisms (RPMs) that may be mandated from time to time by ICANN, including each mandatory RPM set forth in the Trademark Clearinghouse model contained in the Registry Agreement, specifically Specification 7. Applicant acknowledges that, at a minimum, ICANN requires a Sunrise period, a Trademark Claims service, and interaction with the Trademark Clearinghouse with respect to the registration of domain names for the Applicant’s TLD. It should be noted that because ICANN, as of the time of this application submission, has not issued final guidance with respect to the Trademark Clearinghouse, Applicant cannot fully detail the specific implementation of the Trademark Clearinghouse within this application. Applicant will adhere to all processes and procedures to comply with ICANN guidance once this guidance is finalized. 

As described in this response, Applicant will implement a Sunrise period and Trademark Claims service with respect to the registration of domain names within the Applicant’s TLD. Certain aspects of the Sunrise period and⁄or Trademark Claims service may be administered on behalf of Applicant by Applicant-approved registrars or by subcontractors of Applicant, such as its selected backend registry services provider, Verisign.

Applicant is committed to implementing all the rights protection mechanisms developed and approved by ICANN in addition to any other mechanisms or protections that may be necessary to effectively protect trademark holders’ (and other rightsholders’) rights. Indeed, one of Applicant’s core objectives is the protection of the rights of both the Applicant and of third parties. To that effect, the Applicant’s TLD has policies and practices which minimize abusive registration activities and other activities that affect the legal rights of others, and which further provide safeguards against unauthorized, unqualified and inappropriate registrations and ensure compliance with ICANN policies.

Applicant intends to request from ICANN an exemption from Specification 9 of the Registry Operatory Registry Agreement. As such, Applicant intents to function in such a way that all domain name registrations in the TLD shall be registered to and maintained by Applicant and Applicant will not sell, distribute or transfer control of domain name registrations to any party that is not an Affiliate of Applicant as defined in the ICANN-Registry Operator Registry Agreement. All domain name registrations intended to be used within Applicant’s registry will be registered to and controlled and maintained by Applicant and for the benefit of Applicant and its users, parents, sisters and Affiliates. This will prevent fraudulent entities from obtaining a registration. As the Applicant will be the only registrant approved, there will be no risk of registration of a name by an entity which does not have such a legal name or is not commonly known by such a name. This will minimize cybersquatters and⁄or domain prospectors and will eliminate the possibility of abusive overreaching applications (i.e., requesting domains which do not reflect the name of the entity (legal or commonly known)).

In the event that Applicant is not granted an exemption from Specification 9, Applicant will partner with a corporate registrar with expertise in running a registry to support such efforts. Applicant intends to partner with its current corporate registrar or one of similar technical capability and expertise and allocate the appropriate funds and human resources to ensure that both itself, as the registry operator, and its selected registrar are at all times in compliance with ICANN guidelines.

At the appropriate time, between post-submission of this application and prior to the Applicant’s TLD launch, Applicant will identify, determine and engage the proper service provider (e.g., Applicant-approved registrar and⁄or selected backend registry services provider, Verisign) to support its provision of the Sunrise period and Trademark Claims service. Any engagement for the implementation and provision of such services shall be in compliance with all ICANN-mandated regulations, agreements, guidance and policies, as it is of paramount importance of the Applicant to protect the rights of all rightsholders.

Sunrise Period. As provided by the Trademark Clearinghouse model set forth in the ICANN Applicant Guidebook, the Sunrise service pre-registration procedure for domain names continues for at least 30 days prior to the launch of the general registration of domain names in the gTLD (unless Applicant decides to offer a longer Sunrise period). 

During the Sunrise period, holders of marks that have been previously validated by the Trademark Clearinghouse receive notice of domain names that are an identical match (as defined in the ICANN Applicant Guidebook) to their mark(s). Such notice is in accordance with ICANN’s requirements and is provided by Applicant either directly or through Applicant-approved registrars. 

Applicant requires all registrants, either directly or through Applicant-approved registrars, to i) affirm that said registrants meet the Sunrise Eligibility Requirements (SER), and ii) submit to the Sunrise Dispute Resolution Policy (SDRP) consistent with Section 6 of the Trademark Clearinghouse model. At a minimum, Applicant recognizes and honors all word marks for which a proof of use was submitted and validated by the Trademark Clearinghouse as well as any additional eligibility requirements as specified in Question 18.

During the Sunrise period, Applicant and⁄or Applicant-approved registrars, as applicable, are responsible for determining whether each domain name is eligible to be registered (including in accordance with the SERs). As the Applicant will be the only registrant under Applicant’s TLD, and the Applicant will comply with all policies and directives of the Trademark Clearinghouse and all other relevant rights protections mechanisms related to accepted and acknowledged rightsholders, there will be no risk of threats to the rights of third parties as third party registrations will not be permitted.

Trademark Claims Service. As provided by the Trademark Clearinghouse model set forth in the ICANN Applicant Guidebook, all new gTLDs will have to provide a Trademark Claims service for a minimum of 60 days after the launch of the general registration of domain names in the gTLD (Trademark Claims period).

During the Trademark Claims period, in accordance with ICANN’s requirements, Applicant or the Applicant-approved registrar will send a Trademark Claims Notice to any prospective registrant of a domain name that is an identical match (as defined in the ICANN Applicant Guidebook) to any mark that is validated in the Trademark Clearinghouse. The Trademark Claims Notice will include links to the Trademark Claims as listed in the Trademark Clearinghouse and will be provided at no cost.

Prior to registration of said domain name, Applicant or the Applicant-approved registrar will require each prospective registrant to provide the warranties dictated in the Trademark Clearinghouse model set forth in the ICANN Applicant Guidebook. Those warranties will include receipt and understanding of the Trademark Claims Notice and confirmation that registration and use of said domain name will not infringe on the trademark rights of the mark holders listed. Without receipt of said warranties, the Applicant or the Applicant-approved registrar will not process the domain name registration.

Following the registration of a domain name, the Applicant-approved registrar will provide a notice of domain name registration to the holders of marks that have been previously validated by the Trademark Clearinghouse and are an identical match. This notice will be as dictated by ICANN. At a minimum Applicant will recognize and honor all word marks validated by the Trademark Clearinghouse.

As Applicant will be the single and only registrant under Applicant’s TLD, Applicant will be the only party to whom compliance with the Trademark Clearinghouse will apply. Applicant will at all times use the Trademark Clearinghouse as a resource to determine whether its registrations are in conflict with the existing rights of third parties and, in the event of any conflict, will act in accordance with all relevant rights protection mechanisms, including, without limitation those described in Specification 7 of the ICANN-Registry Operator Registry Agreement.

2. Mechanisms Designed to Identify and address the abusive use of registered names on an ongoing basis
In addition to the Sunrise period and Trademark Claims services described in Section 1 of this response, Applicant implements and adheres to RPMs post-launch as mandated by ICANN, and confirms that registrars accredited for the Applicant’s TLD are in compliance with these mechanisms. Certain aspects of these post-launch RPMs may be administered on behalf of Applicant by Applicant-approved registrars or by subcontractors of Applicant, such as its selected backend registry services provider, Verisign. 

Applicant will implement and execute all post-launch services listed in this section, all of which shall be administered on behalf of Applicant by Applicant-approved registrars or by subcontractors of Applicant, such as its selected backend registry services provider, Verisign. At the appropriate time, between post-submission of this application and prior to the Applicant’s TLD launch, Applicant will identify, determine and engage the proper service provider (e.g., Applicant-approved registrar and⁄or selected backend registry services provider, Verisign) to support its provision of the Sunrise period and Trademark Claims service. Any engagement for the implementation and provision of such services shall be in compliance with all ICANN-mandated regulations, agreements, guidance and policies, as it is of paramount importance of the Applicant to protect the rights of all rightsholders.

These post-launch RPMs include the established Uniform Domain-Name Dispute-Resolution Policy (UDRP), as well as the newer Uniform Rapid Suspension System (URS) and Trademark Post-Delegation Dispute Resolution Procedure (PDDRP). Where applicable, Applicant will implement all determinations and decisions issued under the corresponding RPM.

After a domain name is registered, trademark holders can object to the registration through the UDRP or URS. Objections to the operation of the gTLD can be made through the PDDRP.

The following descriptions provide implementation details of each post-launch RPM for the Applicant’s TLD: 

• UDRP: The UDRP provides a mechanism for complainants to object to domain name registrations. The complainant files its objection with a UDRP provider and the domain name registrant has an opportunity to respond. The UDRP provider makes a decision based on the papers filed. If the complainant is successful, ownership of the domain name registration is transferred to the complainant. If the complainant is not successful, ownership of the domain name remains with the domain name registrant. Applicant and entities operating on its behalf adhere to all decisions rendered by UDRP providers.
• URS: As provided in the Applicant Guidebook, all registries are required to implement the URS. Similar to the UDRP, a complainant files its objection with a URS provider. The URS provider conducts an administrative review for compliance with filing requirements. If the complaint passes review, the URS provider notifies the registry operator and locks the domain. A lock means that the registry restricts all changes to the registration data, but the name will continue to resolve. After the domain is locked, the complaint is served to the domain name registrant, who has an opportunity to respond. If the complainant is successful, the registry operator is informed and the domain name is suspended for the balance of the registration period; the domain name will not resolve to the original website, but to an informational web page provided by the URS provider. If the complainant is not successful, the URS is terminated and full control of the domain name registration is returned to the domain name registrant. Similar to the existing UDRP, Applicant and entities operating on its behalf adhere to decisions rendered by the URS providers.
• PDDRP: As provided in the Applicant Guidebook, all registries are required to implement the PDDRP. The PDDRP provides a mechanism for a complainant to object to the registry operator’s manner of operation or use of the gTLD. The complainant files its objection with a PDDRP provider, who performs a threshold review. The registry operator has the opportunity to respond and the provider issues its determination based on the papers filed, although there may be opportunity for further discovery and a hearing. Applicant participates in the PDDRP process as specified in the Applicant Guidebook.

Additional Measures Specific to Rights Protection. Applicant provides additional measures against potentially abusive registrations, including those articulated in Applicant response to question #28 and included in its attached Abuse Prevention and Mitigation Implementation Plan. These measures help mitigate phishing, pharming, and other Internet security threats. The measures exceed the minimum requirements for RPMs defined by Specification 7 of the Registry Agreement and are available at the time of registration. All measures articulated below will be implemented to the extent and consistent with Applicant response to question #28 and included in its attached Abuse Prevention and Mitigation Implementation Plan, and include:

• Rapid Takedown or Suspension Based on Court Orders: Applicant complies promptly with any order from a court of competent jurisdiction that directs it to take any action on a domain name that is within its technical capabilities as a TLD registry. These orders may be issued when abusive content, such as child pornography, counterfeit goods, or illegal pharmaceuticals, is associated with the domain name.
• Anti-Abuse Process: Applicant implements an anti-abuse process that is executed based on the type of domain name takedown requested. The anti-abuse process is for malicious exploitation of the DNS infrastructure, such as spam, phishing, pharming, fast flux hosting, botnets, and malware. 
• Authentication Procedures: Verisign, Applicant’s selected backend registry services provider, uses two-factor authentication to augment security protocols for telephone, email, and chat communications.
• Malware Code Identification: This safeguard reduces opportunities for abusive behaviors that use registered domain names in the gTLD. Registrants are often unknowing victims of malware exploits. As Applicant’s backend registry services provider, Verisign has developed proprietary code to help identify malware in the zones it manages, which in turn helps registrars by identifying malicious code hidden in their domain names.
• DNSSEC Signing Service: Domain Name System Security Extensions (DNSSEC) helps mitigate pharming attacks that use cache poisoning to redirect unsuspecting users to fraudulent websites or addresses. It uses public key cryptography to digitally sign DNS data when it comes into the system and then validate it at its destination. The Applicant’s TLD is DNSSEC-enabled as part of Verisign’s core backend registry services. 

3. RESOURCING PLANS
Applicant projects it will use the following personnel roles to support the implementation of RPMs:
o 1 senior level marketing⁄business executive
o 1 technical manager
o 1 administrative professional

To implement and manage the Applicant’s TLD as described in this application, Applicant can scale as needed, and utilize resources provided by our parent company, as defined above. In particular, personnel currently involved in the operation of Applicant’s existing .com business can assist with the needs of this new TLD and may be transitioned over to supporting the TLD as the .com businesses wind down in favor of the new TLD. In addition to these individuals, our parent company will support our implementation of RPMs through the provision of their resources as well as additional outside resources on an as-needed basis. Support from our parent company will include access to a law department, finance department, information systems, technical support, human resources and such other administrative support that may be required. In particular, we anticipate using outside advisors and lawyers to assist in managing any disputes which must be resolved. Once the top level domain has been awarded, we do not anticipate disputes beyond what is frequently encountered in operating the .com. However, given the expanded opportunities associated with operating the top level domain, we have increased the likelihood of disputes, take down notices or such other matters and increased the .com dispute resolution budget. We will utilize outside advisors to provide the additional talent and resources and specialized knowledge that we cannot cost effectively maintain internally. Projected costs associated with these resources are further discussed in the response to Question 47 below.

Resource Planning Specific to Backend Registry Activities

Verisign, Applicant’s selected backend registry services provider, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to Applicant fully accounts for cost related to this infrastructure, which is provided as Line IIb.G, Total Critical Function Cash Outflows, within the Question 46 financial projections response.

Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force. (Current statistics are publicly available in Verisign’s quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100 percent of the time for more than 13 years for .com, proving Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s TLD service offerings. 

Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support the implementation of RPMs:
• Customer Affairs Organization: 9
• Customer Support Personnel: 36
• Information Security Engineers: 11

To implement and manage the Applicant’s TLD as described in this application, Verisign, Applicant’s selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area. 

When usage projections indicate a need for additional staff, Verisign’s internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed gTLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internet’s largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.

1 DETAILED DESCRIPTION OF PROCESSES AND SOLUTIONS DEPLOYED TO MANAGE LOGICAL SECURITY ACROSS INFRASTRUCTURE AND SYSTEMS, MONITORING AND DETECTING THREATS AND SECURITY VULNERABILITIES AND TAKING APPROPRIATE STEPS TO RESOLVE THEM
The Applicant’s selected backend registry services provider’s (Verisign’s) comprehensive security policy has evolved over the years as part of managing some of the world’s most critical TLDs. Verisign’s Information Security Policy is the primary guideline that sets the baseline for all other policies, procedures, and standards that Verisign follows. This security policy addresses all of the critical components for the management of backend registry services, including architecture, engineering, and operations. 
Verisign’s general security policies and standards with respect to these areas are provided as follows:
• Architecture
• Information Security Architecture Standard: This standard establishes the Verisign standard for application and network architecture. The document explains the methods for segmenting application tiers, using authentication mechanisms, and implementing application functions.
• Information Security Secure Linux Standard: This standard establishes the information security requirements for all systems that run Linux throughout the Verisign organization.
• Information Security Secure Oracle Standard: This standard establishes the information security requirements for all systems that run Oracle throughout the Verisign organization.
• Information Security Remote Access Standard: This standard establishes the information security requirements for remote access to terminal services throughout the Verisign organization.
• Information Security SSH Standard: This standard establishes the information security requirements for the application of Secure Shell (SSH) on all systems throughout the Verisign organization.
• Engineering
• Secure SSL⁄TLS Configuration Standard: This standard establishes the information security requirements for the configuration of Secure Sockets Layer⁄Transport Layer Security (SSL⁄TLS) for all systems throughout the Verisign organization.
• Information Security C++ Standards: These standards explain how to use and implement the functions and application programming interfaces (APIs) within C++. The document also describes how to perform logging, authentication, and database connectivity.
• Information Security Java Standards: These standards explain how to use and implement the functions and APIs within Java. The document also describes how to perform logging, authentication, and database connectivity.
• Operations
• Information Security DNS Standard: This standard establishes the information security requirements for all systems that run DNS systems throughout the Verisign organization.
• Information Security Cryptographic Key Management Standard: This standard provides detailed information on both technology and processes for the use of encryption on Verisign information security systems.
• Secure Apache Standard: Verisign has a multitude of Apache web servers, which are used in both production and development environments on the Verisign intranet and on the Internet. They provide a centralized, dynamic, and extensible interface to various other systems that deliver information to the end user. Because of their exposure and the confidential nature of the data that these systems host, adequate security measures must be in place. The Secure Apache Standard establishes the information security requirements for all systems that run Apache web servers throughout the Verisign organization.
• Secure Sendmail Standard: Verisign uses sendmail servers in both the production and development environments on the Verisign intranet and on the Internet. Sendmail allows users to communicate with one another via email. The Secure Sendmail Standard establishes the information security requirements for all systems that run sendmail servers throughout the Verisign organization.
• Secure Logging Standard: This standard establishes the information security logging requirements for all systems and applications throughout the Verisign organization. Where specific standards documents have been created for operating systems or applications, the logging standards have been detailed. This document covers all technologies.
• Patch Management Standard: This standard establishes the information security patch and upgrade management requirements for all systems and applications throughout Verisign.
• General
• Secure Password Standard: Because passwords are the most popular and, in many cases, the sole mechanism for authenticating a user to a system, great care must be taken to help ensure that passwords are “strong” and secure. The Secure Password Standard details requirements for the use and implementation of passwords.
• Secure Anti-Virus Standard: Verisign must be protected continuously from computer viruses and other forms of malicious code. These threats can cause significant damage to the overall operation and security of the Verisign network. The Secure Anti-Virus Standard describes the requirements for minimizing the occurrence and impact of these incidents.

Security processes and solutions for this TLD are based on the standards defined above, each of which is derived from Verisign’s experience and industry best practice. These standards comprise the framework for the overall security solution and applicable processes implemented across all products under Verisign’s management. The security solution and applicable processes include, but are not limited to:
• System and network access control (e.g., monitoring, logging, and backup) 
• Independent assessment and periodic independent assessment reports
• Denial of service (DoS) and distributed denial of service (DDoS) attack mitigation
• Computer and network incident response policies, plans, and processes
• Minimization of risk of unauthorized access to systems or tampering with registry data
• Intrusion detection mechanisms, threat analysis, defenses, and updates 
• Auditing of network access
• Physical security

Further details of these processes and solutions are provided in Part B of this response.
1.1 Security Policy and Procedures for the Proposed Registry
Specific security policy related details, requested as the bulleted items of Question 30 – Part A, are provided here. 
Independent Assessment and Periodic Independent Assessment Reports. To help ensure effective security controls are in place, the Applicant, through its selected backend registry services provider, Verisign, conducts a yearly American Institute of Certified Public Accountants (AICPA) and Canadian Institute of Chartered Accountants (CICA) SAS 70 audit on all of its data centers, hosted systems, and applications. During these SAS 70 audits, security controls at the operational, technical, and human level are rigorously tested. These audits are conducted by a certified and accredited third party and help ensure that Verisign in-place environments meet the security criteria specified in Verisign’s customer contractual agreements and are in accordance with commercially accepted security controls and practices. Verisign also performs numerous audits throughout the year to verify its security processes and activities. These audits cover many different environments and technologies and validate Verisign’s capability to protect its registry and DNS resolution environments. Figure ‎30A 1 lists a subset of the audits that Verisign conducts. For each audit program or certification listed in Figure ‎30A 1, Verisign has included, as attachments to the Part B component of this response, copies of the assessment reports conducted by the listed third-party auditor. From Verisign’s experience operating registries, it has determined that together these audit programs and certifications provide a reliable means to ensure effective security controls are in place and that these controls are sufficient to meet ICANN security requirements and therefore are commensurate with the guidelines defined by ISO 27001.

Augmented Security Levels or Capabilities. See Section 5 of this response. 
Commitments Made to Registrants Concerning Security Levels. See Section 4 of this response.
2 SECURITY CAPABILITIES ARE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY
Verisign, the Applicant’s selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies. 
Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the TLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to the Applicant fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.
3 TECHNICAL PLAN ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION
Verisign, the Applicant’s selected backend registry services provider, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to the Applicant fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response. 
Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force. (Current statistics are publicly available in Verisign’s quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100 percent of the time for more than 13 years for .com, proving Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s TLD service offerings. 
Verisign projects it will use the following personnel role, which is described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support its security policy:
• Information Security Engineers: 11

To implement and manage the TLD as described in this application, Verisign, the Applicant’s selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area. 
When usage projections indicate a need for additional staff, Verisign’s internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed gTLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internet’s largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.
4 SECURITY MEASURES ARE CONSISTENT WITH ANY COMMITMENTS MADE TO REGISTRANTS REGARDING SECURITY LEVELS
Verisign is the Applicant’s selected backend registry services provider. For this gTLD, no unique security measures or commitments must be made by Verisign or the Applicant to any registrant.
5 SECURITY MEASURES ARE APPROPRIATE FOR THE APPLIED-FOR gTLD STRING (FOR EXAMPLE, APPLICATIONS FOR STRINGS WITH UNIQUE TRUST IMPLICATIONS, SUCH AS FINANCIAL SERVICES-ORIENTED STRINGS, WOULD BE EXPECTED TO PROVIDE A COMMENSURATE LEVEL OF SECURITY)
No unique security measures are necessary to implement this gTLD. As defined in Section 1 of this response, Verisign, the Applicant’s selected backend registry services provider, commits to providing backend registry services in accordance with the following international and relevant security standards:
• American Institute of Certified Public Accountants (AICPA) and Canadian Institute of Chartered Accountants (CICA) SAS 70 
• WebTrust⁄SysTrust for Certification Authorities (CA)
As defined in Section 1 of this response, Verisign, the Applicant’s selected backend registry services provider, commits to providing backend registry services in accordance with the following international and relevant security standards:
• American Institute of Certified Public Accountants (AICPA) and Canadian Institute of Chartered Accountants (CICA) SAS 70 
• WebTrust⁄SysTrust for Certification Authorities (CA)