Application number: 1-1507-65003 for Trixy Birch, LLC

Trixy Birch, LLC

155 108th Avenue NE, Suite 510
Bellevue 98004
US

+1 424 254 8537

+1 425 671 0020

Daniel Schindler

EVP, Donuts Inc.

+1 424 254 8537

trixybirch@donuts.co

Jonathon Nevett

EVP, Donuts Inc.

+1 424 254 8537

secondary@donuts.co

Limited Liability Company

Delaware. http:⁄⁄delcode.delaware.gov⁄title6⁄c018⁄sc01⁄index.shtml

Not Available

Dozen Donuts, LLC

Dozen Donuts, LLC
N⁄A

Paul Stahura
CEO, Donuts Inc.

hosting

Not Available

Donuts has conducted technical analysis on the applied-for string, and concluded that there are no known potential operational or rendering issues associated with the string.
The following sections discuss the potential operational or rendering problems that can arise, and how Donuts mitigates them.
## Compliance and Interoperability
The applied-for string conforms to all relevant RFCs, as well as the string requirements set forth in Section 2.2.1.3.2 of the Applicant Guidebook.
## Mixing Scripts
If a domain name label contains characters from different scripts, it has a higher likelihood of encountering rendering issues. If the mixing of scripts occurs within the top-level label, any rendering issue would affect all domain names registered under it. If occurring within second level labels, its ill-effects are confined to the domain names with such labels.
All characters in the applied-for gTLD string are taken from a single script. In addition, Donutsʹs IDN policies are deliberately conservative and compliant with the ICANN Guidelines for the Implementation of IDN Version 3.0. Specifically, Donuts does not allow mixed-script labels to be registered at the second level, except for languages with established orthographies and conventions that require the commingled use of multiple scripts, e.g. Japanese.
## Interaction Between Labels
Even with the above issue appropriately restricted, it is possible that a domain name composed of labels with different properties such as script and directionality may introduce unintended rendering behaviour.
Donuts adopts a conservative strategy when offering IDN registrations. In particular, it ensures that any IDN language tables used for offering IDN second level registrations involve only scripts and characters that would not pose a risk when combined with the top level label.
## Immature Scripts
Scripts or characters added in Unicode versions newer than 3.2 (on which IDNA2003 was based) may encounter interoperability issues due to the lack of software support.
Donuts does not currently plan to offer registration of labels containing such scripts or characters.
## Other Issues
To further contain the risks of operation or rendering problems, Donuts currently does not offer registration of labels containing combining characters or characters that require IDNA contextual rules handling. It may reconsider this decision in cases where a language has a clear need for such characters.
Donuts understands that the following may be construed as operational or rendering issues, but considers them out of the scope of this question. Nevertheless, it will take reasonable steps to protect registrants and Internet users by working with vendors and relevant language communities to mitigate such issues.
- missing fonts causing string to fail to render correctly; and
- universal acceptance of the TLD;

Q18A CHAR: 7985

ABOUT DONUTS
Donuts Inc. is the parent applicant for this and multiple other TLDs. The company intends to increase competition and consumer choice at the top level. It will operate these carefully selected TLDs safely and securely in a shared resources business model. To achieve its objectives, Donuts has recruited seasoned executive management with proven track records of excellence in the industry. In addition to this business and operational experience, the Donuts team also has contributed broadly to industry policymaking and regulation, successfully launched TLDs, built industry-leading companies from the ground up, and brought innovation, value and choice to the domain name marketplace.

DONUTS’ PLACE WITHIN ICANN’S MISSION
ICANN and the new TLD program share the following purposes: 
1. to make sure that the Internet remains as safe, stable and secure as possible, while 
2. helping to ensure there is a vibrant competitive marketplace to efficiently bring the benefits of the namespace to registrants and users alike. 

ICANN harnesses the power of private enterprise to bring forth these public benefits. While pursuing its interests, Donuts helps ICANN accomplish its objectives by:

1. Significantly widening competition and choice in Internet identities with hundreds of new top-level domain choices; 
2. Providing innovative, robust, and easy-to-use new services, names and tools for users, registrants, registrars, and registries while at the same time safeguarding the rights of others;
3. Designing, launching, and securely operating carefully selected TLDs in multiple languages and character sets; and
4. Providing a financially robust corporate umbrella under which its new TLDs will be protected and can thrive.

ABOUT DONUTS’ RESOURCES
Donuts’ financial resources are extensive. The company has raised more than US$100 million from a number of capital sources including multiple multi-billion dollar venture capital and private equity funds, a top-tier bank, and other well-capitalized investors. Should circumstances warrant, Donuts is prepared to raise additional funding from current or new investors. Donuts also has in place pre-funded, Continued Operations Instruments to protect future registrants. These resource commitments mean Donuts has the capability and intent to launch, expand and operate its TLDs in a secure manner, and to properly protect Internet users and rights-holders from potential abuse. 

Donuts firmly believes a capable and skilled organization will operate multiple TLDs and benefit Internet users by:

1. Providing the operational and financial stability necessary for TLDs of all sizes, but particularly for those with smaller volume (which are more likely to succeed within a shared resources and shared services model);
2. Competing more powerfully against incumbent gTLDs; and
3. More thoroughly and uniformly executing consumer and rights holder protections.

THIS TLD
This TLD is attractive and useful to end-users as it better facilitates search, self-expression, information sharing and the provision of legitimate goods and services. Along with the other TLDs in the Donuts family, this TLD will provide Internet users with opportunities for online identities and expression that do not currently exist. In doing so, the TLD will introduce significant consumer choice and competition to the Internet namespace – the very purpose of ICANN’s new TLD program. 

This TLD is a generic term and its second level names will be attractive to a variety of Internet users. Making this TLD available to a broad audience of registrants is consistent with the competition goals of the New TLD expansion program, and consistent with ICANN’s objective of maximizing Internet participation. Donuts believes in an open Internet and, accordingly, we will encourage inclusiveness in the registration policies for this TLD. In order to avoid harm to legitimate registrants, Donuts will not artificially deny access, on the basis of identity alone (without legal cause), to a TLD that represents a generic form of activity and expression.

DONUTS’ APPROACH TO PROTECTIONS
No entity, or group of entities, has exclusive rights to own or register second level names in this TLD. There are superior ways to minimize the potential abuse of second level names, and in this application Donuts will describe and commit to an extensive array of protections against abuse, including protections against the abuse of trademark rights. 

We recognize some applicants seek to address harms by constraining access to the registration of second level names. However, we believe attempts to limit abuse by limiting registrant eligibility is unnecessarily restrictive and harms users by denying access to many legitimate registrants. Restrictions on second level domain eligibility would prevent law-abiding individuals and organizations from participating in a space to which they are legitimately connected, and would inhibit the sort of positive innovation we intend to see in this TLD. As detailed throughout this application, we have struck the correct balance between consumer and business safety, and open access to second level names.

By applying our array of protection mechanisms, Donuts will make this TLD a place for Internet users that is far safer than existing TLDs. Donuts will strive to operate this TLD with fewer incidences of fraud and abuse than occur in incumbent TLDs. In addition, Donuts commits to work toward a downward trend in such incidents. 

OUR PROTECTIONS
Donuts has consulted with and evaluated the ideas of international law enforcement, consumer privacy advocacy organizations, intellectual property interests and other Internet industry groups to create a set of protections that far exceed those in existing TLDs, and bring to the Internet namespace nearly two dozen new rights and protection mechanisms to raise user safety and protection to a new level. 

These include eight, innovative and forceful mechanisms and resources that far exceed the already powerful protections in the applicant guidebook. These are: 

1. Periodic audit of WhoIs data for accuracy;
2. Remediation of inaccurate Whois data, including takedown, if warranted;
3. A new Domain Protected Marks List (DPML) product for trademark protection; 
4. A new Claims Plus product for trademark protection;
5. Terms of use that prohibit illegal or abusive activity;
6. Limitations on domain proxy and privacy service;
7. Published policies and procedures that define abusive activity; and 
8. Proper resourcing for all of the functions above.

They also include fourteen new measures that were developed specifically by ICANN for the new TLD process. These are: 

1. Controls to ensure proper access to domain management functions;
2. 24⁄7⁄365 abuse point of contact at registry;
3. Procedures for handling complaints of illegal or abusive activity, including remediation and takedown processes; 
4. Thick WhoIs;
5. Use of the Trademark Clearinghouse;
6. A Sunrise process;
7. A Trademark Claims process;
8. Adherence to the Uniform Rapid Suspension system;
9. Adherence to the Uniform Domain Name Dispute Resolution Policy;
10. Adherence to the Post Delegation Dispute Resolution Policy;
11. Detailed security policies and procedures;
12. Strong security controls for access, threat analysis and audit;
13. Implementation DNSSEC; and
14. Measures for the prevention of orphan glue records.

DONUTS’ INTENTION FOR THIS TLD
As a senior government authority has recently said, “a successful applicant is entrusted with operating a critical piece of global Internet infrastructure.” Donuts’ plan and intent is for this TLD to serve the international community by bringing new users online through opportunities for economic growth, increased productivity, the exchange of ideas and information and greater self-expression.

Q18B CHAR: 6457

Donuts will be the industry leader in customer service, reputation and choice. The reputation of this, and other TLDs in the Donuts portfolio, will be built on:
1. Our successful launch and marketplace reach; 
2. The stability of registry operations; and
3. The effectiveness of our protection mechanisms. 

THE GOAL OF THIS TLD

This and other Donuts TLDs represent discrete segments of commerce and human interest, and will give Internet users a better vehicle for reaching audiences. In reviewing potential strings, we deeply researched discrete industries and sectors of human activity and consulted extensive data sources relevant to the online experience. Our methodology resulted in the selection of this TLD – one that offers a very high level of user utility, precision in content delivery, and ability to contribute positively to economic growth.

SERVICE LEVELS

Donuts will endeavor to provide a service level that is higher than any existing TLD. Donuts’ commitment is to meet and exceed ICANN-mandated availability requirements, and to provide industry-leading services, including non-mandatory consumer and rights protection mechanisms (as described in answers to Questions 28, 29, and 30) for a beneficial customer experience.

REPUTATION

As noted, Donuts management enjoys a reputation of excellence as domain name industry contributors and innovators. This management team is committed to the successful expansion of the Internet, the secure operation of the DNS, and the creation of a new segment of the web that will be admired and respected. 

The Donuts registry and its operations are built on the following principles: 

1. More meaningful product choice for registrants and users;
2. Innovative services;
3. Competitive pricing; and
4. A more secure environment with better protections.

These attributes will flow to every TLD we operate. This string’s reputation will develop as a compelling product choice, with innovative offerings, competitive pricing, and safeguards for consumers, businesses and other users. 

Finally, the Donuts team has significant operational experience with registrars, and will collaborate knowledgeably with this channel to deliver new registration opportunities to end-users in way that is consistent with Donuts principles. 

NAMESPACE COMPETITION

This TLD will contribute significantly to the current namespace. It will present multiple new domain name alternatives compared to existing generic and country code TLDs. The DNS today offers very limited addressing choices, especially for registrants who seek a specific identity. 

INNOVATION

Donuts will provide innovative registration methods that allow registrants the opportunity to secure an important identity using a variety of easy-to-use tools that fit individual needs and preferences. 

Consistent with our principle of innovation, Donuts will be a leader in rights protection, shielding those that deserve protection and not unfairly limiting or directing those that don’t. As detailed in this application, far-reaching protections will be provided in this TLD. Nevertheless, the Donuts approach is inclusive, and second level registrations in this TLD will be available to any responsible registrant with an affinity for this string. We will use our significant protection mechanisms to prevent and eradicate abuse, rather than attempting to do so by limiting registrant eligibility.

This TLD will contribute to the user experience by offering registration alternatives that better meet registrants’ identity needs, and by providing more intuitive methods for users to locate products, services and information. This TLD also will contribute to marketplace diversity, an important element of user experience. In addition, Donuts will offer its sales channel a suite of innovative registration products that are inviting, practical and useful to registrants.

As noted, Donuts will be inclusive in its registration policies and will not limit registrant eligibility at the second level at the moment of registration. Restricting access to second level names in this broadly generic TLD would cause more harm than benefit by denying domain access to legitimate registrants. Therefore, rather than artificially limiting registrant access, we will control abuse by carefully and uniformly implementing our extensive range of user and rights protections.

Donuts will not limit eligibility or otherwise exclude legitimate registrants in second level names. Our primary focus will be the behavior of registrants, not their identity.

Donuts will specifically adhere to ICANN-required registration policies and will comply with all requirements of the Registry Agreement and associated specifications regarding registration policies. Further, Donuts will not tolerate abuse or illegal activity in this TLD, and will have strict registration policies that provide for remediation and takedown as necessary.

Donuts TLDs will comply with all applicable laws and regulations regarding privacy and data protection. Donuts will provide a highly secure registry environment for registrant and user data (detailed information on measures to protect data is available in our technical response). 

Donuts will permit the use of proxy and privacy services for registrations in this TLD, as there are important, legitimate uses for such services (including free speech rights and the avoidance of spam). Donuts will limit how such proxy and privacy services are offered (details on these limitations are provided in our technical response). Our approach balances the needs of legitimate and responsible registrants with the need to identify registrants who illegally use second level domains. 

Donuts will build on ICANN’s outreach and media coverage for the new TLD Program and will initiate its own effort to educate Internet users and rights holders about the launch of this TLD. Donuts will employ three specific communications efforts. We will:

1. Communicate to the media, analysts, and directly to registrants about the Donuts enterprise.
2. Build on existing relationships to create an open dialogue with registrars about what to expect from Donuts, and about the protections required by any registrar selling this TLD.
3. Communicate directly to end-users, media and third parties interested in the attributes and benefits of this TLD.

Q18C Standard CHAR: 1440

Generally, during the Sunrise phase of this TLD, Donuts will conduct an auction if there are two or more competing applications from validated trademark holders for the same second level name. Alternatively, if there is a defined trademark classification reflective of this TLD, Donuts may give preference to second-level applicants with rights in that classification of goods and services. Post-Sunrise, requests for registration will generally be on a first-come, first-served basis.

Donuts may offer reduced pricing for registrants interested in long-term registration, and potentially to those who commit to publicizing their use of the TLD. Other advantaged pricing may apply in selective cases, including bulk purchase pricing. 

Donuts will comply with all ICANN-related requirements regarding price increases: advance notice of any renewal price increase (with the opportunity for existing registrants to renew for up to ten years at their current pricing); and advance notice of any increase in initial registration pricing. 

The company does not otherwise intend, at this time, to make contractual commitments regarding pricing. Donuts has made every effort to correctly price its offerings for end-user value prior to launch. Our objective is to avoid any disruption to our customers after they have registered. We do not plan or anticipate significant price increases over time.

No

Not Available

No

Q22 CHAR: 4979

As previously discussed (in our response to Q18: Mission ⁄ Purpose) Donuts believes in an open Internet. Consistent with this we also believe in an open DNS, where second level domain names are available to all registrants who act responsibly. 

The range of second level names protected by Specification 5 of the Registry Operator contract is extensive (approx. 2,000 strings are blocked). This list resulted from a lengthy process of collaboration and compromise between members of the ICANN community, including the Governmental Advisory Committee. Donuts believes this list represents a healthy balance between the protection of national naming interests and free speech on the Internet. 

Donuts does not intend to block second level names beyond those detailed in Specification 5. Should a geographic name be registered in this TLD and used for illegal or abusive activity Donuts will remedy this by applying the array of protections implemented in this TLD. (For details about these protections please see our responses to Questions 18, 28, 29 and 30).

Donuts will strictly adhere to the relevant provisions of Specification 5 of the New gTLD Agreement. Specifically:

1. All two-character labels will be initially reserved, and released only upon agreement between Donuts and the relevant government and country code manager.
2. At the second level, country and territory names will be reserved at the second and other levels according to these standards:
2.1. Short form (in English) of country and territory names documented in the ISO 3166-1 list;
2.2. Names of countries and territories as documented by the United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardization of Geographical Names, Part III Names of Countries of the World; and
2.3. The list of United Nations member states in six official UN languages, as prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names.
Donuts will initially reserve country and territory names at the second level and at all other levels within the TLD. Donuts supports this requirement by using the following internationally recognized lists to develop a comprehensive master list of all geographic names that are initially reserved:

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

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

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

4. The 2-letter alpha-2 code of all country and territory names contained on the ISO 3166-1 list, including all reserved and unassigned codes 

This comprehensive list of names will be ineligible for registration. Only in consultation with the GAC and ICANN would Donuts develop a proposal for release of these reserved names, and seek approval accordingly. Donuts understands governmental processes require time-consuming, multi-department consultations. Accordingly, we will apportion more than adequate time for the GAC and its members to review any proposal we provide.

Donuts recognizes the potential use of country and territory names at the third level. We will address and mitigate attempted third-level use of geographic names as part of our operations.

Donuts’ list of geographic names will be transmitted to Registrars as part of the onboarding process and will also be made available to the public via the TLD website. Changes to the list are anticipated to be rare; however, Donuts will regularly review and revise the list as changes are made by government authorities.

For purposes of clarity the following will occur for a domain that is reserved by the registry:
1. An availability check for a domain in the reserved list will result in a “not available” status. The reason given will indicate that the domain is reserved.
2. An attempt to register a domain name in the reserved list will result in an error.
3. An EPP info request will result in an error indicating the domain name was not found.
4. Queries for a reserved name in the WHOIS system will display information indicating the reserved status and indicate it is not registered nor is available for registration.
5. Reserved names will not be published or used in the zone in any way.
6. Queries for a reserved name in the DNS will result in an NXDOMAIN response.

Q23 CHAR: 22971

TLD Applicant is applying to become an ICANN accredited Top Level Domain (TLD) registry. TLD Applicant meets the operational, technical, and financial capability requirements to pursue, secure and operate the TLD registry. The responses to technical capability questions were prepared to demonstrate, with confidence, that the technical capabilities of TLD Applicant meet and substantially exceed the requirements proposed by ICANN.

The following response describes our registry services, as implemented by Donuts and our partners. Such partners include Demand Media Europe Limited (DMEL) for back-end registry services; AusRegistry Pty Ltd. (ARI) for Domain Name System (DNS) services and Domain Name Service Security Extensions (DNSSEC); an independent consultant for abuse mitigation and prevention consultation; Equinix and SuperNap for datacenter facilities and infrastructure; and Iron Mountain Intellectual Property Management, Inc. (Iron Mountain) for data escrow services. For simplicity, the term “company” and the use of the possessive pronouns “we”, “us”, “our”, “ours”, etc., all refer collectively to Donuts and our subcontracted service providers.

DMEL is a wholly-owned subsidiary of DMIH Limited, a well-capitalized Irish corporation whose ultimate parent company is Demand Media, Inc., a leading content and social media company listed on the New York Stock Exchange (ticker: DMD). DMEL is structured to operate a robust and reliable Shared Registration System by leveraging the infrastructure and expertise of DMIH and Demand Media, Inc., which includes years of experience in the operation side for domain names in both gTLDs and ccTLDs for over 10 years. 

1.0. EXECUTIVE SUMMARY

We offer all of the customary services for proper operation of a gTLD registry using an approach designed to support the security and stability necessary to ensure continuous uptime and optimal registry functionality for registrants and Internet users alike. 

2.0. REGISTRY SERVICES

2.1. Receipt of Data from registrars

The process of registering a domain name and the subsequent maintenance involves interactions between registrars and the registry. These interactions are facilitated by the registry through the Shared Registration System (SRS) through two interfaces:

- EPP: A standards-based XML protocol over a secure network channel.
- Web: A web based interface that exposes all of the same functionality as EPP yet accessible through a web browser.

Registrants wishing to register and maintain their domain name registrations must do so through an ICANN accredited registrar. The XML protocol, called the Extensible Provisioning Protocol (EPP) is the standard protocol widely used by registrars to communicate provisioning actions. Alternatively, registrars may use the web interface to create and manage registrations.

The registry is implemented as a “thick” registry meaning that domain registrations must have contact information associated with each. Contact information will be collected by registrars and associated with domain registrations.

2.1.1. SRS EPP Interface

The SRS EPP Interface is provided by a software service that provides network based connectivity. The EPP software is highly compliant with all appropriate RFCs including:

- RFC 5730 Extensible Provisioning Protocol (EPP)
- RFC 5731 Extensible Provisioning Protocol (EPP) Domain Name Mapping
- RFC 5732 Extensible Provisioning Protocol (EPP) Host Mapping
- RFC 5733 Extensible Provisioning Protocol (EPP) Contact Mapping
- RFC 5734 Extensible Provisioning Protocol (EPP) Transport over TCP
- RFC 5910 Domain Name System (DNS) Security Extensions for Extensible Provisioning Protocol (EPP)
- RFC 3915 Domain Registry Grace Period Mapping for EPP

2.1.1.1. SRS EPP Interface Security Considerations

Security precautions are put in place to ensure transactions are received only from authorized registrars in a private, secure manner. Registrars must provide the registry with narrow subnet ranges, allowing the registry to restrict network connections that originate only from these pre-arranged networks. The source IP address is verified against the authentication data received from the connection to further validate the source of the connection. Registrars may only establish a limited number of connections and the network traffic is rate limited to ensure that all registrars receive the same quality of service. Network connections to the EPP server must be secured with TLS. The revocation status and validity of the certificate are checked.

Successful negotiation of a TLS session begins the process of authentication using the protocol elements of EPP. Registrars are not permitted to continue without a successful EPP session establishment. The EPP server validates the credential information passed by the registrar along with validation of:

- Certificate revocation status 
- Certificate chain
- Certificate Common Name matches the Common Name the registry has listed for the source IP address 
- User name and password are correct and match those listed for the source IP address

In the event a registrar creates a level of activity that threatens the service quality of other registrars, the service has the ability to rate limit individual registrars.

2.1.1.2. SRS EPP Interface Stability Considerations

To ensure the stability of the EPP Interface software, strict change controls and access controls are in place. Changes to the software must be approved by management and go through a rigorous testing and staged deployment procedure. 

Additional stability is achieved by carefully regulating the available computing resources. A policy of conservative usage thresholds leaves an equitable amount of computing resources available to handle spikes and service management.

2.1.2. SRS Web Interface

The SRS web interface is an alternative way to access EPP functionality using a web interface, providing the features necessary for effective operations of the registry. This interface uses the HTTPS protocol for secure web communication. Because users can be located worldwide, as with the EPP interface, the web interface is available to all registrars over multiple network paths.
Additional functionality is available to registrars to assist them in managing their account. For instance, registrars are able to view their account balance in near real time as well as the status of the registry services. In addition, notifications that are sent out in email are available for viewing.

2.1.2.1. Web Interface Security Considerations

Only registrars are authorized to use the SRS web interface, and therefore the web interface has several security measures to prevent abuse. The web interface requires an encrypted network channel using the HTTPS protocol. Attempts to access the interface through a clear channel are redirected to the encrypted channel.

The web interface restricts access by requiring each user to present authentication credentials before proceeding. In addition to the typical user name and password combinations, the web interface also requires the user to possess a hardware security key as a second factor of authentication. 

Registrars are provided a tool to create and manage users that are associated with their account. With these tools, they can set access and authorization levels for their staff.

2.1.2.2. Web Interface Stability Considerations

Both the EPP interface and web interface use a common service provider to perform the work required to fulfill their requests. This provides consistency across both interfaces and ensures all policies and security rules are applied.

The software providing services for both interfaces executes on a farm of servers, distributing the load more evenly ensuring stability is maintained.
 
2.2. Dissemination of TLD Zone Files

2.2.1. Communication of Status Information of TLD Zone Servers to Registrars

The status of TLD zone servers and their ability to reflect changes in the SRS is of great importance to registrars and Internet users alike. We ensure that any change from normal operations is communicated to the relevant stakeholders as soon as is appropriate. Such communication might be prior to the status change, during the status change and⁄or after the status change (and subsequent reversion to normal) — as appropriate to the party being informed and the circumstance of the status change.

Normal operations are:

- DNS servers respond within SLAs for DNS resolution.
- Changes in the SRS are reflected in the zone file according to the DNS update time SLA.

The SLAs are those from Specification 10 of the Registry Agreement.

A deviation from normal operations, whether it is registry wide or restricted to a single DNS node, will result in the appropriate status communication being sent.

2.2.2. Communication Policy

We maintain close communication with registrars regarding the performance and consistency of the TLD zone servers.

A contact database containing relevant contact information for each registrar is maintained. In many cases, this includes multiple forms of contact, including email, phone and physical mailing address. Additionally, up-to-date status information of the TLD zone servers is provided within the SRS Web Interface.

Communication using the registrar contact information discussed above will occur prior to any maintenance that has the potential to effect the access to, consistency of, or reliability of the TLD zone servers. If such maintenance is required within a short timeframe, immediate communication occurs using the above contact information. In either case, the nature of the maintenance and how it affects the consistency or accessibility of the TLD zone servers, and the estimated time for full restoration, are included within the communication.

That being said, the TLD zone server infrastructure has been designed in such a way that we expect no downtime. Only individual sites will potentially require downtime for maintenance; however the DNS service itself will continue to operate with 100% availability.

2.2.3. Security and Stability Considerations

We restrict zone server status communication to registrars, thereby limiting the scope for malicious abuse of any maintenance window. Additionally, we ensure registrars have effective operational procedures to deal with any status change of the TLD nameservers and will seek to align its communication policy to those procedures.

2.3. Zone File Access Provider Integration

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

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

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

2.4. Zone File Update

To ensure changes within the SRS are reflected in the zone file rapidly and securely, we update the zone file on the TLD zone servers following a staged but rapid propagation of zone update information from the SRS, outwards to the TLD zone servers - which are visible to the Internet. As changes to the SRS data occur, those changes are updated to isolated systems which act as the authoritative primary server for the zone, but remain inaccessible to systems outside our network. The primary servers notify the designated secondary servers, which service queries for the TLD zone from the public. Upon notification, the secondary servers transfer the incremental changes to the zone and publicly present those changes.

The mechanisms for ensuring consistency within and between updates are fully implemented in our TLD zone update procedures. These mechanisms ensure updates are quickly propagated while the data remains consistent within each incremental update, regardless of the speed or order of individual update transactions. 

2.5. Operation of Zone Servers

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

2.5.1. Security and Operational Considerations of Zone Server Operations

The potential risks associated with operating TLD zone servers are recognized by us such that we will perform the steps required to protect the integrity and consistency of the information they provide, as well as to protect the availability and accessibility of those servers to hosts on the Internet. The TLD zone servers comply with all relevant RFCs for DNS and DNSSEC, as well as BCPs for the operation and hosting of DNS servers. The TLD zone servers will be updated to support any relevant new enhancements or improvements adopted by the IETF.

The DNS servers are geographically dispersed across multiple secure data centers in strategic locations around the world. By combining multi-homed servers and geographic diversity, ARI’s zone servers remain impervious to site level, supplier level or geographic level operational disruption.

The TLD zone servers are protected from accessibility loss by malicious intent or misadventure, via the provision of significant over-capacity of resources and access paths. Multiple independent network paths are provided to each TLD zone server and the query servicing capacity of the network exceeds the extremely conservatively anticipated peak load requirements by at least 10 times, to prevent loss of service should query loads significantly increase.

As well as the authentication, authorization and consistency checks carried out by the registrar access systems and DNS update mechanisms, ARI reduces the scope for alteration of DNS data by following strict DNS operational practices:

- TLD zone servers are not shared with other services.
- The primary authoritative TLD zone server is inaccessible outside ARI’s network.
- TLD zone servers only serve authoritative information.
- The TLD zone is signed with DNSSEC and a DNSSEC Practice⁄Policy Statement published.

2.6. Dissemination of Domain Registration Information

Domain name registration information is required for a variety of purposes. Our registry provides this information through the required WHOIS service through a standard text based network protocol on port 43. Whois also is provided on the registry’s web site using a standard web interface. Both interfaces are publically available at no cost to the user and are reachable worldwide.

The information displayed by the Whois service consists not only of the domain name but also of relevant contact information associated with the domain. It also identifies nameserver delegation and the registrar of record. This service is available to any Internet user, and use of it does not require prior authorization or permission.

2.6.1. Whois Port 43 Interface

The Whois port 43 interface consists of a standard Transmission Control Protocol (TCP) server that answers requests for information over port 43 in compliance with IETF RFC 3912. For each query, the TCP server accepts the connection over port 43 and then waits for a set time for the query to be sent. This communication occurs via clear, unencrypted ASCII text. If a properly formatted and valid query is received, the registry database is queried for the registration data. If registration data exists, it is returned to the service where it is then formatted and delivered to the requesting client. Each query connection is short-lived. Once the output is transmitted, the server closes the connection.

2.6.2. Whois Web Interface

The Whois web interface also uses clear, unencrypted text. The web interface is in an HTML format suitable for web browsers. This interface is also available over an encrypted channel on port 43 using the HTTPS protocol.

2.6.3. Security and Stability Considerations

Abuse of the Whois system through data mining is a concern as it can impact system performance and reduce the quality of service to legitimate users. The Whois system mitigates this type of abuse by detecting and limiting bulk query access from single sources. It does this in two ways: 1) by rate limiting queries by non-authorized parties; and 2) by ensuring all queries result in responses that do not include data sets representing significant portions of the registration database.
In addition, the Whois web interface adds a simple challenge-response CAPCHA that requires a user to type in the characters displayed in image format.
Both systems have blacklist functionality to provide a complete block to individual IPs or IP ranges. 

2.7. Internationalized Domain Names (IDNs)

An Internationalized Domain Name (IDN) contains at least one label that is displayed in a specific language script in IDN aware software. We will offer registration of second level IDN labels at launch,
IDNs are published into the TLD zone. The SRS EPP and Web Interfaces also support IDNs. 
The IDN implementation is fully compliant with the IDNA 2008 suite of standards (RFC 5890, 5891, 5892 and 5893) as well as the ICANN Guidelines for the Implementation of IDN Version 3.0 〈http:⁄⁄www.icann.org⁄en⁄resources⁄idn⁄implementation-guidelines〉. To ensure stability and security, we have adopted a conservative approach in our IDN registration policies, as well as technical implementation.

All IDN registrations must be requested using the A-label form, and accompanied by an RFC 5646 language tag identifying the corresponding language table published by the registry. The candidate A-label is processed according to the registration protocol as specified in Section 4 of RFC 5891, with full U-label validation. Specifically, the “Registry Restrictions” steps specified in Section 4.3 of RFC 5891 are implemented by validating the U-label against the identified language table to ensure that the set of characters in the U-label is a proper subset of the character repertoire listed in the language table.

2.7.1. IDN Stability Considerations

To avoid the intentional or accidental registration of visually similar characters, and to avoid identity confusion between domains, there are several restrictions on the registration of IDNs.
Domains registered within a particular language are restricted to only the characters of that language. This avoids the use of visually similar characters within one language which mimic the appearance of a label within another language, regardless of whether that label is already within the DNS or not.
Child domains are restricted to a specific language and registrations are prevented in one language being confused with a registration in another language; for example Cyrillic а (U+0430) and Latin a (U+0061).

2.8. DNSSEC

DNSSEC provides a set of extensions to the DNS that allow an Internet user (normally the resolver acting on a user’s behalf) to validate that the DNS responses they receive were not manipulated en-route.
This type of fraud, commonly called ‘man in the middle’, allows a malicious party to misdirect Internet users. DNSSEC allows a domain owner to sign their domain and to publish the signature, so that all DNS consumers who visit that domain can validate that the responses they receive are as the domain owner intended.

Registries, as the operators of the parent domain for registrants, must publish the DNSSEC material received from registrants, so that Internet users can trust the material they receive from the domain owner. This is commonly referred to as a “chain of trust.” Internet users trust the root (operated by IANA), which publishes the registries’ DNSSEC material, therefore registries inherit this trust. Domain owners within the TLD subsequently inherit trust from the parent domain when the registry publishes their DNSSEC material.

In accordance with new gTLD requirements, the TLD zone will be DNSSEC signed and the receipt of DNSSEC material from registrars for child domains is supported in all provisioning systems.

2.8.1. Stability and Operational Considerations for DNSSEC

2.8.1.1. DNSSEC Practice Statement

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

2.8.1.2. Resolution Stability

DNSSEC is considered to have made the DNS more trustworthy; however some transitional considerations need to be taken into account. DNSSEC increases the size and complexity of DNS responses. ARI ensures the TLD zone servers are accessible and offer consistent responses over UDP and TCP.

The increased UDP and TCP traffic which results from DNSSEC is accounted for in both network path access and TLD zone server capacity. ARI will ensure that capacity planning appropriately accommodates the expected increase in traffic over time.

ARI complies with all relevant RFCs and best practice guides in operating a DNSSEC-signed TLD. This includes conforming to algorithm updates as appropriate. To ensure Key Signing Key Rollover procedures for child domains are predictable, DS records will be published as soon as they are received via either the EPP server or SRS Web Interface. This allows child domain operators to rollover their keys with the assurance that their timeframes for both old and new keys are reliable.

3.0. APPROACH TO SECURITY AND STABILITY

Stability and security of the Internet is an important consideration for the registry system. To ensure that the registry services are reliably secured and remain stable under all conditions, DMEL takes a conservative approach with the operation and architecture of the registry system.

By architecting all registry services to use the least privileged access to systems and data, risk is significantly reduced for other systems and the registry services as a whole should any one service become compromised. By continuing that principal through to our procedures and processes, we ensure that only access that is necessary to perform tasks is given. ARI has a comprehensive approach to security modeled of the ISO27001 series of standards and explored further in the relevant questions of this response.

By ensuring all our services adhering to all relevant standards, DMEL ensures that entities which interact with the registry services do so in a predictable and consistent manner. When variations or enhancements to services are made, they are also aligned with the appropriate interoperability standards.

Q24 CHAR: 19964

TLD Applicant is applying to become an ICANN accredited Top Level Domain (TLD) registry. TLD Applicant meets the operational, technical, and financial capability requirements to pursue, secure and operate the TLD registry. The responses to technical capability questions were prepared to demonstrate, with confidence, that the technical capabilities of TLD Applicant meet and substantially exceed the requirements proposed by ICANN.

1.0. INTRODUCTION

Our Shared Registration System (SRS) complies fully with Specification 6, Section 1.2 and the SLA Matrix provided with Specification 10 in ICANN’s Registry Agreement and is in line with the projections outlined in our responses to Questions 31 and 46. The services provided by the SRS are critical to the proper functioning of a TLD registry. 

We will adhere to these commitments by operating a robust and reliable SRS founded on best practices and experience in the domain name industry. 

2.0. TECHNICAL OVERVIEW

A TLD operator must ensure registry services are available at all times for both registrants and the Internet community as a whole. To meet this goal, our SRS was specifically engineered to provide the finest levels of service derived from a long pedigree of excellence and experience in the domain name industry. This pedigree of excellence includes a long history of technical excellence providing long running, highly available and high-performing services that help thousands of companies derive their livelihoods. 

Our SRS services will give registrars standardized access points to provision and manage domain name registration data. We will provide registrars with two interfaces: an EPP protocol over TCP⁄IP and a web site accessible from any web browser (note: throughout this document, references to the SRS are inclusive of both these interfaces). 

Initial registration periods will comply with Specification 6 and will be in one (1) year increments up to a maximum of ten (10) years. Registration terms will not be allowed to exceed ten (10) years. In addition, renewal periods also will be in one-year increments and renewal periods will only allow an extension of the registration period of up to ten years from the time of renewal.

The performance of the SRS is critical for the proper functioning of a TLD. Poor performance of the registration systems can adversely impact registrar systems that depend on its responsiveness. Our SRS is committed to exceeding the performance specifications described in Specification 10 in all cases. To ensure that we are well within specifications for performance, we will test our system on a regular basis during development to ensure that changes have not impacted performance in a material way. In addition, we will monitor production systems to ensure compliance. If internal thresholds are exceeded, the issue will be escalated, analyzed and addressed.

Our SRS will offer registry services that support Internationalized Domain Names (IDNs). Registrations can be made through both the EPP and web interfaces. 

3.0. ROBUST AND RELIABLE ARCHITECTURE
To ensure quality of design, the SRS software was designed and written by seasoned and experienced software developers. This team designed the SRS using modern software architecture principles geared toward ensuring flexibility in its design not only to meet business needs but also to make it easy to understand, maintain and test. 

A classic 3-tier design was used for the architecture of the system. 3-tier is a well-proven architecture that brings flexibility to the system by abstracting the application layer from the protocol layer. The data tier is isolated and only accessible by the services tier. 3-tier adds an additional layer of security by minimizing access to the data tier through possible exploits of the protocol layer.

The protocol and services layers are fully redundant. A minimum of three physical servers is in place in both the protocol and services layers. Communications are balanced across the servers. Load balancing is accomplished with a redundant load balancer pair.

4.0. SOFTWARE QUALITY

The software for the SRS, as well as other registry systems, was developed using an approach that ensures that every line of source code is peer reviewed and source code is not checked into the source code repository without the accompanying automated tests that exercise the new functionality. The development team responsible for building the SRS and other registry software applies continuous integration practices to all software projects; all developers work on an up-to-date code base and are required to synchronize their code base with the master code base and resolve any incompatibilities before checking in. Every source code check-in triggers an automated build and test process to ensure a minimum level of quality. Each day an automated “daily build” is created, automatically deployed to servers and a fully-automated test suite run against it. Any failures are automatically assigned to developers to resolve in the morning when they arrive.

When extensive test passes are in order for release candidates, these developers use a test harness designed to run usability scenarios that exercise the full gamut of use cases, including accelerated full registration life cycles. These scenarios can be entered into the system using various distributions of activity. For instance, the test harness can be run to stress the system by changing the distribution of scenarios or to stress the system by exaggerating particular scenarios to simulate land rushes or, for long running duration scenarios, a more common day-to-day business distribution.

5.0. SOFTWARE COMPLIANCE

The EPP interface to our SRS is compliant with current RFCs relating to EPP protocols and best practices. This includes RFCs 5910, 5730, 5731, 5732, 5733 and 5734. Since we are also supporting Registry Grace Period functionality, we are also compliant with RFC 3915. Details of our compliance with these specifications are provided in our response to Question 25. We are also committed to maintaining compliance with future RFC revisions as they apply as documented in Section 1.2 of Specification 6 of the new gTLD Agreement.

We strive to be forward-thinking and will support the emerging standards of both IPv6 and DNSSEC on our SRS platform. The SRS was designed and has been tested to accept IPv6 format addresses for nameserver glue records and provision them to the gTLD zone. In addition, key registry services will be accessible over both IPv4 and IPv6. These include both the SRS EPP and SRS web-based interfaces, both port 43 and web-based WHOIS interfaces and DNS, among others. For details regarding our IPv6 reachability plans, please refer to our response to Question 36.

DNSSEC services are provided, and we will comply with Specification 6. Additionally, our DNSSEC implementation complies with RFCs 4033, 4034, 4035, and 4509; and we commit to complying with the successors of these RFCs and following the best practices described in RFC 4641. Additional compliance and commitment details on our DNSSEC services can be found in our response to Question 43.

6.0. DATABASE OPERATIONS

The database for our gTLD is Microsoft SQL Server 2008 R2. It is an industry-leading database engine used by companies requiring the highest level of security, reliability and trust. Case studies highlighting SQL Server’s reliability and use indicate its successful application in many industries, including major financial institutions such as Visa, Union Bank of Israel, KeyBank, TBC Bank, Paymark, Coca-Cola, Washington State voter registration and many others. In addition, Microsoft SQL Server provides a number of features that ease the management and maintenance of the system. Additional details about our database system can be found in our response to Question 33.

Our SRS architecture ensures security, consistency and quality in a number of ways. To prevent eavesdropping, the services tier communicates with the database over a secure channel. The SRS is architected to ensure all data written to the database is atomic. By convention, leave all matters of atomicity are left to the database. This ensures consistency of the data and reduces the chance of error. So that we can examine data versions at any point in time, all changes to the database are written to an audit database. The audit data contains all previous and new values and the date⁄time of the change. The audit data is saved as part of each atomic transaction to ensure consistency.

To minimize the chance of data loss due to a disk failure, the database uses an array of redundant disks for storage. In addition, maintain an exact duplicate of the primary site is maintained in a secondary datacenter. All hardware is fully duplicated and set up to take over operations at any time. All database operations are replicated to the secondary datacenter via synchronous replication. The secondary datacenter always maintains an exact copy of our live data as the transactions occur. 

7.0. REDUNDANT HARDWARE

The SRS is composed of several pieces of hardware that are critical to its proper functioning, reliability and scale. At least two of each hardware component comprises the SRS, making the service fully redundant. Any component can fail, and the system is designed to use the facility of its pair. The EPP interface to the SRS will operate with more than two servers to provide the capacity required to meet our projected scale as described in Question 46: Projections Template.

8.0. HORIZONTALLY SCALABLE

The SRS is designed to scale horizontally. That means that, as the needs of the registry grow, additional servers can be easily added to handle additional loads. 

The database is a clustered 2-node pair configured for both redundancy and performance. Both nodes participate in serving the needs of the SRS. A single node can easily handle the transactional load of the SRS should one node fail. In addition, there is an identical 2-node cluster in our backup datacenter. All data from the primary database is continuously replicated to the backup datacenter.

Not only is the registry database storage medium specified to provide the excess of capacity necessary to allow for significant growth, it is also configured to use techniques, such as data sharing, to achieve horizontal scale by distributing logical groups of data across additional hardware. For further detail on the scalability of our SRS, please refer to our response to Question 31.

9.0. REDUNDANT HOT FAILOVER SITE

We understand the need for maximizing uptime. As such, our plan includes maintaining at all times a warm failover site in a separate datacenter for the SRS and other key registry services. Our planned failover site contains an exact replica of the hardware and software configuration contained in the primary site. Registration data will be replicated to the failover site continuously over a secure connection to keep the failover site in sync.

Failing over an SRS is not a trivial task. In contrast, web site failover can be as simple as changing a DNS entry. Failing over the SRS, and in particular the EPP interface, requires careful planning and consideration as well as training and a well-documented procedure. Details of our failover procedures as well as our testing plans are detailed in our response to Question 41.

10.0. SECURE ACCESS

To ensure security, access to the EPP interface by registrars is restricted by IP⁄subnet. Access Control Lists (ACLs) are entered into our routers to allow access only from a restricted, contiguous subnet from registrars. Secure and private communication over mutually authenticated TLS is required. Authentication credentials and certificate data are exchanged in an out-of-band mechanism. Connections made to the EPP interface that successfully establish an EPP session are subject to server policies that dictate connection maximum lifetime and minimal activity to maintain the session.

To ensure fair and equal access for all registrars, as well as maintain a high level of service, we will use traffic shaping hardware to ensure all registrars receive an equal number of resources from the system. 

To further ensure security, access to the SRS web interface is over the public Internet via an encrypted HTTPS channel. Each registrar will be issued master credentials for accessing the web interface. Each registrar also will be required to use 2-factor authentication when logging in. We will issue a set of Yubikey (http:⁄⁄yubico.com) 2-factor, one-time password USB keys for authenticating with the web site. When the SRS web interface receives the credentials plus the one-time password from the Yubikey, it communicates with a RADIUS authentication server to check the credentials.

11.0. OPERATING A ROBUST AND RELIABLE SRS

11.1. AUTOMATED DEPLOYMENT

To minimize human error during a deployment, we use a fully-automated package and deployment system. This system ensures that all dependencies, configuration changes and database components are included every time. To ensure the package is appropriate for the system, the system also verifies the version of system we are upgrading.

11.2. CHANGE MANAGEMENT

We use a change management system for changes and deployments to critical systems. Because the SRS is considered a critical system, it is also subject to all change management procedures. The change management system covers all software development changes, operating system and networking hardware changes and patching. Before implementation, all change orders entered into the system must be reviewed with careful scrutiny and approved by appropriate management. New documentation and procedures are written; and customer service, operations, and monitoring staff are trained on any new functionality added that may impact their areas.

11.3. PATCH MANAGEMENT

Upon release, all operating system security patches are tested in the staging environment against the production code base. Once approved, patches are rolled out to one node of each farm. An appropriate amount of additional time is given for further validation of the patch, depending on the severity of the change. This helps minimize any downtime (and the subsequent roll back) caused by a patch of poor quality. Once validated, the patch is deployed on the remaining servers.

11.4. REGULAR BACKUPS

To ensure that a safe copy of all data is on hand in case of catastrophic failure of all database storage systems, backups of the main database are performed regularly. We perform full backups on both a weekly and monthly basis. We augment these full backups with differential backups performed daily. The backup process is monitored and any failure is immediately escalated to the systems engineering team. Additional details on our backup strategy and procedures can be found in our response to Question 37.

11.5. DATA ESCROW

Data escrow is a critical registry function. Escrowing our data on a regular basis ensures that a safe, restorable copy of the registration data is available should all other attempts to restore our data fail. Our escrow process is performed in accordance with Specification 2. Additional details on our data escrow procedures can be found in our response to Question 38.

11.6. REGULAR TRAINING

Ongoing security awareness training is critical to ensuring users are aware of security threats and concerns. To sustain this awareness, we have training programs in place designed to ensure corporate security policies pertaining to registry and other operations are understood by all personnel. All employees must pass a proficiency exam and sign the Information Security Policy as part of their employment. Further detail on our security awareness training can be found in our response to Question 30a.

We conduct failover training regularly to ensure all required personnel are up-to-date on failover process and have the regular practice needed to ensure successful failover should it be necessary. We also use failover training to validate current policies and procedures. For additional details on our failover training, please refer to our response to Question 41.

11.7. ACCESS CONTROL

User authentication is required to access any network or system resource. User accounts are granted the minimum access necessary. Access to production resources is restricted to key IT personnel. Physical access to production resources is extremely limited and given only as needed to IT-approved personnel. For further details on our access control policies, please refer to our response to Question 30a.

11.8. 24⁄7 MONITORING AND REGISTRAR TECHNICAL SUPPORT

We employ a full-time staff trained specifically on monitoring and supporting the services we provide. This staff is equipped with documentation outlining our processes for providing first-tier analysis, issue troubleshooting, and incident handling. This team is also equipped with specialty tools developed specifically to safely aid in diagnostics. On-call staff second-tier support is available to assist when necessary. To optimize the service we provide, we conduct ongoing training in both basic and more advanced customer support and conduct additional training, as needed, when new system or tool features are introduced or solutions to common issues are developed.

12.0. SRS INFRASTRUCTURE

As shown in Attachment A, Figure 1, our SRS infrastructure consists of two identically provisioned and configured datacenters with each served by multiple bandwidth providers. 

For clarity in Figure 1, connecting lines through the load balancing devices between the Protocol Layer and the Services Layer are omitted. All hardware connecting to the Services Layer goes through a load-balancing device. This device distributes the load across the multiple machines providing the services. This detail is illustrated more clearly in subsequent diagrams in Attachment A.

13.0 RESOURCING PLAN

Resources for the continued development and maintenance of the SRS and ancillary services have been carefully considered. We have a significant portion of the required personnel on hand and plan to hire additional technical resources, as indicated below. Resources on hand are existing full time employees whose primary responsibility is the SRS. 

For descriptions of the following teams, please refer to the resourcing section of our response to Question 31, Technical Review of Proposed Registry. Current and planned allocations are below.

Software Engineering: 

- Existing Department Personnel: Project Manager, Development Manager, two Sr. Software Engineers, two, Sr. Database Engineer, Quality Assurance Engineer
- First Year New Hires: Web Developer, Database Engineer, Technical Writer, Build⁄Deployment Engineer

Systems Engineering: 

- Existing Department Personnel: Sr. Director IT Operations, two Sr. Systems Administrators, two Systems Administrators, two Sr. Systems Engineers, two Systems Engineers
- First Year New Hires: Systems Engineer

Network Engineering: 

- Existing Department Personnel: Sr. Director IT Operations, two Sr. Network Engineers, two Network Engineers
- First Year New Hires: Network Engineer

Database Operations: 

- Existing Department Personnel: Sr. Database Operations Manager, 2 Database Administrators

Information Security Team: 

- Existing Department Personnel: Director of Information Security, Sr. Information Security Specialist, Information Security Specialists, Sr. Information Security Engineer, Information Security Engineer
- First Year New Hires: Information Security Engineer

Network Operations Center (NOC): 

- Existing Department Personnel: Manager, two NOC Supervisors, 12 NOC Analysts
- First Year New Hires: Eight NOC Analysts

Q25 CHAR: 20820

TLD Applicant is applying to become an ICANN accredited Top Level Domain (TLD) registry. TLD Applicant meets the operational, technical, and financial capability requirements to pursue, secure and operate the TLD registry. The responses to technical capability questions were prepared to demonstrate, with confidence, that the technical capabilities of TLD Applicant meet and substantially exceed the requirements proposed by ICANN.

1.0. INTRODUCTION

Our SRS EPP interface is a proprietary network service compliant with RFC 3735 and RFCs 5730-4. The EPP interface gives registrars a standardized programmatic access point to provision and manage domain name registrations. 

2.0. IMPLEMENTATION EXPERIENCE

The SRS implementation for our gTLD leverages extensive experience implementing long-running, highly available network services accessible. Our EPP interface was written by highly experienced engineers focused on meeting strict requirements developed to ensure quality of service and uptime. The development staff has extensive experience in the domain name industry. 

3.0. TRANSPORT

The EPP core specification for transport does not specify that a specific transport method be used and is, thus, flexible enough for use over a variety of transport methods. However, EPP is most commonly used over TCP⁄IP and secured with a Transport Layer Security (TLS) layer for domain registration purposes. Our EPP interface uses the industry standard TCP with TLS.

4.0. REGISTRARS’ EXPERIENCE

Registrars will find our EPP interface familiar and seamless. As part of the account creation process, a registrar provides us with information we use to authenticate them. The registrar provides us with two subnets indicating the connection’s origination. In addition, the registrar provides us with the Common Name specified in the certificate used to identify and validate the connection. 

Also, as part of the account creation process, we provide the registrar with authentication credentials. These credentials consist of a client identifier and an initial password and are provided in an out-of-band, secure manner. These credentials are used to authenticate the registrar when starting an EPP session. 

Prior to getting access to the production interfaces, registrars have access to an Operational Test and Evaluation (OT&E) environment. This environment is an isolated area that allows registrars to develop and test against registry systems without any impact to production. The OT&E environment also provides registrars the opportunity to test implementation of custom extensions we may require.

Once a registrar has completed testing and is prepared to go live, the registrar is provided a Scripted Server Environment. This environment contains an EPP interface and database pre-populated with known data. To verify that the registrar’s implementations are correct and minimally suitable for the production environment, the registrar is required to run through a series of exercises. Only after successful performance of these exercises is a registrar allowed access to production services.

5.0. SESSIONS

The only connections that are allowed are those from subnets previously communicated during account set up. The registrar originates the connection to the SRS and must do so securely using a Transport Layer Security (TLS) encrypted channel over TCP⁄IP using the IANA assigned standard port of 700. 

The TLS protocol establishes an encrypted channel and confirms the identity of each machine to its counterpart. During TLS negotiation, certificates are exchanged to mutually verify identities. Because mutual authentication is required, the registrar certificate must be sent during the negotiation. If it is not sent, the connection is terminated and the event logged.

The SRS first examines the Common Name (CN). The SRS then compares the Common Name to the one provided by the registrar during account set up. The SRS then validates the certificate by following the signature chain, ensures that the chain is complete, and terminates against our store of root Certificate Authorities (CA). The SRS also verifies the revocation status with the root CA. If these fail, the connection is terminated and the event logged.

Upon successful completion of the TLS handshake and the subsequent client validation, the SRS automatically sends the EPP greeting. Then the registrar initiates a new session by sending the login command with their authentication credentials. The SRS passes the credentials to the database for validation over an encrypted channel. Policy limits the number of failed login attempts. If the registrar exceeds the maximum number of attempts, the connection to the server is closed. If authentication was successful, the EPP session is allowed to proceed and a response is returned indicating that the command was successful.

An established session can only be maintained for a finite period. EPP server policy specifies the timeout and maximum lifetime of a connection. The policy requires the registrar to send a protocol command within a given timeout period. The maximum lifetime policy for our registry restricts the connection to a finite overall timespan. If a command is not received within the timeout period or the connection lifetime is exceeded, the connection is terminated and must be reestablished. Connection lifecycle details are explained in detail in our Registrar Manual.

The EPP interface allows pipelining of commands. For consistency, however, the server only processes one command at a time per session and does not examine the next command until a response to the previous command is sent. It is the registrar’s responsibility to track both the commands and their responses.

6.0. EPP SERVICE SCALE

Our EPP service is horizontally scalable. Its design allows us to add commodity-grade hardware at any time to increase our capacity. The design employs a 3-tier architecture which consists of protocol, services and data tiers. Servers for the protocol tier handle the loads of SSL negotiation and protocol validation and parsing. These loads are distributed across a farm of numerous servers balanced by load-balancing devices. The protocol tier connects to the services tier through load-balancing devices.

The services tier consists of a farm of servers divided logically based on the services provided. Each service category has two or more servers. The services tier is responsible for registry policy enforcement, registration lifecycle and provisioning, among other services. The services tier connects to the data tier which consists of Microsoft SQL Server databases for storage.

The data tier is a robust SQL Server installation that consists of a 2-node cluster in an active⁄active configuration. Each node is designed to handle the entire load of the registry should the alternate node go offline.

Additional details on scale and our plans to service the load we anticipate are described in detail on questions 24: SRS Performance and 32: Architecture.

7.0. COMPLIANCE WITH CORE AND EPP EXTENSION RFCs

The EPP interface is highly compliant with the following RFCs:

- RFC 5730 Extensible Provisioning Protocol
- RFC 5731 EPP Domain Name Mapping
- RFC 5732 EPP Host Mapping
- RFC 5733 EPP Contact Mapping
- RFC 5734 EPP Transport over TCP
- RFC 3915 Domain Registry Grace Period Mapping
- RFC 5910 Domain Name System (DNS) Security Extensions Mapping

The implementation is fully compliant with all points in each RFC. Where an RFC specifies optional details or service policy, they are explained below.

7.1. RFC 5730 EXTENSIBLE PROVISIONING PROTOCOL

Section 2.1 Transport Mapping Considerations - ack.
Transmission Control Protocol (TCP) in compliance with RFC 5734 with TLS.

Section 2.4 Greeting Format – compliant
The SRS implementation responds to a successful connection and subsequent TLS handshake with the EPP Greeting. The EPP Greeting is also transmitted in response to a 〈hello⁄〉 command. The server includes the EPP versions supported which at this time is only 1.0. The Greeting contains namespace URIs as 〈objURI⁄〉 elements representing the objects the server manages. 

The Greeting contains a 〈svcExtension〉 element with one 〈extURI〉 element for each extension namespace URI implemented by the SRS.

Section 2.7 Extension Framework – compliant
Each mapping and extension, if offered, will comply with RFC 3735 Guidelines for Extending EPP.

Section 2.9 Protocol Commands – compliant

Login command’s optional 〈options〉 element is currently ignored. The 〈version〉 is verified and 1.0 is currently the only acceptable response. The 〈lang〉 element is also ignored because we currently only support English (en). This server policy is reflected in the greeting.

The client mentions 〈objURI〉 elements that contain namespace URIs representing objects to be managed during the session inside 〈svcs〉 element of Login request. Requests with unknown 〈objURI〉 values are rejected with error information in the response. A 〈logout〉 command ends the client session. 

Section 4 Formal syntax - compliant
All commands and responses are validated against applicable XML schema before acting on the command or sending the response to the client respectively. XML schema validation is performed against base schema (epp-1.0), common elements schema (eppcom-1.0) and object-specific schema.

Section 5 Internationalization Considerations - compliant
EPP XML recognizes both UTF-8 and UTF-16. All date-time values are presented in Universal Coordinated Time using Gregorian calendar.

7.2. RFC 5731 EPP DOMAIN NAME MAPPING

Section 2.1 Domain and Host names – compliant
The domain and host names are validated to meet conformance requirements mentioned in RFC 0952, 1123 and 3490. 

Section 2.2 Contact and Client Identifiers – compliant
All EPP contacts are identified by a server-unique identifier. Contact identifiers conform to “clIDType” syntax described in RFC 5730.

Section 2.3 Status Values – compliant
A domain object always has at least one associated status value. Status value can only be set by the sponsoring client or the registry server where it resides. Status values set by server cannot be altered by client. Certain combinations of statuses are not permitted as described by RFC.

Section 2.4 Dates and Times – compliant
Date and time attribute values are represented in Universal Coordinated Time (UTC) using Gregorian calendar, in conformance with XML schema.

Section 2.5 Validity Periods – compliant
Our SRS implementation supports validity periods in unit year (“y”). The default period is 1y.

Section 3.1.1 EPP 〈check〉 Command – compliant
A maximum of 5 domains can be checked in a single command request as defined by server policy.

Section 3.1.2 EPP 〈info〉 Command – compliant
EPP 〈info〉 command is used to retrieve information associated with a domain object. If the querying Registrar is not the sponsoring registrar and the registrar does not provide valid authorization information, the server does not send any domain elements in response per server policy.

Section 3.1.3 EPP 〈transfer〉 Query Command – compliant
EPP 〈transfer〉 command provides a query operation that allows a client to determine the real-time status of pending and completed transfer requests. If the authInfo element is not provided or authorization information is invalid, the command is rejected for authorization.

Section 3.2.4 EPP 〈transfer〉 Command – compliant
All subordinate host objects to the domain are transferred along with the domain object.

7.3. RFC 5732 EPP HOST MAPPING

Section 2.1 Host Names – compliant
The host names are validated to meet conformance requirements mentioned in RFC 0952, 1123 and 3490. 

Section 2.2 Contact and Client Identifiers – compliant
All EPP clients are identified by a server-unique identifier. Client identifiers conform to “clIDType” syntax described in RFC 5730.

Section 2.5 IP Addresses – compliant
The syntax for IPv4 addresses conform to RFC0791. The syntax for IPv6 addresses conform to RFC4291.

Section 3.1.1 EPP 〈check〉 Command – compliant
Maximum of five host names can be checked in a single command request set by server policy.

Section 3.1.2 EPP 〈info〉 Command – compliant
If the querying client is not a sponsoring client, the server does not send any host object elements in response and the request is rejected for authorization according to server policy.

Section 3.2.2 EPP 〈delete〉 Command – compliant
A delete is permitted only if the host is not delegated.

Section 3.2.2 EPP 〈update〉 Command – compliant
Any request to change host name of an external host that has associations with objects that are sponsored by a different client fails.

7.4. RFC 5733 EPP CONTACT MAPPING

Section 2.1 Contact and Client Identifiers – compliant
Contact identifiers conform to “clIDType” syntax described in RFC 5730.

Section 2.6 Email Addresses – compliant
Email address validation conforms to syntax defined in RFC5322.

Section 3.1.1 EPP 〈check〉 Command – compliant
Maximum of 5 contact id can be checked in a single command request.

Section 3.1.2 EPP 〈info〉 Command – compliant
If querying client is not sponsoring client, server does not send any contact object elements in response and the request is rejected for authorization.

Section 3.2.2 EPP 〈delete〉 Command – compliant
A delete is permitted only if the contact object is not associated with other known objects.

7.5. RFC 5734 EPP TRANSPORT OVER TCP

Section 2 Session Management – compliant
The SRS implementation conforms to the required flow mentioned in the RFC for initiation of a connection request by a client, to establish a TCP connection. The client has the ability to end the session by issuing an EPP 〈logout〉 command, which ends the session and closes the TCP connection. Maximum life span of an established TCP connection is defined by server policy. Any connections remaining open beyond that are terminated. Any sessions staying inactive beyond the timeout policy of the server are also terminated similarly. Policies regarding timeout and lifetime values are clearly communicated to registrars in documentation provided to them.

Section 3 Message Exchange – compliant
With the exception of EPP server greeting, EPP messages are initiated by EPP client in the form of EPP commands. Client-server interaction works as a command-response exchange where the client sends one command to the server and the server returns one response to the client in the exact order as received by the server.

Section 8 Security considerations – ack.
TLS 1.0 over TCP is used to establish secure communications from IP restricted clients. Validation of authentication credentials along with the certificate common name, validation of revocation status and the validation of the full certificate chain are performed. The ACL only allows connections from subnets prearranged with the Registrar.

Section 9 TLS Usage Profile – ack.
The SRS uses TLS 1.0 over TCP and matches the certificate common name. The full certificate chain, revocation status and expiry date is validated. TLS is implemented for mutual client and server authentication. 

8.0. EPP EXTENSIONS

8.1. STANDARDIZED EXTENSIONS

Our implementation includes extensions that are accepted standards and fully documented. These include the Registry Grace Period Mapping and DNSSEC.

8.2. COMPLIANCE WITH RFC 3735

RFC 3735 are the Guidelines for Extending the Extensible Provisioning Protocol. Any custom extension implementations follow the guidance and recommendations given in RFC 3735.

8.3. COMPLIANCE WITH DOMAIN REGISTRY GRACE PERIOD MAPPING RFC 3915

Section 1 Introduction – compliant
Our SRS implementation supports all specified grace periods particularly, add grace period, auto-renew grace period, renew grace period, and transfer grace period.

Section 3.2 Registration Data and Supporting Information – compliant
Our SRS implementation supports free text and XML markup in the restore report.

Section 3.4 Client Statements – compliant
Client can use free text or XML markup to make 2 statements regarding data included in a restore report.

Section 5 Formal syntax - compliant
All commands and responses for this extension are validated against applicable XML schema before acting on the command or sending the response to the client respectively. XML schema validation is performed against RGP specific schema (rgp-1.0).

8.4. COMPLIANCE WITH DOMAIN NAME SYSTEM (DNS) SECURITY EXTENSIONS MAPPING RFC 5910

RFC 5910 describes an Extensible Provisioning Protocol (EPP) extension mapping for the provisioning and management of Domain Name System Security Extensions (DNSSEC) for domain names stored in a shared central repository. Our SRS and DNS implementation supports DNSSEC. 

The information exchanged via this mapping is extracted from the repository and used to publish DNSSEC Delegate Signer (DS) resource records (RR) as described in RFC 4034.

Section 4 DS Data Interface and Key Data Interface – compliant
Our SRS implementation supports only DS Data Interface across all commands applicable with DNSSEC extension.

Section 4.1 DS Data Interface – compliant
The client can provide key data associated with the DS information. The collected key data along with DS data is returned in an info response, but may not be used in our systems.

Section 4.2 Key Data Interface – compliant
Since our gTLD’s SRS implementation does not support Key Data Interface, when a client sends a command with Key Data Interface elements, it is rejected with error code 2306.

Section 5.1.2 EPP 〈info〉 Command – compliant
This extension does not add any elements to the EPP 〈info〉 command. When an 〈info〉 command is processed successfully, the EPP 〈resData〉 contains child elements for EPP domain mapping. In addition, it contains a child 〈secDNS:infData〉 element that identifies extension namespace if the domain object has data associated with this extension. It is conditionally based on whether or the client added the 〈extURI〉 element for this extension in the 〈login〉 command. Multiple DS data elements are supported.

Section 5.2.1 EPP 〈create〉 Command – compliant
The client must add an 〈extension〉 element, and the extension element MUST contain a child 〈secDNS:create〉 element if the client wants to associate data defined in this extension to the domain object. Multiple DS data elements are supported. Since the SRS implementation does not support maxSigLife, it returns a 2102 error code if the command included a value for maxSigLife.

Section 5.2.5 EPP 〈update〉 Command – compliant
Since the SRS implementation does not support the 〈secDNS:update〉 element’s optional “urgent” attribute, an EPP error result code of 2102 is returned if the “urgent” attribute is specified in the command with value of Boolean true.

8.5. PROPRIETARY EXTENSION DOCUMENTATION

We are not proposing any proprietary EPP extensions for this TLD.

8.6. EPP CONSISTENT WITH THE REGISTRATION LIFECYCLE DESCRIBED IN QUESTION 27

Our EPP implementation makes no changes to the industry standard registration lifecycle and is consistent with the lifecycle described in Question 27.

9.0. RESOURCING PLAN

For descriptions of the following teams, please refer to our response to Question 31. Current and planned allocations are below.

Software Engineering: 

- Existing Department Personnel: Project Manager, Development Manager, 2 Sr. Software Engineers, Sr. Database Engineer, Quality Assurance Engineer
- First Year New Hires: Web Developer, Database Engineer, Technical Writer, Build⁄Deployment Engineer

Systems Engineering: 

- Existing Department Personnel: Sr. Director IT Operations, two Sr. Systems Administrators, two Systems Administrators, two Sr. Systems Engineers, two Systems Engineers
- First Year New Hires: Systems Engineer

Network Engineering: 

- Existing Department Personnel: Sr. Director IT Operations, two Sr. Network Engineers, two Network Engineers
- First Year New Hires: Network Engineer

Database Operations: 

- Existing Department Personnel: Sr. Database Operations Manager, two Database Administrators

Information Security Team: 

- Existing Department Personnel: Director of Information Security, Sr. Information Security Specialist, Information Security Specialists, Sr. Information Security Engineer, Information Security Engineer
- First Year New Hires: Information Security Engineer

Network Operations Center (NOC): 

- Existing Department Personnel: Manager, two NOC Supervisors, 12 NOC Analysts
- First Year New Hires: Eight NOC Analysts

Q26 CHAR: 19908

1.0. INTRODUCTION

Our registry provides a publicly available Whois service for registered domain names in the top-level domain (TLD). Our planned registry also offers a searchable Whois service that includes web-based search capabilities by domain name, registrant name, postal address, contact name, registrar ID and IP addresses without an arbitrary limit. The Whois service for our gTLD also offers Boolean search capabilities, and we have initiated appropriate precautions to avoid abuse of the service. This searchable Whois service exceeds requirements and is eligible for a score of 2 by providing the following:

- Web-based search capabilities by domain name, registrant name, postal address, contact names, registrar IDs, and Internet Protocol addresses without arbitrary limit. 
- Boolean search capabilities. 
- Appropriate precautions to avoid abuse of this feature (e.g., limiting access to legitimate authorized users).
- Compliance with any applicable privacy laws or policies.

The Whois service for our planned TLD is available via port 43 in accordance with RFC 3912. Also, our planned registry includes a Whois web interface. Both provide free public query-based access to the elements outlined in Specification 4 of the Registry Agreement. In addition, our registry includes a searchable Whois service. This service is available to authorized entities and accessible from a web browser.

2.0. HIGH-LEVEL WHOIS SYSTEM DESCRIPTION

The Whois service for our registry provides domain registration information to the public. This information consists not only of the domain name but also of relevant contact information associated with the domain. It also identifies nameserver delegation and the registrar of record. This service is available to any Internet user, and use does not require prior authorization or permission. To maximize accessibility to the data, Whois service is provided over two mediums, as described below. Where the medium is not specified, any reference to Whois pertains to both mediums. We describe our searchable Whois solution in Section 11.0.

One medium used for our gTLD’s Whois service is port 43 Whois. This consists of a standard Transmission Control Protocol (TCP) server that answers requests for information over port 43 in compliance with IETF RFC 3912. For each query, the TCP server accepts the connection over port 43 and then waits for a set time for the query to be sent. This communication occurs via clear, unencrypted text. If no query is received by the server within the allotted time or a malformed query is detected, the connection is closed. If a properly formatted and valid query is received, the registry database is queried for the registration data. If registration data exists, it is returned to the service where it is then formatted and delivered to the requesting client. Each query connection is short-lived. Once the output is transmitted, the server closes the connection.

The other medium used for Whois is via web interface using clear, unencrypted text. The web interface is in an HTML format suitable for web browsers. This interface is also available over an encrypted channel on port 443 using the HTTPS protocol.

The steps for accessing the web-based Whois will be prominently displayed on the registry home page. The web-based Whois is for interactive use by individual users while the port 43 Whois system is for automated use by computers and lookup clients.

Both Whois service offerings comply with Specification 4 of the New GTLD Agreement. Although the Whois output is free text, it follows the output format as described for domain, registrar and nameserver data in Sections 1.4, 1.5 and 1.6 of Specification 4 of the Registry Agreement.

Our gTLD’s WHOIS service is mature, and its current implementation has been in continuous operation for seven years. A dedicated support staff monitors this service 24⁄7. To ensure high availability, multiple redundant servers are maintained to enable capacity well above normal query rates.

Most of the queries sent to the port 43 Whois service are automated. The Whois service contains mechanisms for detecting abusive activity and, if abuse is detected, reacts appropriately. This capability contributes to a high quality of service and availability for all users.

2.1. PII POLICY

The services and systems for this gTLD do not collect, process or store any personally identifiable information (PII) as defined by state disclosure and privacy laws. Registry systems collect the following Whois data types: first name, last name, address and phone numbers of all billing, administration and technical contacts. Any business conducted where confidential PII consisting of customer payment information is collected uses systems that are completely separate from registry systems and segregated at the network layer. 

3.0. RELEVANT NETWORK DIAGRAM(S)

Our network diagram (Q 26 - Attachment A, Figure 1) provides a quick-reference view of the Whois system. This diagram reflects the Whois system components and compliance descriptions and explanations that follow in this section.

3.1. NARRATIVE FOR Q26 - FIGURE 1 OF 1 (SHOWN IN ATTACHMENT A)

The Whois service for our gTLD operates from two datacenters from replicated data. Network traffic is directed to either of the datacenters through a global load balancer. Traffic is directed to an appropriate server farm, depending on the service interface requested. The load balancer within the datacenter monitors the load and health of each individual server and uses this information to select an appropriate server to handle the request.

The protocol server handling the request communicates over an encrypted channel with the Whois service provider through a load-balancing device. The WHOIS service provider communicates directly with a replicated, read-only copy of the appropriate data from the registry database. The Whois service provider is passed a sanitized and verified query, such as a domain name. The database attempts to locate the appropriate records, then format and return them. Final output formatting is performed by the requesting server and the results are returned back to the original client.

4.0. INTERCONNECTIVITY WITH OTHER REGISTRY SYSTEMS

The Whois port 43 interface runs as an unattended service on servers dedicated to this task. As shown in Attachment A, Figure 1, these servers are delivered network traffic by redundant load-balancing hardware, all of which is protected by access control methods. Balancing the load across many servers helps distribute the load and allows for expansion. The system’s design allows for the rapid addition of new servers, typically same-day, should load require them.

Both our port 43 Whois and our web-based Whois communicate with the Whois service provider in the middle tier. Communication to the Whois service provider is distributed by a load balancing pair. The Whois service provider calls the appropriate procedures in the database to search for the registration records. 

The Whois service infrastructure operates from both datacenters, and the global load balancer distributes Whois traffic evenly across the two datacenters. If one datacenter is not responding, the service sends all traffic to the remaining datacenter. Each datacenter has sufficient capacity to handle the entire load.

To avoid placing an abnormal load on the Shared Registration System (SRS), both service installations read from replicated, read-only database instances (see Figure 1). Because each instance is maintained via replication from the primary SRS database, each replicated database contains a copy of the authoritative data. Having the Whois service receive data from this replicated database minimizes the impact of services competing for the same data and enables service redundancy. Data replication is also monitored to prevent detrimental impact on the primary SRS.

5.0. FREQUENCY OF SYNCHRONIZATION BETWEEN SERVERS

As shown in Figure 1, the system replicates WHOIS services data continuously from the authoritative database to the replicated database. This persistent connection is maintained between the databases, and each transaction is queued and published as an atomic unit. Delays, if any, in the replication of registration information are minimal, even during periods of high load. At no time will the system prioritize replication over normal operations of the SRS.

6.0. POTENTIAL FORMS OF ABUSE

Potential forms of abuse of this feature, and how they are mitigated, are outlined below. For additional information on our approach to preventing and mitigating Whois service abuse, please refer to our response to Question 28.

6.1. DATA MINING ABUSE

This type of abuse consists primarily of a user using queries to acquire all or a significant portion of the registration database. 

The system mitigates this type of abuse by detecting and limiting bulk query access from single sources. It does this in two ways: 1) by rate-limiting queries by non-authorized parties; and 2) by ensuring all queries result in responses that do not include data sets representing significant portions of the registration database.

6.2. INVALID DATA INJECTION

This type of abuse is mitigated by 1) ensuring that all Whois systems are strictly read-only; and 2) ensuring that any input queries are properly sanitized to prevent data injection.

6.3. DISCLOSURE OF PRIVATE INFORMATION

The Whois system mitigates this type of abuse by ensuring all responses, while complete, only contain information appropriate to Whois output and do not contain any private or non-public information. 

7.0. COMPLIANCE WITH WHOIS SPECIFICATIONS FOR DATA OBJECTS, BULK ACCESS, AND LOOKUPS

Whois specifications for data objects, bulk access, and lookups for our gTLD are fully compliant with Specifications 4 and 10 to the Registry Agreement, as explained below.

7.1. COMPLIANCE WITH SPECIFICATION 4 

Compliance of Whois specifications with Specification 4 is as follows:

- Registration Data Directory Services Component: Specification 4.1 is implemented as described. Formats follow the outlined semi-free text format. Each data object is represented as a set of key⁄value pairs with lines beginning with keys followed by a colon and a space as delimiters, followed by the value. Fields relevant to RFCs 5730-4 are formatted per Section 1.7 of Specification 4.
- Searchability compliance is achieved by implementing, at a minimum, the specifications in section 1.8 of specification 4. We describe this searchability feature in Section 11.0.
- Co-operation, ICANN Access and Emergency Operator Access: Compliance with these specification components is assured.
- Bulk Registration Data Access to ICANN: Compliance with this specification component is assured.

Evidence of Whois system compliance with this specification consists of:

- Matching existing Whois output with specification output to verify that it is equivalent.

7.2. COMPLIANCE WITH SPECIFICATION 10 FOR WHOIS

Our gTLD’s Whois complies fully with Specification 10. With respect to Section 4.2, the approach used ensures that Round-Trip Time (RTT) remains below five times the corresponding Service Level Requirement (SLR).

7.2.1. Emergency Thresholds

To achieve compliance with this Specification 10 component, several measures are used to ensure emergency thresholds are never reached:

1) Provide staff training as necessary on Registry Transition plan components that prevent Whois service interruption in case of emergency (see the Question 40 response for details).
2) Conduct regular failover testing for Whois services as outlined in the Question 41 response.
3) Adhere to recovery objectives for Whois as outlined in the Question 39 response. 
 
7.2.2. Emergency Escalation

Compliance with this specification component is achieved by participation in escalation procedures as outlined in this section.

8.0. COMPLIANCE WITH RFC 3912

Whois service for our gTLD is fully compliant with RFC 3912 as follows:

- RFC 3912 Element, “A Whois server listens on TCP port 43 for requests from Whois clients”: This requirement is properly implemented, as described in Section 1 above. Further, running Whois on ports other than port 43 is an option.
- RFC 3912 Element, “The Whois client makes a text request to the Whois server, then the Whois server replies with text content”: The port 43 Whois service is a text-based query and response system. Thus, this requirement is also properly implemented.
- RFC 3912 Element, “All requests are terminated with ASCII CR and then ASCII LF. The response might contain more than one line of text, so the presence of ASCII CR or ASCII LF characters does not indicate the end of the response”: This requirement is properly implemented for our TLD.
- RFC 3912 Element, “The Whois server closes its connection as soon as the output is finished”: This requirement is properly implemented for our TLD, as described in Section 1 above.
- RFC 3912 Element, “The closed TCP connection is the indication to the client that the response has been received”: This requirement is properly implemented.

9.0. RESOURCING PLAN

Resources for the continued development and maintenance of the Whois have been carefully considered. Many of the required personnel are already in place. Where gaps exist, technical resource addition plans are outlined below as “First Year New Hires.” Resources now in place, shown as “Existing Department Personnel”, are employees whose primary responsibility is the registry system. 

Software Engineering: 

- Existing Department Personnel: Project Manager, Development Manager, two Sr. Software Engineers, Sr. Database Engineer, Quality Assurance Engineer
- First Year New Hires: Web Developer, Database Engineer, Technical Writer, Build⁄Deployment Engineer

Systems Engineering: 

- Existing Department Personnel: Sr. Director IT Operations, two Sr. Systems Administrators, two Systems Administrators, two Sr. Systems Engineers, two Systems Engineers
- First Year New Hires: Systems Engineer

Network Engineering: 

- Existing Department Personnel: Sr. Director IT Operations, two Sr. Network Engineers, two Network Engineers
- First Year New Hires: Network Engineer

Database Operations: 

- Existing Department Personnel: Sr. Database Operations Manager, two Database Administrators

Information Security Team: 

- Existing Department Personnel: Director of Information Security, Sr. Information Security Specialist, Information Security Specialists, Sr. Information Security Engineer, Information Security Engineer
- First Year New Hires: Information Security Engineer

Network Operations Center (NOC): 

- Existing Department Personnel: Manager, two NOC Supervisors, 12 NOC Analysts
- First Year New Hires: Eight NOC Analysts

11.0. PROVISION FOR SEARCHABLE WHOIS CAPABILITIES

The searchable Whois service for our gTLD provides flexible and powerful search ability for users through a web-based interface. This service is provided only to entities with a demonstrated need for it. Where access to registration data is critical to the investigation of cybercrime and other potentially unlawful activity, we authorize access for fully vetted law enforcement and other entities as appropriate. Search capabilities for our gTLD’s searchable Whois meet or exceed the requirements indicated in section 1.8 of specification 4.

Once authorized to use the system, a user can perform exact and partial match searches on the following fields:

- Domain name
- Registrant name
- Postal address including street, city and state, etc., of all registration contacts
- Contact names
- Registrant email address
- Registrar name and ID
- Nameservers
- Internet Protocol addresses

In addition, all other EPP Contact Object fields and sub-fields are searchable as well. The following Boolean operators are also supported: AND, OR, NOT. These operators can be used for joining or excluding results.

Certain types of registry related abuse are unique to the searchable Whois function. Providing searchable Whois warrants providing protection against this abuse. Potential problems include:

- Attempts to abuse Whois by issuing a query that essentially returns the entire database in the result set. 
- Attempts to run large quantities of queries sufficient to reduce the performance of the registry database. 
 
Precautions for preventing and mitigating abuse of the Whois search service include:

- Limiting access to authorized users only.
- Establishing legal agreements with authorized users that clearly define and prohibit system abuse.
- Queuing search queries into a job processing system.
- Executing search queries against a replicated read-only copy of the database.
- Limiting result sets when the query is clearly meant to cause a wholesale dump of registration data.

Only authorized users with a legitimate purpose for searching registration data are permitted to use the searchable Whois system. Examples of legitimate purpose include the investigation of terrorism or cybercrime by authorized officials, or any of many other official activities that public officials must conduct to fulfill their respective duties. We grant access for these and other purposes on a case-by-case basis.

To ensure secure access, a two-factor authentication device is issued to each authorized user of the registry. Subsequent access to the system requires the user name, password and a one-time generated password from the issued two-factor device.

Upon account creation, users are provided with documentation describing our terms of service and policies for acceptable use. Users must agree to these terms to use the system. These terms clearly define and illustrate what constitutes legitimate use and what constitutes abuse. They also inform the user that abuse of the system is grounds for limiting or terminating the user’s account.

For all queries submitted, the searchable Whois system first sanitizes the query to deter potential harm to our internal systems. The system then submits the query to a queue for job processing. The system processes each query one by one and in the order received. The number of concurrent queries executed varies, depending on the current load.

To ensure Whois search capabilities do not affect other registry systems, the system executes queries against a replicated read-only version of the database. The system updates this database frequently as registration transactions occur. These updates are performed in a manner that ensures no detrimental load is placed on the production SRS.

To process successfully, each query must contain the criteria needed to filter its results down to a reasonable result set (one that is not excessively large). If the query does not meet this, the user is notified that the result set is excessive and is asked to verify the search criteria. If the user wishes to continue without making the indicated changes, the user must contact our support team to verify and approve the query. Each successful query submitted results in immediate execution of the query.

Query results are encrypted using the unique shared secret built into each 256-bit Advanced Encryption Standard (AES) two-factor device. The results are written to a secure location dedicated for result storage and retrieval. Each result report has a unique file name in the user’s directory. The user’s directory is assigned the permissions needed to prevent unauthorized access to report files. For the convenience of Registrars and other users, each query result is stored for a minimum of 30 days. At any point following this 30-day period, the query result may be purged by the system.

Q27 CHAR: 19951

1.0. INTRODUCTION
To say that the lifecycle of a domain name is complex would be an understatement. A domain name can traverse many states throughout its lifetime and there are many and varied triggers that can cause a state transition. Some states are triggered simply by the passage of time. Others are triggered by an explicit action taken by the registrant or registrar. Understanding these is critical to the proper operation of a gTLD registry. To complicate matters further, a domain name can contain one or more statuses. These are set by the registrar or registry and have a variety of uses.

When this text discusses EPP commands received from registrars, with the exception of a transfer request, the reader can assume that the command is received from the sponsoring registrar and successfully processed. The transfer request originates from the potential gaining registrar. Transfer details are explicit for clarity.

2.0. INDUSTRY STANDARDS
The registration life cycle approach for our gTLD follows industry standards for registration lifecycles and registration statuses. By implementing a registration life cycle that adheres to these standards, we avoid compounding an already confusing topic for registrants. In addition, since registrar systems are already designed to manage domain names in a standard way, a standardized registration lifecycle also lowers the barrier to entry for registrars.

The registration lifecycle for our gTLD follows core EPP RFCs including RFC 5730 and RFC 5731 and associated documentation of lifecycle information. To protect registrants, EPP Grace Period Mapping for domain registrations is implemented, which affects the registration lifecycle and domain status. EPP Grace Period Mapping is documented in RFC 3915.

3.0. REGISTRATION STATES
For a visual guide to this registration lifecycle discussion, please refer to the attachment, Registration Lifecycle Illustrations. Please note that this text makes many references to the status of a domain. For brevity, we do not distinguish between the domain mapping status 〈domain:status〉 and the EPP Grace Period Mapping status 〈rgp:rgpStatus〉 as making this differentiation in every case would make this document more difficult to read and in this context does not improve understanding.

4.0. AVAILABILITY
The lifecycle for any domain registration begins with the Available state. This is not necessarily a registration state, per se, but indicates the lack of domain registration implied and provides an entry and terminal point for the state diagram provided. In addition to the state diagram, please refer to Fig. 2 – Availability Check for visual representation of the process flow.

Before a user can register a new domain name, the registry performs an availability check. Possible outcomes of this availability check include:
1. Domain name is available for registration.
2. Domain name is already registered, regardless of the current state and not available for registration.
3. Domain name has been reserved by the registry.
4. Domain name string has been blocked because of a trademark claim.

5.0. INITIAL REGISTRATION
The first step in domain registration is the availability check as described above and shown in Fig. 2 – Availability Check. A visual guide to the description for domain registration in this section can be found in Fig. 3 – Domain Registration. If the domain is available for registration, a registrar submits a registration request. 

With this request, the registrar can include zero or more nameserver hosts for zone delegation. If the registrar includes zero or one nameserver host(s), the domain is registered but the EPP status of the domain is set to inactive. If the registrar includes two or more, the EPP status of the domain is set to ok.

The request may also include a registration period (the number of years the registrar would like the domain registered). If this time period is omitted, the registry may use a default initial registration period. The policy for this aligns with the industry standard of one year as the default period. If the registrar includes a registration period, the value must be between one and ten years as specified in the gTLD Registry Agreement.

Once the registration process is complete within the registry, the domain registration is considered to be in the REGISTERED state but within the Add Grace Period.


6.0. REGISTERED STATE - ADD GRACE PERIOD
The Add Grace Period is a status given to a new domain registration. The EPP status applied in this state is addPeriod. The Add Grace Period is a state in which the registrar is eligible for a refund of the registration price should the registration be deleted while this status is applied. The status is removed and the registration transitions from the Add Grace Period either by an explicit delete request from the registrar or by the lapse of five days. This is illustrated in Fig. 1 and Fig. 3 of the illustrations attachment. 

If the registrar deletes the domain during the Add Grace Period, the domain becomes immediately available for registration. The registrar is refunded the original cost of the registration.

If the five-day period lapses without receiving a successful delete command, the addPeriod status is removed from the domain.


7.0. REGISTERED STATE
A domain registration spends most of its time in the REGISTERED state. A domain registration period can initially be between one year and ten years in one-year increments as specified in the new gTLD Registry Agreement. At any time during the registration’s term, several things can occur to either affect the registration period or transition the registration to another state. The first three are the auto-renew process, an explicit renew EPP request and a successful completion of the transfer process.

8.0. REGISTRATION PERIOD EXTENSION
The registration period for a domain is extended either through a successful renew request by the registrar, through the successful completion of the transfer process or through the auto-renew process. This section discusses each of these three options.

8.1. EXTENSION VIA RENEW REQUEST
One way that a registrar can extend the registration period is by issuing a renew request. Each renew request includes the number of years desired for extension of the registration up to ten years. Please refer to the flow charts found in both Fig. 4 – Renewal and Fig. 5 – Renewal Grace Period for a visual representation of the following. 

Because the registration period cannot extend beyond ten years, any request for a registration period beyond ten years fails. The domain must not contain the status renewProhibited. If this status exists on the domain, the request for a renewal fails. 

Upon a successful renew request, the registry adds the renewPeriod status to the domain. This status remains on the domain for a period of five days. The number of years in the renew request is added to the total registration period of the domain. The registrar is charged for each year of the additional period.

While the domain has the renewPeriod status, if the sponsoring registrar issues a successful delete request, the registrar receives a credit for the renewal. The renewPeriod status is removed and the domain enters the Redemption Grace Period (RGP) state. The status redemptionPeriod is added to the status of the domain. 

8.2. EXTENSION VIA TRANSFER PROCESS
The second way to extend the registration is through the Request Transfer process. A registrar may transfer sponsorship of a domain name to another registrar. The exact details of a transfer are explained in the Request Transfer section below. The successful completion of the Request Transfer process automatically extends the registration for one year. The registrar is not charged separately for the addition of the year; it comes automatically with the successful transfer. The transferPeriod status is added to the domain. 

If the gaining registrar issues a successful delete request during the transferPeriod, the gaining registrar receives a credit for the transfer. The status redemptionPeriod is added to the status of the domain and transferPeriod is removed. The domain then enters the RGP state.


8.3. EXTENSION VIA AUTO-RENEW 
The last way a registration period can be extended is passive and is the simplest way because it occurs without any action by the Registrar. When the registration period expires, for the convenience of the registrar and registrant, the registration renews automatically for one year. The registrar is charged for the renewal at this time. This begins the Auto Renew Grace Period. The autoRenewPeriod status is added to the domain to represent this period. 

The Auto Renew Grace Period lasts for 45 days. At any time during this period, the Registrar can do one of four things: 1) passively accept the renewal; 2) actively renew (to adjust renewal options); 3) delete the registration; or 4) transfer the registration. 

To passively accept the renewal, the registrar need only allow the 45-day time span to pass for the registration to move out of the Auto Renew Grace Period.

Should the registrar wish to adjust the renewal period in any way, the registrar can submit a renew request via EPP to extend the registration period up to a maximum of ten years. If the renew request is for a single year, the registrar is not charged. If the renew request is for more than a single year, the registrar is charged for the additional years that the registration period was extended. If the command is a success, the autoRenewPeriod status is removed from the domain.

Should the registrar wish to delete the registration, the registrar can submit a delete command via EPP. Once a delete request is received, the autoRenewPeriod status is removed from the domain and the redemptionPeriod status is added. The registrar is credited for the renewal fees. For illustration of this process, please refer to Fig. 6 – Auto Renew Grace Period.

The last way move a domain registration out of the Auto Renew state is by successful completion of the Request Transfer process, as described in the following section. If the transfer completes successfully, the autoRenewPeriod status is removed and the transferPeriod status is added.

9.0. REQUEST TRANSFER

A customer can change the sponsoring registrar of a domain registration through the Request Transfer process. This process is an asynchronous, multi-step process that can take many as five days but may occur faster, depending on the level of support from participating Registrars.

The initiation of the transfer process is illustrated in Fig. 8 – Request Transfer. The transfer process begins with a registrar submitting a transfer request. To succeed, the request must meet several criteria. First, the domain status must not contain transferProhibited or pendingTransfer. Second, the initial domain registration must be at least 60 days old or, if transferred prior to the current transfer request, must not have been transferred within the last 60 days. Lastly, the transfer request must contain the correct authInfo (authorization information) value. If all of these criteria are met, the transfer request succeeds and the domain moves into the Pending Transfer state and the pendingTransfer status is added to the domain.

There are four ways to complete the transfer (and move it out of Pending Transfer status):
1. The transfer is auto-approved.
2. The losing registrar approves the transfer.
3. The losing registrar rejects the transfer.
4. The requesting registrar cancels the transfer.

After a successful transfer request, the domain continues to have the pendingTransfer status for up to five days. During this time, if no other action is taken by either registrar, the domain successfully completes the transfer process and the requesting registrar becomes the new sponsor of the domain registration. This is illustrated in Fig. 9 – Auto Approve Transfer.

At any time during the Pending Transfer state, either the gaining or losing registrar can request the status of a transfer provided they have the correct domain authInfo. Querying for the status of a transfer is illustrated in Fig. 13 – Query Transfer.

During the five-day Pending Transfer state, the losing registrar can accelerate the process by explicitly accepting or rejecting the transfer. If the losing registrar takes either of these actions, the pendingTransfer status is removed. Both of these actions are illustrated in Fig. 10 – Approve Transfer and Fig. 11 – Reject Transfer.

During the five-day Pending Transfer state, the requesting registrar may cancel the transfer request. If the registrar sends a cancel transfer request, the pendingTransfer status is removed. This is shown in Fig. 12 – Cancel Transfer.

If the transfer process is a success, the registry adds the transferPeriod status and removes the pendingTransfer status. If the domain was in the Renew Period state, upon successful completion of the transfer process, this status is removed. 

The transferPeriod status remains on the domain for five days. This is illustrated in Fig. 14 – Transfer Grace Period. During this period, the gaining Registrar may delete the domain and obtain a credit for the transfer fees. If the gaining registrar issues a successful delete request during the transferPeriod, the gaining registrar receives a credit for the transfer. The status redemptionPeriod is added to the status of the domain and transferPeriod is removed. The domain then enters the RGP state. 


10.0. REDEMPTION GRACE PERIOD
The Redemption Grace Period (RGP) is a service provided by the registry for the benefit of registrars and registrants. The RGP allows a registrar to recover a deleted domain registration. The only way to enter the RGP is through a delete command sent by the sponsoring registrar. A domain in RGP always contains a status of redemptionPeriod. For an illustrated logical flow diagram of this, please refer to Fig. 15 – Redemption Grace Period.

The RGP lasts for 30 days. During this time, the sponsoring registrar may recover the domain through a two-step process. The first step is to send a successful restore command to the registry. The second step is to send a restore report to the registry.

Once the restore command is processed, the registry adds the domain status of pendingRestore to the domain. The domain is now in the Pending Restore state, which lasts for seven days. During this time, the registry waits for the restore report from the Registrar. If the restore report is not received within seven days, the domain transitions back to the RGP state. If the restore report is successfully processed by the registry, the domain registration is restored back to the REGISTERED state. The statuses of pendingRestore and redemptionPeriod are removed from the domain.

After 30 days in RGP, the domain transitions to the Pending Delete state. A status of pendingDelete is applied to the domain and all other statuses are removed. This state lasts for five days and is considered a quiet period for the domain. No commands or other activity can be applied for the domain while it is in this state. Once the five days lapse, the domain is again available for registration.

11.0. DELETE
To delete a domain registration, the sponsoring registrar must send a delete request to the registry. If the domain is in the Add Grace Period, deletion occurs immediately. In all other cases, the deleted domain transitions to the RGP. For a detailed visual diagram of the delete process flow, please refer to Fig. 7 – Delete.

For domain registration deletion to occur successfully, the registry must first ensure the domain is eligible for deletion by conducting two checks. The registry first checks to verify that the requesting registrar is also the sponsoring registrar. If this is not the case, the registrar receives an error message.

The registry then checks the various domain statuses for any restrictions that might prevent deletion. If the domain’s status includes either the transferPending or deleteProhibited, the name is not deleted and an error is returned to the registrar.

If the domain is in the Add Grace Period, the domain is immediately deleted and any registration fees paid are credited back to the registrar. The domain is immediately available for registration.

If the domain is in the Renew Grace Period, the Transfer Grace Period or the Auto Renew Grace Period, the respective renewPeriod, transferPeriod or autoRenewPeriod statuses are removed and the corresponding fees are credited to the Registrar. The domain then moves to the RGP as described above.

12.0. ADDITIONAL STATUSES
There are additional statuses that the registry or registrar can apply to a domain registration to limit what actions can be taken on it or to limit its usefulness. This section addresses such statuses that have not already addressed in this response.

Some statuses are applied by the registrar and others are exclusively applied by the registry. Registry-applied statuses cannot be altered by registrars. Status names that registrars can add or remove begin with “client”. Status names that only the registry can add or remove begin with “server”. These statuses can be applied by a registrar using the EPP domain update request as defined in RFC 5731.

To prevent a domain registration from being deleted, the status values of clientDeleteProhibited or serverDeleteProhibited may be applied by the appropriate party.

To withhold delegation of the domain to the DNS, clientHold or serverHold is applied. This prevents the domain name from being published to the zone file. If it is already published, the domain name is removed from the zone file.

To prevent renewal of the domain registration clientRenewProhibited or serverRenewProhibited is applied by the appropriate party.

To prevent the transfer of sponsorship of a registration, the states clientTransferProhibited or serverTransferProhibited is applied to the domain. When this is done, all requests for transfer are rejected by the registry.

If a domain registration contains no host objects, the registry applies the status of inactive. Since there are no host objects associated with the domain, by definition, it cannot be published to the zone. The inactive status cannot be applied by registrars.

If a domain has no prohibitions, restrictions or pending operations and the domain also contains sufficient host object references for zone publication, the registry assigns the status of ok if there is no other status set.

There are a few statuses defined by the domain mapping RFC 5731 that our registry does not use. These statuses are: pendingCreate, pendingRenew and pendingUpdate. RFC 5731 also defines some status combinations that are invalid. We acknowledge these and our registry system disallows these combinations.

13.0. RESOURCING
Software Engineering: 
- Existing Department Personnel: Project Manager, Development Manager, two Sr. Software Engineers, Sr. Database Engineer, Quality Assurance Engineer
- New Hires: Web Developer, Database Engineer, Technical Writer, Build⁄Deployment Engineer
Systems Engineering:
- Existing Department Personnel: Sr. Director IT Operations, 2 Sr. Systems Administrators, 2 Systems Administrators, 2 Sr. Systems Engineers, 2 Systems Engineers
- New Hires: Systems Engineer
Network Engineering: 
- Existing Department Personnel: Sr. Director IT Operations, two Sr. Network Engineers, 2 Network Engineers
- New Hires: Network Engineer
Database Operations: 
- Existing Department Personnel: Sr. Database Operations Manager, 2 Database Administrators
Network Operations Center: 
- Existing Department Personnel: Manager, 2 NOC Supervisors, 12 NOC Analysts
- New Hires: Eight NOC Analysts

Q28 Standard CHAR: 29543

1.0. INTRODUCTION

Donuts will employ strong policies and procedures to prevent and mitigate abuse. Our intention is to ensure the integrity of this top-level domain (TLD) and maintain it as a trusted space on the Internet. We will not tolerate abuse and will use professional, consistent, and fair policies and procedures to identify and address abuse in the legal, operational, and technical realms 

Our approach to abuse prevention and mitigation includes the following:

– An Anti-Abuse Policy that clearly defines malicious and abusive behaviors;
– An easy-to-use single abuse point of contact (APOC) that Internet users can use to report the malicious use of domains in our TLD;
– Procedures for investigating and mitigating abuse;
– Procedures for removing orphan glue records used to support malicious activities;
– Dedicated procedures for handling legal requests, such as inquiries from law enforcement bodies, court orders, and subpoenas; 
– Measures to deter abuse of the Whois service; and
– Policies and procedures to enhance Whois accuracy, including compliance and monitoring programs.

Our abuse prevention and mitigation solution leverages our extensive domain name industry experience and was developed based on extensive study of existing gTLDs and ccTLDs for best registry practices. This same experience will be leveraged to manage the new TLD.

2.0. ANTI-ABUSE POLICY 

The Anti-Abuse Policy for our registry will be enacted under the Registry-Registrar Agreement, with obligations from that agreement passed on to and made binding upon all registrants, registrars, and resellers. This policy will also be posted on the registry web site and accompanied by abuse point-of-contact contact information (see below). Internet users can report suspected abuse to the registry and sponsoring registrar, and report an orphan glue record suspected of use in connection with malicious conduct (see below).

The policy is especially designed to address the malicious use of domain names. Its intent is to:

1. Make clear that certain types of behavior are not tolerated;
2. Deter both criminal and non-criminal but harmful use of domain names; and 
3. Provide the registry with clearly stated rights to mitigate several types of abusive behavior when found. 

This policy does not take the place of the Uniform Dispute Resolution Policy (UDRP) or the Uniform Rapid Suspension System (URS), and it is not to be used as an alternate form of dispute resolution or as a brand protection mechanism. 

Below is a policy draft based on the anti-abuse policies of several existing TLD registries with exemplary practices (including .ORG, .CA, and .INFO). We plan to adopt the same, or a substantially similar version, after the conclusion of legal reviews.

3.0. TLD ANTI-ABUSE POLICY

The registry reserves the right, at its sole discretion and at any time and without limitation, to deny, suspend, cancel, redirect, or transfer any registration or transaction, or place any domain name(s) on registry lock, hold, or similar status as it determines necessary for any of the following reasons: 

(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 the registry operator, its affiliates, subsidiaries, officers, directors, or employees; 
(4) to comply with the terms of the registration agreement and the registry’s Anti-Abuse Policy; 
(5) registrant fails to keep Whois information accurate and up-to-date; 
(6) domain name use violates the registry’s acceptable use policies, or a third partyʹs rights or acceptable use policies, including but not limited to the infringement of any copyright or trademark; 
(7) to correct mistakes made by the registry operator or any registrar in connection with a domain name registration; or
(8) as needed during resolution of a dispute.

Abusive use of a domain is an illegal, malicious, or fraudulent action and includes, without limitation, the following:

– Distribution of malware: The dissemination of software designed to infiltrate or damage a computer system without the ownerʹs informed consent. Examples include computer viruses, worms, keyloggers, trojans, and fake antivirus products;
– Phishing: attempts to acquire sensitive information such as usernames, passwords, and credit card details by masquerading as a trustworthy entity in an electronic communication;
– DNS hijacking or poisoning;
– Spam: The use of electronic messaging systems to send unsolicited bulk messages. This includes but is not limited to email spam, instant messaging spam, mobile messaging spam, and the spamming of Internet forums;
– Use of botnets, including malicious fast-flux hosting;
– Denial-of-service attacks;
– Child pornography⁄child sexual abuse images;
– The promotion, encouragement, sale, or distribution of prescription medication without a valid prescription in violation of applicable law; and
– Illegal access of computers or networks.

4.0. SINGLE ABUSE POINT OF CONTACT 

Our prevention and mitigation plan includes use of a single abuse point of contact (APOC). This contact will be a role-based e-mail address in the form of “abuse@registry.tld”. This e-mail address will allow multiple staff members to monitor abuse reports. This role-based approach has been used successfully by ISPs, e-mail service providers, and registrars for many years, and is considered an Internet abuse desk best practice. 

The APOC e-mail address will be listed on the registry web site. We also will provide a convenient web form for complaints. This form will prompt complainants to provide relevant information. (For example, complainants who wish to report spam will be prompted to submit the full header of the e-mail.) This will help make their reports more complete and accurate.

Complaints from the APOC e-mail address and web form will go into a ticketing system, and will be routed to our abuse handlers (see below), who will evaluate the tickets and execute on them as needed.

The APOC is mainly for complaints about malicious use of domain names. Special addresses may be set up for other legal needs, such as civil and criminal subpoenas, and for Sunrise issues.

5.0. ABUSE INVESTIGATION AND MITIGATION 

Our designated abuse handlers will receive and evaluate complaints received via the APOC. They will decide whether a particular issue merits action, and decide what action is appropriate.

Our designated abuse handlers have domain name industry experience receiving, investigating and resolving abuse reports. Our registry implementation plan will leverage this experience and deploy additional resources in an anti-abuse program tailored to running a registry.

We expect that abuse reports will be received from a wide variety of parties, including ordinary Internet users; security researchers and Internet security companies; institutions, such as banks; and law enforcement agencies. 

Some of these parties typically provide good forensic data or supporting evidence of the alleged malicious behavior. In other cases, the party reporting an issue may not be familiar with how to provide evidence. It is not unusual, in the Internet industry, that a certain percentage of abuse reports are not actionable because there is insufficient evidence to support the complaint, even after additional investigation.

The abuse handling function will be staffed with personnel who have experience handling abuse complaints. This group will function as an abuse desk to “triage” and investigate reports. Over the past several years, this group has investigated allegations about a variety of problems, including malware, spam, phishing, and child pornography⁄child sexual abuse images.

6.0. POLICIES, PROCEDURES, AND SERVICE LEVELS 

Our abuse prevention and mitigation plan includes development of an internal manual for assessing and acting upon abuse complaints. Our designated abuse handlers will use this to ensure consistent and fair processes. To prevent exploitation of internal procedures by malefactors, these procedures will not be published publicly. 

Assessing abuse reports requires great care. The goals are accuracy, a zero false-positive rate to prevent harm to innocent registrants, and good documentation. 

Different types of malicious activities require different methods of investigation and documentation. The procedures we deploy will address all the abuse types listed in our Anti-Abuse Policy (above). This policy will also contain procedures for assessing complaints about orphan nameservers used for malicious activities.

One of the first steps in addressing abusive or harmful activities is to determine the type of domain involved. Two types of domains may be involved: 1) a “compromised domain”; and⁄or 2) a maliciously registered domain. 

A “compromised” domain is one that has been hacked or otherwise compromised by criminals; the registrant is not responsible for the malicious activity taking place on the domain. For example, most domain names that host phishing sites are compromised. The goal in such cases is to inform the registrant of the problem via the registrar. Ideally, such domains are not suspended, since suspension disrupts legitimate activity on the domain.

The second type of potentially harmful domain, the maliciously registered domain, is one registered by a bad actor for the purpose of abuse. Since it has no legitimate use, this type of domain is a candidate for suspension.

In general, we see the registry as the central entity responsible for monitoring abuse of the TLD and passing any complaints received to the domains’ sponsoring registrars. In an alleged (though credible) case of malicious use, the case will be communicated to the domain’s sponsoring registrar requesting that the registrar investigate, act appropriately, and report on it within a defined time period. Our abuse handlers will also provide any evidence they collect to the registrar.

There are several good reasons for passing a case of malicious domain name use on to the registrar. First, the registrar has a direct relationship and contract with the registrant. It is important to respect this relationship as it pertains both to business in general and any legal perspectives involved. Second, the registrar holds a better position to evaluate and act because the registrar typically has vital information the registry operator does not, including domain purchase details and payment method (i.e., credit card, etc.); the identity of a proxy-protected registrant; the IP address from which the domain purchase was made; and whether a reseller is involved. Finally, it is important the registrar know if a registrant is in violation of registry or registrar policies and terms—the registrar may wish to suspend the registrant’s account, or investigate other domains the registrar has registered in this TLD or others.

The registrar is also often best for determining if questionable registrant activity violates the registrar’s legal terms of service or the registry Anti-Abuse Policy, and deciding whether to take any action. Registrars will be required to include language in their registrar-registrant contracts that indemnifies the registrar if it takes action and allows the registrar to suspend or cancel a domain name. 

If a registrar does not take action within the time indicated by us in the report (i.e., 24 hours), we may take action ourselves. In some cases, we may suspend the domain name(s), and we reserve the right to act directly and immediately. We plan to take action directly if time is of the essence, such as with a malware attack that may cause significant harm to Internet users. 

It is important to note that strict service level agreements (SLAs) for abuse response and mitigation are not always appropriate, additional tailoring of any SLAs may be required, depending on the problem. For example, suspending a domain within 24 hours may not be the best course of action when working with law enforcement or a national clearinghouse to address reports of child pornography. Officials may need more than 24 hours to investigate and gather evidence. 

7.0. ABUSE MONITORING AND METRICS

In addition to addressing abuse complaints, we will actively monitor the overall abuse status of the TLD, gather intelligence and track abuse metrics to address criminal use of domains in the TLD.

To enable active reporting of problems to the sponsoring registrars, our plan includes proactive monitoring for malicious use of the domains in the TLD. Our goal is to keep malicious activity at an acceptably low level, and mitigate it actively when it occurs—we may do so by using professional blocklists of domain names. For example, professional advisors such as LegitScript (www.legitscript.com) may be used to identify and close down illegal “rogue” Internet pharmacies.

Our approach also incorporates recordkeeping and metrics regarding abuse and abuse reports. These may include:

– The number of abuse reports received by the registry’s abuse point of contact described above and the domains involved;
– The number of cases and domains referred to registrars for resolution;
– The number of cases and domains for which the registry took direct action;
– Resolution times (when possible or relevant, as resolution times for compromised domains are difficult to measure).

We expect law enforcement to be involved in only a small percentage of abuse cases and will call upon relevant law enforcement as needed. 

8.0. HANDLING REPORTS FROM LAW ENFORCEMENT, COURT ORDERS 

The new gTLD Registry Agreement contains this requirement: “Registry Operator shall take reasonable steps to investigate and respond to any reports from law enforcement and governmental and quasi-governmental agencies of illegal conduct in connection with the use of the TLD. In responding to such reports, Registry Operator will not be required to take any action in contravention of applicable law.” (Article 2.8) 

We will be responsive as required by Article 2.8. Our abuse handling team will comply with legal processes and leverage both experience and best practices to work effectively with law enforcement and other government agencies. The registry will post a Criminal Subpoena Policy and Procedure page, which will detail how law enforcement and government agencies may submit criminal and civil subpoenas. When we receive valid court orders or seizure warrants from courts or law enforcement agencies of relevant jurisdiction, we will expeditiously review and comply with them. 

9.0. PROHIBITING DOMAIN HIJACKINGS AND UNAPPROVED UPDATES

Our abuse prevention and mitigation plan also incorporates registrars that offer domain protection services and high-security access and authentication controls. These include services designed to prevent domain hijackings and inhibit unapproved updates (such as malicious changes to nameserver settings). Registrants will then have the opportunity to obtain these services should they so elect. 

10.0. ABUSE POLICY: ADDRESSING INTELLECTUAL PROPERTY INFRINGEMENT

Intellectual property infringement involves three distinct but sometimes intertwined problems: cybersquatting, piracy, and trademark infringement:

– Cybersquatting is about the presence of a trademark in the domain string itself. 
– Trademark infringement is the misuse or misappropriation of trademarks – the violation of the exclusive rights attached to a trademark without the authorization of the trademark owner or any licensees. Trademark infringement sometimes overlaps with piracy.
– Piracy involves the use of a domain name to sell unauthorized goods, such as copyrighted music, or trademarked physical items, such as fake brand-name handbags. Some cases of piracy involve trademark infringement.

The Uniform Dispute Resolution Process (UDRP) and the new Uniform Rapid Suspension System (URS) are anti-cybersquatting policies. They are mandatory and all registrants in the new TLD will be legally bound to them. Please refer to our response to Question #29 for details on our plans to respond to URS orders. 

The Anti-Abuse Policy for our gTLD will be used to address phishing cases that involve trademarked strings in the domain name. The Anti-Abuse Policy prohibits violation of copyright or trademark; such complaints will be routed to the sponsoring Registrar.

11.0. PROPOSED MEASURES FOR REMOVAL OF ORPHAN GLUE RECORDS

Below are the policies and procedures to be used for our registry in handling orphan glue records. The anti-abuse documentation for our gTLD will reflect these procedures.

By definition, a glue record becomes an ʺorphanʺ when the delegation point Name Server (NS) record referencing it is removed without also removing the corresponding glue record. The delegation point NS record is sometimes referred to as the parent NS record. 

As ICANN’s SSAC noted in its Advisory SAC048 “SSAC Comment on Orphan Glue Records in the Draft Applicant Guidebook” (http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf ), ʺOrphaned glue can be used for abusive purposes; however, the dominant use of orphaned glue supports the correct and ordinary operation of the Domain Name System (DNS).ʺ For example, orphan glue records may be created when a domain (example.tld) is placed on Extensible Provisioning Protocol (EPP) ServerHold or ClientHold status. This use of Hold status is an essential tool for suspending malicious domains. When placed on Hold, the domain is removed from the zone and will stop resolving. However, any child nameservers (now orphan glue) of that domain (e.g., ns1.example.tld) are left in the zone. It is important to keep these orphan glue records in the zone so that any innocent sites using that nameserver will continue to resolve. 


We will use the following procedure—used by several existing registries and considered a generally accepted DNS practice—to manage orphan glue records.. When a registrar submits a request to delete a domain, the registry first checks for the existence of glue records. If glue records exist, the registry checks to see if other domains in the registry are using the glue records. If other domains in the registry are using the glue records, then registrar EPP requests to delete the domain will fail until no other domains are using the glue records. (This functionality is currently in place for the .ORG registry.) However, if a registrar submits a complaint that orphan glue is being used maliciously and the malicious conduct is confirmed, the registry operator will remove the orphan glue record from the zone file via an exceptional process. 

12.0. METHODS TO PROMOTE WHOIS ACCURACY

12.1. ENFORCING REQUIRED CONTACT DATA FIELDS

We will offer a “thick” registry system. In this model, all key contact details for each domain name will be stored in a central location by the registry. This allows for better access to domain data and provides uniformity in storing the information. 

As per the EPP specification, certain contact data fields are mandatory. Our registry will enforce those, plus certain other fields as necessary. This ensures that registrars are providing required domain registration data. The following fields (indicated as “MANDATORY”) will be mandatory at a minimum:

Contact Name [MANDATORY]
Street1 [MANDATORY]
City [MANDATORY]
State⁄Province [optional]
Country [MANDATORY]
Postal Code [optional]
Registrar Phone [MANDATORY]
Phone Ext [optional]
Fax [optional]
Fax Ext [optional]
Email [MANDATORY]

In addition, our registry will verify formats for relevant individual data fields (e.g. e-mail, and phone⁄fax numbers) and will reject any improperly formatted submissions. Only valid country codes will be allowed, as defined by the ISO 3166 code list. 

We will reject entries that are clearly invalid. For example, a contact that contains phone numbers such as 555.5555, or registrant names that consist only of hyphens, will be rejected.

12.2. POLICIES AND PROCEDURES TO ENHANCE WHOIS ACCURACY COMPLIANCE

We generally will rely on registrars to enforce WHOIS accuracy measures, but will also rely on review and audit procedures to enhance compliance.

As part of our RRA (Registry-Registrar Agreement), we will require each registrar to be responsible for ensuring the input of accurate Whois data by its registrants. The Registrar⁄Registered Name Holder Agreement will include specific clauses to ensure accuracy of Whois data, as per ICANN requirements, and to give the registrar the right to cancel or suspend registrations if the registered name holder fails to respond to the registrar’s query regarding accuracy of data. In addition, the Anti-Abuse Policy for our registry will give the registry the right to suspend, cancel, etc., domains that have invalid Whois data. 

As part of our RRA (Registry-Registrar Agreement), we will include a policy similar to the one below, currently used by the Canadian Internet Registration Authority (CIRA), the operator of the .CA registry. It will require the registrar to help us verify contact data.

“CIRA is entitled at any time and from time to time during the Term…to verify: (a) the truth, accuracy and completeness of any information provided by the Registrant to CIRA, whether directly, through any of the Registrars of Record or otherwise; and (b) the compliance by the Registrant with the provisions of the Agreement and the Registry PRP. The Registrant shall fully and promptly cooperate with CIRA in connection with such verification and shall give to CIRA, either directly or through the Registrar of Record such assistance, access to and copies of, such information and documents as CIRA may reasonably require to complete such verification. CIRA and the Registrant shall each be responsible for their own expenses incurred in connection with such verification.”
http:⁄⁄www.cira.ca⁄assets⁄Documents⁄Legal⁄Registrants⁄registrantagreement.pdf 

On a periodic basis, we will perform spot audits of the accuracy of Whois data in the registry. Questionable data will be sent to the sponsoring registrars as per the above policy.

All accredited registrars have agreed with ICANN to obtain contact information from registrants, and to take reasonable steps to investigate and correct any reported inaccuracies in contact information for domain names registered through them. As part of our RRA (Registry-Registrar Agreement), we will include a policy that allows us to de-accredit any registrar who a) does not respond to our Whois accuracy requests, or b) fails to update Whois data or delete the name within 15 days of our report of invalid WHOIS data. In order to allow for inadvertent and unintentional mistakes by a registrar, this policy may include a “three strikes” rule under which a registrar may be de-accredited after three failures to comply.

12.3. PROXY⁄PRIVACY SERVICE POLICY TO CURB ABUSE

In our TLD, we will allow the use of proxy⁄privacy services. We believe that there are important, legitimate uses for such services. (For example, to protect free speech rights and avoid receiving spam.) 

However, we will limit how proxy⁄privacy services are offered. The goal of this policy is to make proxy⁄privacy services unattractive to abusers, namely the spammers and e-criminals who use such services to hide their identities. We believe the policy below will enhance WHOIS accuracy, will help deter the malicious use of domain names in our TLD, and will aid in the investigation and mitigation of abuse complaints. 

Registry policy will require the following, and all registrars and their registrants and resellers will be bound to it contractually: 

a. Registrants must provide complete and accurate contact information to their registrar (or reseller, if applicable).. Domains that do not meet this policy may be suspended.
b. Registrars and resellers must provide the underlying registrant information to the registry operator, upon written request, during an abuse investigation. This information will be held in confidence by the registry operator.
c. The registrar or reseller must publish the underlying registrant information in the Whois if it is determined by the registry operator or the registrar that the registrant has breached any terms of service, such as the TLD Anti-Abuse Policy. 

The purpose of the above policy is to ensure that, in case of an abuse investigation, the sponsoring registrar has access to the registrant’s true identity, and can provide that data to the registry. If it is clear the registrant has violated the TLD’s Anti-Abuse Policy or other terms of service, the registrant’s identity will be published publicly via the Whois, where it can be seen by the public and by law enforcement.


13.0. REGISTRY-REGISTRAR CODE OF CONDUCT AS RELATED TO ABUSE

Donuts does not currently intend to become a registrar for this TLD. Donuts and our back-end technical operator will comply fully with the Registry Code of Conduct specified in the New TLD Registry Agreement, Specification 9. For abuse issues, we will comply by establishing an adequate “firewall” between our registry operations and the operations of any affiliated registrar. As the Code requires, the registry will not “directly or indirectly show any preference or provide any special consideration to any Registrar with respect to operational access to registry systems and related registry services”. Here is a non-exhaustive list of specific steps to be taken to enforce this:

– Abuse complaints and cases will be evaluated and executed upon using the same criteria and procedures, regardless of a domain’s sponsoring registrar.
– Registry personnel will not discuss abuse cases with non-registry personnel or personnel from separate entities operating under the company. This policy is designed to both enhance security and prevent conflict of interest.
– If a compliance function is involved, the compliance staff will have responsibilities to the registry only, and not to a registrar we may be “affiliated” with at any point in the future. For example, if a compliance staff member is assigned to conduct audits of WHOIS data, that person will have no duty to any registrar business we may be operating at the time. The person will be free of conflicts of interest, and will be enabled to discharge his or her duties to the registry impartially and effectively.

14.0. CONTROLS TO ENSURE PROPER ACCESS TO DOMAIN FUNCTIONS

Our registry incorporates several measures to ensure proper access to domain functions, including authentication provisions in the RRA relative to notification and contact updates via use of AUTH-INFO codes.

IP address access control lists, SSL certificates, and proper authentication will be used to control registrar access to the registry system. Registrars will be given access only to perform operations on the objects they sponsor.

Every domain will have a unique AUTH-INFO code as per EPP RFCs. The AUTH-INFO code is a 6- to 16-character code assigned by the registrar at the time the name is created. Its purpose is to aid identification of the domain owner so proper authority can be established. (It is the ʺpasswordʺ to the domain name.) Registrars must use the domain’s password to initiate a Registrar-to-Registrar transfer. It is used to ensure that domain updates (update contact information, transfer, or deletion) are undertaken by the proper registrant, and that this registrant is adequately notified of domain update activity. Only the sponsoring Registrar of a domain has access to the domain’s AUTH-INFO code stored in the registry, and this is accessible only via encrypted, password-protected channels.

Our Registry-Registrar contract will require that each registrar assign a unique AUTH-INFO code to every domain it creates. Due to security risk, registrars should not assign the same AUTH-INFO code to multiple domains.

Information about other registry security measures such as encryption and security of Registrar channels are confidential to ensure the security of the registry system. Details can be found in our response to Question #30(b).

15.0. RESOURCING PLAN

Our back-end registry operator will perform the majority of Abuse Prevention and Mitigation services for this TLD, as required by our agreement with them. Donuts staff will supervise the activity of the provider. In some cases Donuts staff will play a direct role in the handling of abuse cases. 

The compliance department of our registry operator has two full time staff members who are trained in DNS, the investigation of abuse complaints, and related specialties. The volume of abuse activity will be gauged and additional staff hired by our back-end registry operator as required to meet their SLA commitments. In addition to the two full-time members, they expect to retain the services of one or more outside contractors to provide additional security and anti-abuse expertise – including advice on the effectiveness of our policies and procedures. 

Finally, Donuts’ Legal Department will have one attorney whose role includes the oversight of legal issues related to abuse, and interaction with courts and law enforcement. 

Q29 Standard CHAR: 25023


1.0. INTRODUCTION

To minimize abusive registrations and other activities that affect the legal rights of others, our approach includes well-developed policies for rights protection, both during our TLD’s rollout period and on an ongoing basis. As per gTLD Registry Agreement Specification 7, we will offer a Sunrise Period and a Trademark Claims service during the required time periods, we will use the Trademark Clearinghouse, and we will implement Uniform Rapid Suspension (URS) on an ongoing basis. In addition to these newly mandated ICANN protections, we will implement two other trademark protections that were developed specifically for the new TLD program. These additional protections are: (i) a Domain Protected Marks List (DPML) for the blocking of trademarked strings across multiple TLDs; and (ii) a Claims Plus product to alert registrars to registrations that potentially infringe existing marks.

Below we detail how we will fulfill these requirements and further meet or exceed ICANN’s requirements. We also describe how we will provide additional measures specific to rights protection above ICANN’s minimum, including abusive use policies, takedown procedures, and other covenants.

Our RPM approach leverages staff with extensive experience in a large number of gTLD and ccTLD rollouts, including the Sunrises for .CO, .MOBI, .ASIA, .EU, .BIZ, .US., .TRAVEL, TEL, .ME, and .XXX. This staff will utilize their first-hand, practical experience and will effectively manage all aspects of Sunrise, including domain application and domain dispute processes.

The legal regime for our gTLD will include all of the ICANN-mandated protections, as well as some independently developed RPMs proactively included in our Registry-Registrar Agreement. Our RPMs exceed the ICANN-required baseline. They are:

- Reserved names: to protect names specified by ICANN, including the necessary geographic names.
- A Sunrise Period: adhering to ICANN requirements, and featuring trademark validation via the Trademark Clearinghouse.
- A Trademark Claims Service: offered as per ICANN requirements, and active after the Sunrise period and for the required time during wider availability of the TLD. 
- Universal Rapid Suspension (URS) 
- Uniform Dispute Resolution Process (UDRP)
- Domain Protected Marks List (DPML)
- Claims Plus 
- Abusive Use and Takedown Policies



2.0. NARRATIVE FOR Q29 FIGURE 1 OF 1

Attachment A, Figure 1, shows Rollout Phases and the RPMs that will be used in each. As per gTLD Registry Agreement Specification 7, we will offer a Sunrise Period and a Trademark Claims service during the required time periods. In addition, we will use the Trademark Clearinghouse to implement URS on an ongoing basis.

3.0. PRE-SUNRISE: RESERVED AND PREMIUM NAMES

Our Pre-sunrise phase will include a number of key practices and procedures. First, we will reserve the names noted in the gTLD Registry Agreement Specification 5. These domains will not be available in Sunrise or subsequent registration periods. As per Specification 5, Section 5, we will provide national governments the opportunity to request the release of their country and territory names for their use. Please also see our response to Question 22, “Protection of Geographic Names.”

We also will designate certain domains as “premium” domains. These will include domains based on generic words and one-character domains. These domains will not be available in Sunrise, and the registry may offer them via special means such as auctions and RFPs. 

As an additional measure, if a trademark owner objects to a name on the premium name list, the trademark owner may petition to have the name removed from the list and made available during Sunrise. The trademark must meet the Sunrise eligibility rules (see below), and be an exact match for the domain in question. Determinations of whether such domains will be moved to Sunrise will be at the registry’s sole discretion. 

4.0. SUNRISE

4.1. SUNRISE OVERVIEW

Sunrise registration services will be offered for a minimum of 30 days during the pre-launch phase. We will notify all relevant trademark holders in the Trademark Clearinghouse if any party is seeking a Sunrise registration that is an identical match to the name to be registered during Sunrise. 

As per the Sunrise terms, affirmed via the Registry-Registrar Agreement and the Registrar-Registrant Agreement, the domain applicant will assert that it is qualified to hold the domain applied for as per the Sunrise Policy and Rules.

We will use the Trademark Clearinghouse to validate trademarks in the Sunrise. 

If there are multiple valid Sunrise applications for the same domain name string, that string will be subject to auction between only the validated applicants. After receipt of payment from the auction winning bidder, that party will become the registrant of the domain name. (note: in the event one of the identical, contending marks is in a trademark classification reflective of the TLD precedence to that mark may be given during Sunrise).

Sunrise applicants may not use proxy services during the application process.

4.2. SUNRISE: ELIGIBLE RIGHTS

Our Sunrise Eligibility Requirements (SERs) are:

1. Ownership of a qualifying mark. 

a. We will honor the criteria in ICANN’s Trademark Clearinghouse document section 7.2, number (i): The registry will recognize and honor all word marks that are nationally or regionally [see Endnote 1] registered and for which proof of use — which can be a declaration and a single specimen of current use – was submitted to, and validated by, the Trademark Clearinghouse. 

b. In addition, we may accept marks that are not found in the Trademark Clearinghouse, but meet other criteria, such as national trademark registrations or common law rights. 

2. Representation by the applicant that all provided information is true and correct; and

3. Provision of data sufficient to document rights in the trademark. (See information about required Sunrise fields, below).


4.3. SUNRISE TRADEMARK VALIDATION

Our goal is to award Sunrise names only to applicants who are fully qualified to have them. An applicant will be deemed to be qualified if that applicant has a trademark that meets the Sunrise criteria, and is seeking a domain name that matches that trademark, as per the Sunrise rules. 

Accordingly, we will validate applications via the Trademark Clearinghouse. We will compare applications to the Trademark Clearinghouse database, and those that match (as per the Sunrise rules) will be considered valid applications. 

An application validated according to Sunrise rules will be marked as “validated,” and will proceed. (See “Contending Applications,” below.) If an application does not qualify, it will be rejected and will not proceed.

To defray the costs of trademark validation and the Trademark Claims Service, we will charge an application and⁄or validation fee for every application. 

In January 2012, the ICANN board was briefed that “An ICANN cross-functional team is continuing work on implementation of the Trademark Clearinghouse according to a project plan providing for a launch of clearinghouse operations in October 2012. This will allow approximately three months for rights holders to begin recording trademark data in the Clearinghouse before any new gTLDs begin accepting registrations (estimated in January 2013).” (http:⁄⁄www.icann.org⁄en⁄minutes⁄board-briefing-materials-4-05jan12-en.pdf) The Clearinghouse Implementation Assistance Group (IAG), which Donuts is participating in, is working through a large number of process and technical issues as of this writing. We will follow the progress of this work, and plan our implementation details based on the final specifications.

Compliant with ICANN policy, our registry software is designed to properly check domains and compare them to marks in the Clearinghouse that contain punctuation, spaces, and special symbols. 

4.5. CONTENDING APPLICATIONS, SUNRISE AUCTIONS

After conclusion of the Sunrise Period, the registry will finish the validation process. If there is only one valid application for a domain string, the domain will be awarded to that applicant. If there are two or more valid applications for a domain string, only those applicants will be invited to participate in a closed auction for the domain name. The domain will be awarded to the auction winner after payment is received.

After a Sunrise name is awarded to an applicant, it will then remain under a “Sunrise lock” status for a minimum of 60 days in order to allow parties to file Sunrise Challenges (see below). Locked domains cannot be updated, transferred, or deleted.

When a domain is awarded and granted to an applicant, that domain will be available for lookup in the public Whois. Any party may then see what domains have been awarded, and to which registrants. Parties will therefore have the necessary information to consider Sunrise Challenges.

Auctions will be conducted by very specific rules and ethics guidelines. All employees, partners, and contractors of the registry are prohibited from participating in Sunrise auctions.

4.6. SUNRISE DISPUTE RESOLUTION PROCESS (SUNRISE CHALLENGES)

We will retain the services of a well-known dispute resolution provider (such as WIPO) to help formulate the language of our Sunrise Dispute Resolution Process (SDRP, or “Sunrise Challenge”) and hear the challenges filed under it. All applicants and registrars will be contractually obligated to follow the decisions handed down by the dispute resolution provider.

Our SDRP will allow challenges based on the following grounds, as required by ICANN. These will be part of the Sunrise eligibility criteria that all registrants (applicants) will be bound to contractually:

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

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

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

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

Our SDRP will be based generally on some SDRPs that have been used successfully in past TLD launches. The Sunrise Challenge Policies and Rules used in the .ASIA and .MOBI TLDs (minus their unique eligibility criteria) are examples. 

We expect that that there will be three possible outcomes to a Sunrise Challenge:

1. Original registrant proves his⁄her right to the domain. In this case the registrant keeps the domain and it is unlocked for his⁄her use.
2. Original registrant is not eligible or did not respond, and the challenger proved his⁄her right to the domain. In this case the domains is awarded to the complainant.
3. Neither the original registrant nor the complainant proves rights to the domain. In this case the domain is cancelled and becomes available at a later date via a mechanism to be determined by the registry operator.

After any Sunrise name is awarded to an applicant, it will remain under a “Sunrise Lock” status for at least 60 days so that parties can file Sunrise Challenges. During this Sunrise Lock period, the domain will not resolve and cannot be modified, transferred, or deleted by the sponsoring registrar. A domain name will be unlocked at the end of that lock period only if it is not subject to a Sunrise Challenge. Challenged domains will remain locked until the dispute resolution provider has issued a decision, which the registry will promptly execute.

5.0. TRADEMARK CLAIMS SERVICES

The Trademark Claims Service requirements are well-defined in the Applicant Guidebook, in Section 6 of the “Trademark Clearinghouse” attachment. We will comply with the details therein. We will provide Trademark Claims services for marks in the Trademark Clearinghouse post-Sunrise and then for at least the first 60 days that the registry is open for general registration (i.e. during the first 60 days in the registration period(s) after Sunrise). The Trademark Claims service will provide clear notice to a prospective registrant that another party has a trademark in the Clearinghouse that matches the applied-for domain name—this is a notice to the prospective registrant that it might be infringing upon another party’s rights.

The Trademark Clearinghouse database will be structured to report to registries when registrants are attempting to register a domain name that is considered an “Identical Match” with the mark in the Clearinghouse. We will build, test, and implement an interface to the Trademark Clearinghouse before opening our Sunrise period. As domain name applications come into the registry, those strings will be compared to the contents of the Clearinghouse. 

If the domain name is registered in the Clearinghouse, the registry will promptly notify the applicant. We will use the notice form specified in ICANN’s Module 4, “Trademark Clearinghouse” document. The specific statement by the prospective registrant will warrant that: (i) the prospective registrant has received notification that the mark(s) is included in the Clearinghouse; (ii) the prospective registrant has received and understood the notice; and (iii) to the best of the prospective registrant’s knowledge, the registration and use of the requested domain name will not infringe on the rights that are the subject of the notice.

The Trademark Claims Notice will provide the prospective registrant access to the Trademark Clearinghouse Database information referenced in the Trademark Claims Notice. The notice will be provided in real time (or as soon as possible) without cost to the prospective registrant or to those notified. 

“Identical Match” is defined in ICANN’s Module 4, “Trademark Clearinghouse” document, paragraph 6.1.5. We will examine the Clearinghouse specifications and protocol carefully when they are published. To comply with ICANN policy, the software for our registry will properly check domains and compare them to marks in the Clearinghouse that contain punctuation, spaces, and special symbols. 

6.0. GENERAL REGISTRATION

This is the general registration period open to all registrants. No trademark or other qualification will be necessary in order to apply for a domain in this period.

Domain names awarded via the Sunrise process, and domain strings still being contended via the Sunrise process cannot be registered in this period. This will protect the interests of all Sunrise applicants.

7.0. UNIFORM RAPID SUSPENSION (URS)

We will implement decisions rendered under the URS on an ongoing basis. (URS will not apply to Sunrise names while they are in Sunrise Lock period; during that time those domains are subject to Sunrise policy and Sunrise Challenge instead.)

As per URS policy, the registry will receive notice of URS actions from ICANN-approved URS providers. As per ICANN’s URS requirements, we will lock the domain within 24 hours of receipt of the Notice of Complaint from the URS Provider. Locking means that the registry restricts all changes to the registration data, including transfer and deletion of domain names, though names will continue to resolve. 

Our registry’s compliance team will oversee URS procedures. URS e-mails from URS providers will be directed immediately to the registry’s Support staff, which is on duty 24⁄7⁄365. Support staff will be responsible for executing the directives from the URS provider, and all support staff will receive training in the proper procedures. 

Support staff will notify the URS Provider immediately upon locking the domain name, via e-mail.

Support staff for the registry will retain all copies of e-mails from the URS providers. Each case or order will be assigned a tracking or ticket number. This number will be used to track the status of each opened URS case through to resolution via a database.

Registry staff will then execute further operations upon notice from the URS providers. Each URS provider is required to specify the remedy and required actions of the registry, with notification to the registrant, the complainant, and the sponsoring registrar. 

The guidelines provide that if the complainant prevails, the registry “shall suspend the domain name, which shall remain suspended for the balance of the registration period and would not resolve to the original web site. The nameservers shall be redirected to an informational web page provided by the URS Provider about the URS. The WHOIS for the domain name shall continue to display all of the information of the original Registrant except for the redirection of the nameservers. In addition, the WHOIS shall reflect that the domain name will not be able to be transferred, deleted or modified for the life of the registration.” We will execute the DNS re-pointing required by the URS guidelines, and the domain and its WHOIS data will remain unaltered until the domain expires, as per the ICANN requirements.

8.0. ONGOING RIGHTS PROTECTION MECHANISMS - UDRP

As per ICANN policy, all domains in the TLD will be subject to a Uniform Dispute Resolution Process (UDRP). (Sunrise domains will first be subject to the ICANN-mandated Sunrise SDRP until the Sunrise Challenge period is over, after which those domains will then be subject to UDRP.) 

9.0 ADDITIONAL RIGHTS PROTECTION MECHANISMS NOT REQUIRED BY ICANN 

All Donuts TLDs have two new trademark protection mechanisms developed specifically for the new TLD program. These mechanisms exceed the extensive protections mandated by ICANN. These new protections are:

9.1 Claims Plus: This service will become available at the conclusion of the Trademark Claims service, and will remain available for at least the first five years of registry operations. Trademark owners who are fully registered in the Trademark Clearinghouse may obtain Claims Plus for their marks. We expect the service will be at low or no cost to trademark owners (contingent on Trademark Clearinghouse costs to registries). Claims Plus operates much like Trademark Claims with the exception that notices of potential trademark infringement are sent by the registry to any registrar whose customer performs a check-command or Whois query for a string subject to Claims Plus. Registrars may then take further implementation steps to advise their customers, or use this data to better improve the customer experience. In addition, the Whois at the registry website will output a full Trademark Claims notice for any query of an unregistered name that is subject to Claims Plus. (Note: The ongoing availability of Claims Plus will be contingent on continued access to a Trademark Clearinghouse. The technical viability of some Claims Plus features will be affected by eventual Trademark Clearinghouse rules on database caching). 

9.2 Domain Protected Marks List: The DPML is a rights protection mechanism to assist trademark holders in protecting their intellectual property against undesired registrations of strings containing their marks. The DPML prevents (blocks) registration of second level domains that contain a trademarked term (note: the standard for DPML is “contains”— the protected string must contain the trademarked term). DPML requests will be validated against the Trademark Clearinghouse and the process will be similar to registering a domain name so the process will not be onerous to trademark holders. An SLD subject to DPML will be protected at the second level across all Donuts TLDs (i.e. all TLDs for which this SLD is available for registration). Donuts may cooperate with other registries to extend DPML to TLDs that are not operated by Donuts. The cost of DPML to trademark owners is expected to be significantly less than the cost of actually registering a name.

10.0 ABUSIVE USE POLICIES AND TAKEDOWN PROCEDURES

In our response to Question #28, we describe our anti-abuse program, which is designed to address malware, phishing, spam, and other forms of abuse that may harm Internet users. This program is designed to actively discover, verify, and mitigate problems without infringing upon the rights of legitimate registrants. This program is designed for use in the open registration period. These procedures include the reporting of compromised websites⁄domains to registrars for cleanup by the registrants and their hosting providers. It also describes takedown procedures, and the timeframes and circumstances that apply for suspending domain names used improperly. Please see the response to Question #28 for full details.

We will institute a contractual obligation that proxy protection be stripped away if a domain is proven to be used for malicious purposes. For details, please see “Proxy⁄Privacy Service Policy to Curb Abuse” in the response to Question 28.

11.0. REGISTRY-REGISTRAR CODE OF CONDUCT AS RELATED TO RIGHTS PROTECTION 

We will comply fully with the Registry Code of Conduct specified in the New TLD Registry Agreement, Specification 9. In rights protection matters, we will comply by establishing an adequate “firewall” between the operations of any registrar we establish and the operations of the registry. As the Code requires, we will not “directly or indirectly show any preference or provide any special consideration to any registrar with respect to operational access to registry systems and related registry services”. Here is a non-exhaustive list of specific steps we will take to accomplish this:

- We will evaluate and execute upon all rights protection tasks impartially, using the same criteria and procedures, regardless of a domain’s sponsoring registrar.
- Any registrar we establish or have established at the time of registry launch will not receive preferential access to any premium names, any auctions, etc. Registry personnel and any registrar personnel that we may employ in the future will be prohibited from participating as bidders in any auctions for Landrush names.
- Any registrar staff we may employ in the future will have access to data and records relating only to the applications and registrations made by any registrar we establish, and will not have special access to data related to the applications and registrations made by other registrars.
- If a compliance function is involved, the compliance staffer will be responsible to the registry only, and not to a registrar we own or are “affiliated” with. For example, if a compliance staff member is assigned to conduct audits of WHOIS data, that staffer will not have duties with the registrar business. The staffer will be free of conflicts of interest, and will be enabled to discharge his or her duties to the registry effectively and impartially, regardless of the consequences to the registrar.

12.0. RESOURCING PLAN

Overall management of RPMs is the responsibility of Donuts’ VP of Business Operations. Our back-end registry operator will perform the majority of operational work associated with RPMs, as required by our agreement with them. Donuts VP of Business Operations will supervise the activity of this vendor. 

Resources applied to RPMs include:

1. Legal team 
a. We will have at least one legal counsel who will be dedicated to the registry with previous experience in domain disputes and Sunrise periods and will oversee the compliance and support teams with regard to the legal issues related to Sunrise and RPM’s
b. We have outside counsel with domain and rights protection experience that is available to us as necessary 
2. Dispute Resolution Provider (DRP): The DRP will help formulate Sunrise Rules and Policy, Sunrise Dispute Resolution Policy. The DRP will also examine challenges, but the challenger will be required to pay DRP fees directly to the DRP.
3. Compliance Department and Tech Support: There will be three dedicated personnel assigned to these areas. This staff will oversee URS requests and abuse reports on an ongoing basis. 
4. Programming and technical operations. There are four dedicated personnel assigned to these functions.
5. Project Manager: There will be one person to coordinate the technical needs of this group with the registry IT department. 

13.0. ENDNOTES

1 “Regional” is understood to be a trans-national trademark registry, such as the European Union registry or the Benelux Office for Intellectual Property.

Q30A Standard CHAR: 19646

1.0. INTRODUCTION

Our Information Security (IS) Program and associated IS Policy, Standards and Procedures apply to all Company entities, employees, contractors, temps, systems, data, and processes. The Security Program is managed and maintained by the IS Team, supported by Executive Management and the Board of Directors.

Data and systems vary in sensitivity and criticality and do not unilaterally require the same control requirements. Our security policy classifies data and systems types and their applicable control requirements. All registry systems have the same data classification and are all managed to common security control framework. The data classification applied to all registry systems is our highest classification for confidentiality, availability and integrity, and the supporting control framework is consistent with the technical and operational requirements of a registry, and any supporting gTLD string, regardless of its nature or size. We have the experienced staff, robust system architecture and managed security controls to operate a registry and TLD of any size while providing reasonable assurance over the security, availability, and confidentiality of the systems supporting critical registry functions (i.e., registration services, registry databases, zone administration, and provision of domain name resolution services).

This document describes the governance of our IS Program and the control frameworks our security program aligns to (section 1.0), Security Policy requirements (section 2.0); security assessments conducted (see section 3.0), our process for executive oversight and visibility of risks to ensure continuous improvement (section 4.0), and security commitments to registrants (section 5). Details regarding how these control requirements are implemented, security roles and responsibilities and resources supporting these efforts are included in Security Policy B response.

2.0. INFORMATION SECURITY PROGRAM

The IS Program for our registry is governed by an IS Policy aligned to the general clauses of ISO 27001 requirements for an Information Security Management System (ISMS) and follows the control objectives where appropriate, given the data type and resulting security requirements. (ISO 27001 certification for the registry is not planned, however, our DNS⁄DNSSEC solution is 27001 certified). The IS Program follows a Plan-Do-Check-Act (PDCA) model of continuous improvement to ensure that the security program grows in maturity and that we provide reasonable assurance to our shareholders and Board of Directors that our systems and data are secure.

The High Security Top Level Domain (HSTLD) control framework incorporates ISO 27002, the code of practice for implementing an ISO 27001 ISMS. Therefore, our security program is already closely aligned HSTLD control framework. Furthermore, we agree to abide by the HSTLD Principle 1 and criteria 1.1 - 1.3. (See specifics in Security Policy B response):

Registry systems will be in-scope for Sarbanes-Oxley (SOX) compliance and will follow the SOX control framework governing access control, account management, change management, software development life cycle (SDLC), and job monitoring of all systems. Registry systems will be tested frequently by the IS team for compliance and audited by our internal audit firm, Protiviti, and external audit firm, Price Waterhouse Coopers (PWC), for compliance.

2.1. SECURITY PROGRAM GOVERNANCE

Our Information Security Program is governed by IS Policy, supported by standards, and guided by procedures to ensure uniformed compliance to the program. Standards and associated procedures in support of the policy are shown in Attachment A, Figure 1. Security Program documents are updated annually or upon any system or environment change, new legal or regulatory requirements, and⁄or findings from risk assessments. Any updates to security program are reviewed and approved by the Executive Vice President (EVP) of Information Technology (IT), EVP of Legal & General Counsel, and the EVP of People Operations before dissemination to all employees. 

All employees are required to sign the IS Policy upon hire, upon any major changes, and⁄or annually. By signing the IS Policy, employees agree to abide by the supporting Standards and Procedures applicable to their job roles. To enable signing of the IS Policy, employees must pass a test to ensure competent understanding of the IS Policy and its key requirements. 

3.0. INFORMATION SECURITY POLICY

3.1. INFORMATION ASSET CLASSIFICATION 

The following data classification is applied to registry systems: High Business Impact (HBI): Business Confidential in accordance with the integrity, availability and confidentiality requirements of registry operations. All registry systems will follow Security Policy requirements for HBI systems regardless of the nature of the TLD string, financial materiality or size. HBI data if not properly secured, poses a high degree of risk to the Company and includes data pertaining to the Company’s adherence to legal, regulatory and compliance requirements, mergers and acquisitions (M&A), and confidential data inclusive of, but is not limited to: Personally Identifiable Information (PII) (credit card data, Social Security Numbers (SSN) and account numbers); materially important financial information (before public disclosure), and information which the Board of Directors⁄Executive team deems to be a trade secret, which, if compromised, would cause grave harm to the execution of our business model. 

HBI safeguards are designed, implemented and measured in alignment with confidentiality, integrity, availability and privacy requirements characterized by legal, regulatory and compliance obligations, or through directives issued by the Board of Directors (BOD) and Executive team. Where guidance is provided, such as the Payment Card Industry (PCI) Data Security Standard (DSS) Internal Audit Risk Control Matrices (RCMs), local, state and federal laws, and other applicable regulations, we put forth the appropriate level of effort and resources to meet those obligations. Where there is a lack of guidance or recommended safeguards, Risk Treatment Plans (RTP’s) are designed in alignment with our standard risk management practices. 

Other data classifications for Medium Business Impact (MBI): Business Sensitive and Low Business Impact (LBI): Public do not apply to registry systems.

3.2. INFORMATION ASSET MANAGEMENT

All registry systems have a designated owner and⁄or custodian who ensures appropriate security classifications are implemented and maintained throughout the lifecycle of the asset and that a periodic review of that classification is conducted. The system owner is also responsible for approving access and the type of access granted. The IS team, in conjunction with Legal, is responsible for defining the legal, regulatory and compliance requirements for registry system and data.

3.3. INFORMATION ASSET HANDLING, STORAGE & DISPOSAL

Media and documents containing HBI data must adhere to their respective legal, regulatory and compliance requirements and follow the HBI Handling Standard and the retention requirements within the Document Retention Policy.

3.4. ACCESS CONTROL

User authentication is required to access our network and system resources. We follow a least-privileged role based access model. Users are only provided access to the systems, services or information they have specifically been authorized to use by the system owner based on their job role. Each user is uniquely identified by an ID associated only with that user. User IDs must be disabled promptly upon a user’s termination, or job role change. 

Visitors must sign-in at the front desk of any company office upon arrival and escorted by an employee at all times. Visitors must wear a badge while on-site and return the badge when signing out at the front desk. Dates and times of all visitors as well as the name of the employee escorting them must be tracked for audit purposes. 

Individuals permitted to access registry systems and HBI information must follow the HBI Identity & Access Management Standard. Details of our access controls are described in Part B of Question 30 response including; technical specifications of access management through Active Directory, our ticketing system, physical access controls to systems and environmental conditions at the datacenter.

3.5. COMMUNICATIONS & OPERATIONAL SECURITY

3.5.1. MALICIOUS CODE

Controls shall be implemented to protect against malicious code including but not limited to: 
- Identification of vulnerabilities and applicable remediation activities, such as patching, operating system & software upgrades and⁄or remediation of web application code vulnerabilities. 
- File-integrity monitoring shall be used, maintained and updated appropriately. 
- An Intrusion Detection Solution (IDS) must be implemented on all HBI systems, maintained & updated continuously. 
- Anti-virus (AV) software must be installed on HBI classified web & application systems and systems that provide access to HBI systems. AV software and virus definitions are updated on a regular basis and logs are retained for no less than one year. 

3.5.2. THREAT ANALYSIS & VULNERABILITY MANAGEMENT 

On a regular basis, IS personnel must review newly identified vulnerability advisories from trusted organizations such as the Center for Internet Security, Microsoft, SANS Institute, SecurityFocus, and the CERT at Carnegie-Mellon University. Exposure to such vulnerabilities must be evaluated in a timely manner and appropriate measures taken to communicate vulnerabilities to the system owners, and remediate as required by the Vulnerability Management Standard. Internal and external network vulnerability scans, application & network layer penetration testing must be performed by qualified internal resource or an external third party at least quarterly or upon any significant network change. Web application vulnerability scanning is to be performed on a continual basis for our primary web properties applicable to their release cycles. 

3.5.3. CHANGE CONTROL

Changes to HBI systems including operating system upgrades, computing hardware, networks and applications must follow the Change Control Standard and procedures described in Security Policy question 30b. 

3.5.4. BACKUP & RESTORATION

Data critical to our operations shall be backed up according to our Backup and Restoration Standard. Specifics regarding Backup and Restoration requirements for registry systems are included in questions 37 & 38.

3.6. NETWORK CONTROLS

 - Appropriate controls must be established for ensuring the network is operated consistently and as planned over its entire lifecycle. 
 - Network systems must be synchronized with an agreed upon time source to ensure that all logs correctly reflect the same accurate time.
 - Networked services will be managed in a manner that ensures connected users or services do not compromise the security of the other applications or services as required in the HBI Network Configuration Standard. Additional details are included in Question 32: Architecture response.

3.7. DISASTER RECOVERY & BUSINESS CONTINUITY

The SVP of IT has responsibility for the management of disaster recovery and business continuity. Redundancy and fault-tolerance shall be built into systems whenever possible to minimize outages caused by hardware failures. Risk assessments shall be completed to identify events that may cause an interruption and the probability that an event may occur. Details regarding our registry continuity plan are included in our Question 39 response. 

3.8 SOFTWARE DEVELOPMENT LIFECYCLE

Advance planning and preparation is required to ensure new or modified systems have adequate security, capacity and resources to meet present and future requirements. Criteria for new information systems or upgrades must be established and acceptance testing carried out to ensure that the system performs as expected. Registry systems must follow the HBI Software Development Lifecycle (SDLC) Standard. 

3.9. SECURITY MONITORING

Audit logs that record user activities, system errors or faults, exceptions and security events shall be produced and retained according to legal, regulatory, and compliance requirements. Log files must be protected from unauthorized access or manipulation. IS is responsible for monitoring activity and access to HBI systems through regular log reviews.

3.10. INVESTIGATION & INCIDENT MANAGEMENT RESPONSE

Potential security incidents must be immediately reported to the IS Team, EVP of IT, the Legal Department and⁄or the Incident Response. The Incident Response Team (IRT) is required to investigate: any real or suspected event that could impact the security of our network or computer systems; impose significant legal liabilities or financial loss, loss of proprietary data⁄trade secret, and⁄or harm to our goodwill. The Director of IS is responsible for the organization and maintenance of the IRT that provides accelerated problem notification, damage control, investigation and incident response services in the event of security incidents. Investigation and response processes follow the requirements of the Investigation and Incident Management Standard and supporting Incident Response Procedure (see Question 30b for details).

3.11. LEGAL & REGULATORY COMPLIANCE

All relevant legal, regulatory and contractual requirements are defined, documented and maintained within the IS Policy. Critical records are protected from loss, destruction and falsification, in accordance with legal, contractual and business requirements as described in our Document Retention Policy. Compliance programs implemented that are applicable to Registry Services include:

- Sarbanes Oxley (SOX): All employees managing and accessing SOX systems and⁄or data are required to follow SOX compliance controls. 
- Data Privacy and Disclosure of Personally Identifiable Information (PII): data protection and privacy shall be ensured as required by legal and regulatory requirements, which may include state breach and disclosure laws, US and EU Safe Harbor compliance directives. 

Other compliance programs implemented but not applicable to Registry systems include the Payment Card Industry (PCI) Data Security Standard (DSS), Office of Foreign Assets Control (OFAC) requirements, Copyright Infringement & DMCA. 

4.0. SECURITY ASSESSMENTS

Our IS team conducts frequent security assessments to analyze threats, vulnerabilities and risks associated with our systems and data. Additionally, we contract with several third parties to conduct independent security posture assessments as described below. Details of these assessments are provided in our Security Policy B response. 

4.1. THIRD PARTY SECURITY ASSESSMENTS

We outsource the following third party security assessments (scope, vendor, frequency and remediation requirements of any issues found are detailed in our Security Policy B response); Web Application Security Vulnerability testing, quarterly PCI ASV scans, Sarbanes-Oxley (SOX) control design and operating effectiveness testing and Network and System Security Analysis.

4.2. INTERNAL SECURITY ASSESSMENTS

The IS team conducts routine and continual internal testing (scope, frequency, and remediation requirements of any issues found are detailed in our Security Policy B response) including; web application security vulnerability testing, external and internal vulnerability scanning, system and network infrastructure penetration testing, access control appropriateness reviews, wireless access point discovery, network security device configuration analysis and an annual comprehensive enterprise risk analysis.

5.0. EXECUTIVE OVERSIGHT & CONTINUOUS IMPROVEMENT

In addition to the responsibility for Information Security residing within the IS team and SVP of IT, risk treatment decisions are also the responsibility of the executive of the business unit responsible for the risk. Any risk with potential to impact the business financially or legally in a material way is overseen by the Incident Response Management team and⁄or the Audit Committee. See Figure 2 in Attachment A. The Incident Response Management Team or Audit Committee will provide assistance with management action plans and remediation. 

5.1. GOVERNANCE RISK & COMPLIANCE 

We have deployed RSA’s Archer Enterprise Governance Risk and Compliance (eGRC) Tool to provide an independent benchmarking of risk, compliance and security metrics, assist with executive risk reporting and reduce risk treatment decision making time, enforcing continuous improvement. The eGRC provides automated reporting of registry systems compliance with the security program as a whole, SOX Compliance, and our Vulnerability Management Standard. The eGRC dashboard continuously monitors risks and threats (through automated feeds from our vulnerability testing tools and third party data feeds such as Microsoft, CERT, WhiteHat, etc.) that are actionable. See Attachment A for more details on the GRC solutions deployed.

6.0. SECURITY COMMITMENTS TO REGISTRANTS

We operate all registry systems in a highly secured environment with appropriate controls for protecting HBI data and ensuring all systems remain confidential, have integrity, and are highly available. Registrants can assume that:

1. We safeguard the confidentiality, integrity and availability of registrant data through access control and change management:
 - Access to data is restricted to personnel based on job role and requires 2 factors of authentication.
 - All system changes follow SOX-compliant controls and adequate testing is performed to ensure production pushes are stable and secure.
2. The network and systems are deployed in high availability with a redundant hot datacenter to ensure maximum availability. 
3. Systems are continually assessed for threats and vulnerabilities and remediated as required by the Vulnerability Management Standard to ensure protection from external malicious acts.
 - We conduct continual testing for web code security vulnerabilities (cross-site scripting, SQL Injection, etc.) during the development cycle and in production.
4. All potential security incidents are investigated and remediated as required by our Incident Investigation & Response Standard, any resulting problems are managed to prevent any recurrence throughout the registry.

We believe the security measures detailed in this application are commensurate with the nature of the TLD string being applied for. In addition to the system⁄ infrastructure security policies and measures described in our response to this Q30, we also provide additional safety and security measures for this string.

These additional measures, which are not required by the applicant guidebookare:

1.Periodic audit of Whois data for accuracy;
2.Remediation of inaccurate Whois data, including takedown, if warranted;
3.A new Domain Protected Marks List (DPML) product for trademark protection;
4.A new Claims Plus product for trademark protection;
5.Terms of use that prohibit illegal or abusive activity;
6.Limitations on domain proxy and privacy service;
7.Published policies and procedures that define abusive activity; and
8.Proper resourcing for all of the functions above.

7.0 RESPONSIBILITY OF INFORMATION SECURITY 
See Question B Response Section 10.