Application number: 1-1684-6394 for DotHealth, LLC

DotHealth, LLC

354 Walthery Avenue
Ridgewood New Jersey 07450
US

201 378 3199

201 378 3199

http:⁄⁄www.dothealthgtld.com

Mr. Andrew Ryan Weissberg

Chief Executive Officer

201 378 3199

weissberga@gmail.com

Mr. Neil M Posner

Chief Financial Officer

201 972 5159

nposner1@gmail.com

DotHealth, LLC

Delaware, United States of America

Not Available

Andrew Weissberg
Manager
Jose I. Rasco III
Manager
Juan D. Calle
Manager
Neil Posner
Manager
Nelson D. Calle
Manager

Andrew Weissberg
Chief Executive Officer
Neil Posner
Chief Financial Officer

BelMac Enterprises, LLC
Not Applicable
Straat Health, LLC
Not Applicable

health

Not Available

DotHealth, LLC (“DotHealth”) foresees no known rendering issues in connection with the proposed .health string which it is seeking to apply for as a gTLD. This answer is based upon consultation with DotHealth’s backend provider, Neustar, which has successfully launched a number of new gTLDs over the last decade. In reaching this determination, the following data points were analyzed:
• ICANN’s Security Stability Advisory Committee (SSAC) entitled Alternative TLD Name Systems and Roots: Conflict, Control and Consequences (SAC009);
• IAB - RFC3696 “Application Techniques for Checking and Transformation of Names”
• Known software issues which Neustar has encountered during the last decade launching new gTLDs;
• Character type and length;
• ICANN supplemental notes to Question 16; and
• ICANN’s presentation during its Costa Rica regional meeting on TLD Universal Acceptance;

“Health” is the general condition of the body or mind with reference to soundness and vigor. As a global society, health is a measure of soundness of body, mind or being. Health can mean freedom from disease or ailment. Virtually everywhere in the world, and across many stakeholder segments, health is a major contributor to the economy and serves as a leading and influential indicator for measuring any one country or territory’s economic and societal strengths and weaknesses against others. Throughout the world, people rate health one of their highest priorities and concerns. Whether these are mental, physical, economic or social, these concerns are commonly linked to education and literacy, food and nutrition, fitness and exercise, medicines and therapies, environment and nature, technology and innovation, insurance and employment, for professional research and others. 

For over two decades, the Internet has empowered consumers to make informed health choices and decisions. Although major disparities in access to the Internet still exist in many areas of the developing world, over 14% of the global population uses the Internet at least weekly to find health information, and 20% of people regularly use online or mobile tools for managing or tracking their health (2011 Edelman Health Barometer). More than half of online health-related searches are aimed at acquiring knowledge, answers or information about specific diseases, conditions, medical treatments or procedures in support of a “self-diagnosis,” or on behalf of others. 

Physicians and healthcare professionals are also increasingly using the Internet for professional purposes. A Google 2009 Study revealed that in the U.S., 86% of physicians use Internet to access health information, 65% of primary care doctors search the Web more than once a day for professional purposes, 92% said they accessed it from their office, 21% said they did so with a patient in the examination room, and that 59% reported doing so from a mobile device. Manhattan Research reported in 2011 that 64% of European physicians prefer online sources versus traditional sources to obtain information about pharmaceutical products. In 2010, Frost & Sullivan reported that 75% health care professionals surveyed use social media for business purposes.

The Internet is playing an increasingly important role in strengthening healthcare systems, enabling connectivity between healthcare professionals, institutions and patients. In addition to empowering patients, the Internet is helping to reduce healthcare costs, such as unnecessary hospital emergency room visits. In Great Britain, for example, the National Health Service (NHS) uses the Internet to reduce the burden on general practitioners for common ailments – 60% of the more than 350,000 web inquiries every month are completed within the service and donʹt require any further attention. 

Despite its major benefits and continued adoption, the Internet has also introduced a number of risks and challenges, often as a result of increasingly accessible access to misleading or fraudulent health information. For consumers, the consequences of taking action on inaccurate, false or misleading health information online can be quite serious, given its potential to cause harm, illness, injury and even loss of life. 

Throughout the world, consumers consider academic medical centers and medical associations⁄societies as their most trusted sources of information (Source: Deloitte 2011 Global Consumer Health Study). Despite the increasingly availability of these online sources, currently, it is often difficult for online health consumers to easily distinguish safe and reliable information from inaccurate or fraudulent counterparts. According to the 2010 Bupa Health Pulse Study, very few consumers verify that the source of the data they find is credible. Even when the information “appears” to be credible, more often than not it cannot be trusted and poses significant threats and dangers to online health consumers. Scammers, for example increasingly abuse health-related domain names and keywords to lead online health seekers to counterfeit or dangerous sources, which also pose risks to rightsholders in the health supply chain. 

At DotHealth, LLC, in recognition of these opportunities, challenges and risks, our mission is to establish .health as a safe, trustworthy and secure top-level domain for global health stakeholders. Our goals and objectives are to establish .health as the preferred online namespace for the trusted communication, dissemination, exchange and fulfillment of health-related information and resources. In support of the safety and protection of online health consumers and rightsholders, DotHealth has identified a series of policies, safeguards and standard operating procedures for the .health gTLD that collectively comprise our proposed registry services and procedural framework. This framework will be operated in enterprise collaboration with Neustar, Inc., the world’s leading provider of essential clearinghouse services to the global communications and Internet industry. 
DotHealth will leverage Neustar’s unparalleled technical infrastructure and experience in operating the global registries for numerous top level domains, as well as its malicious monitoring service levels as further described throughout this application submission. We have also executed an exclusive agreement with LegitScript to provide enterprise fraud and abuse monitoring and intelligence services for the .health gTLD. LegitScript’s continued cooperation with leading U.S. and international industry organizations, including the National Association of Boards of Pharmacy, The International Pharmaceutical Federation, the US Food and Drug Administration, and the International Medical Product Anti-Counterfeiting Task Force will play an important role in the creation and ongoing enforcement of DotHealth policies and standards for registrant compliance. LegitScript’s is the healthcare industry’s leading provider of online fraud intelligence and monitoring services, and works with several of the world’s most successful and recognized major e-commerce channels and search engines including Google, Amazon, Yahoo, and Microsoft. Additionally, LegitScript increasingly cooperates with major domain name registrars throughout the world, which will help DotHealth to execute on its goals and objectives for the .health TLD.

DotHealth’s proposed policies and registry services have been developed with consensus and affirmations of support from numerous global and regional health sciences industry organizations including the National Association of Boards of Pharmacy (NABP), The Inter-American College of Physicians and Services (ICPS), The Association of Black Cardiologists and the World Federation of Chiropractic. Our continued cooperation these organizations and others will play an important and influential role in advocating and promoting widespread adoption and the meaningful uses of .health domain names.

As the ICANN new gTLD program is expected to result in the potential introduction of hundreds of new “vertically” oriented namespaces representing brands, special interest groups, geographies and others, we believe the .health gTLD provides for a meaningful opportunity to structure and distinguish a world of online health information and resources that all health stakeholders can trust. 

At DotHealth, LLC (“DotHealth”), our goal is to make the Internet a safer, reliable and genuinely trustworthy resource for all stakeholders in health. We believe that the .health TLD will greatly enhance and improve the ways that health information and resources are discovered, accessed and utilized via the Internet. 

To achieve these goals and objectives, DotHealth will adopt and enforce a series of registry policies, active safeguards and procedures, and work in cooperation with its partners, Neustar and LegitScript to formally distinguish the .health TLD as a “quality label” for health-related websites that adhere to a set of guidelines for safety, reliability and trust. Affirmations of support for these policies and procedures have been secured from numerous global and regional health and wellness industry associations and non-governmental organizations throughout the world. These include the Inter-American College of Physicians, National Association of Boards of Pharmacy (NABP), the World Federation of Chiropractic, the Association of Black Cardiologists and the Regulatory Harmonization Institute.

We envision that .health will appeal to a large, broad, diverse and international addressable market of registrants spanning all major segments of the human health, personal care and animal health industries. DotHealth forecasts that the life sciences and consumer health product segments will comprise the largest segments of the addressable market for .health, as these segments are aggressively shifting their promotional and educational spending from traditional mediums (television, radio, print etc.) to digital channels, including the Internet and mobile devices. Digital resource allocation in support of these goals and campaigns has also shifted from traditional banner advertising toward the creation of “custom online health centers” devoted to a particular disease, condition, or health-related matter. In particular, we believe the pharmaceutical industry will find .health domain names as an attractive alternative to their existing .com or other TLD counterparts for distinguishing non-promotional product-related content or labeling information in order to comply with recently established or newly emerging FDA regulatory guidance for domain names and online resources. Because hundreds of major disease state or condition-related strings are unavailable for registration, the availability of these names in .health will also foster competition in the current domain name space and among those seeking to “own an online health category.” 

DotHealth also envisions that physicians, hospitals and other provider organizations throughout the world will value .health as a safe and reliable resource for communicating and exchanging information with patients and caregivers about their practice or services. In 2011, in the U.S., President Obama ratified the HITECH Act which will make it easier for doctors and other health care professionals to receive incentive payments for adopting and meaningfully using health information technology modules, including patient education web sites and portals which can leverage .health domain names in support of these interventions. 
Because “health” can be associated beyond “wellness” or “disease,” we believe that numerous other market segments and industries outside of the “health” industry will find .health to be an attractive domain name solution for positioning their organizations, products, programs and services. For example, restaurants, which offer “health-conscious” menu options, could utilize .health domain names for specifically marketing or promoting them to consumers. For those engaged in the medical tourism arena, travel and hospitality-related businesses (e.g., hotels or cruise ships) could utilize .health domain names to promote their locations on a “health-related” basis. Employers may wish to utilize .health names for their businesses in support of disseminating information about health insurance programs or services they make available to employees. Major technology companies which provide solutions and services to multiple industries might find .health useful for distinguishing their product⁄service information and resources that specifically cater to health or health stakeholders. For example, IBM could utilize IBM.health instead of http:⁄⁄www-935.ibm.com⁄services⁄us⁄gbs⁄industries⁄healthcare⁄?cm_re=masthead-_-solutions-_-ind-health in this regard. 

As previously stated above, our goal is to make the Internet a safer, reliable and genuinely trustworthy resource for all stakeholders in health. For the .health TLD, in order to enable a safe and reliable online experience for end-users, and in recognition of the challenges and risks that exist in the current online landscape for registrants and end-users, numerous policies, safeguards and standard operating procedures have been identified for the .health TLD which will be enforced and actively monitored for compliance by DotHealth in conjunction with Neustar and LegitScript. Online content on websites discoverable via general search engines is still the mainstay of the digital health landscape. For the average consumer, finding accurate and trustworthy health information can be difficult. When a trusted source isn’t known, online health seekers become especially vulnerable to the dangers of inaccurate or misleading information when they take action with the information they find. Abusive practices and malicious behaviors including email spam, search-engine optimization, social network abuse, typo-squatting, and others are commonplace in online health, and virtually all rely on domain name resolution to direct recipients. These practices and behaviors are commonly classified as “false association,” whereby the information that is discovered or accessed may appear recognizable or trustworthy, but the associated hyperlinks actually resolve to domain names and web sites that aren’t authentic, safe or reliable. Whether accessed through direct navigation, through an organic search result, an e-mail message or otherwise, just clicking on the links themselves can be dangerous, particularly when a user is directed to a domain name that automatically installs malware or poses other threats to user privacy or security. While major search engines like Google now have strong governance in place to restrict rogue online pharmacies from placing paid search advertisements, these do not prevent or inhibit organic searches and email messages with links utilizing health-related keywords or brand names are increasingly at the center of click-fraud and scams that pose harm to health consumers and rightsholders alike. Recently, there has been a push for domain registrars to take a more active role in addressing these risks, although at DotHealth and for the .health gTLD, we intend to eradicate them in the interest of consumer safety and registrant protection at the Registry level. False association also poses various risks to rightsholders, which are of major concern to intellectual property stakeholders throughout the global health sciences industry. Online counterfeit drug sales and “rogue” sources utilize abusive domain name registrations, typo squatting and brand-jacking to exploit health-related trademarks at the expense of rightsholders. According to the World Intellectual Property Organization (WIPO), the biotechnology and pharmaceutical industry sectors rank among the highest of all domain name complainant activity, with over 8% of all cases reported in 2011. 

With 173 million U.S. adults using the Internet for health, and 116 million online specifically for prescription drug or pharmaceutical company resources, our proposed approaches are fully justified and are at the center of DotHealth’s plans and strategies for differentiating .health as a safer and more reliable namespace as compared to its other current and future TLD counterparts. In recognition of these challenges and risks, as the .health Registry Operator, we intend to expressly reserve the right to deny, cancel or transfer any registration that it deems necessary, in its discretion, to protect the integrity and stability of the registry. The DotHealth Registration and Acceptable Use policies we have developed will expressly prohibit the use of .health domain names to support of the illicit promotion or sale of prescription drugs, controlled substances, tainted dietary supplements, ingredients for psychoactive highs, and other substances or ingredients which are have been validated as safety concerns by the U.S. Food and Drug Administration (FDA), the Drug Enforcement Administration (DEA), The European Medicines Agency (EMEA) and⁄or other regional or international regulatory authorities or law enforcement agencies. Registrant compliance with the DotHealth Acceptable Use Policy will be vigilantly monitored and strictly enforced on a daily basis in conjunction with Neustar and LegitScript.

In the interest of protecting rightsholders and intellectual property stakeholders, as well as end-users, numerous operating procedures, safeguards and policies have been identified and orchestrated in conjunction with our proposed efforts to operate the .health TLD registry. These include an extended Sunrise phase as well ongoing cooperation with the newly formed Trademark Clearinghouse and registrars to provide notification services and alerts to ensure rightsholders can stopgap risks for abusive domain name registrations before they are enabled in the .health DNS zone. 

To protect the privacy or confidential information of registrants and end-users, The .health TLD registry solution will leverage Neustar’s architecture which includes multiple layers of security, diversified firewall and networking hardware vendors, multi-factor authentication for accessing registry systems, physical security access controls, a 24x7 manned Network Operations Center that monitors all systems and applications, and a 24x7 manned Security Operations Center that monitors and mitigates DDoS attacks.

Outreach and communications will play an important role in helping DotHealth to achieve our projected benefits. Stakeholders of all kinds – commercial, non-commercial, government organizations and others will need to be educated about the benefits of new gTLDs as they relate to their meaningful use interests, use cases and business models. To establish awareness and adoption of the .health TLD, we plan to utilize various types of health sciences and consumer media channels, events and conferences, and social networks to strategically and regularly deliver key messages regarding the value and benefits of .health, and to communicate our progress and growth. DotHealth also plans to feature a “Resource Center” on our Website for registrants to utilize in order to find an authorized .health registrar, to access our policies, as well as other recommended resources for launching and optimizing the discovery of .health domain names. The Resource Center will also feature examples of .health web sites as credible and trusted sources, identified across various categories in conjunction with accreditation programs that will be executed our industry partners and premium name customers. 

At DotHealth, LLC (“DotHealth”), our mission is to establish .health as a safe, trustworthy and secure top-level domain for global health stakeholders. To ensure success, we have identified and orchestrated a policy framework and numerous safeguards that are designed to mitigate abusive registrations and malicious behaviors which may pose harm to registrants and consumers, or which may otherwise threaten the integrity and stability of the .health registry.

In support of rightsholders and intellectual property stakeholders, in conjunction with the Trademark Clearinghouse, DotHealth will provide a Sunrise Service and trademark notification services for the safeguarding of trademarks as part of its registry operations. The goal of DotHealthʹs sunrise period is to ensure that all rightsholders are able to successfully leverage the brand recognition and value established from their products or services in the context of new .health domain assignments, if they choose to do so. This approach is necessitated by the fact that the biotechnology and pharmaceutical industry sectors rank among the highest of all domain name complainant activity. 

In conjunction with Neustar and LegitScript, active fraud intelligence and surveillance for abusive behaviors in the .health TLD will be implemented as a matter of standard operating procedure and in order to mitigate the potential for .health domain names to be used for the illicit promotion or sale of prescription drugs at the expense of rightsholders. These safeguards will importantly ensure that DotHealth can proactively identify, detect, catalog, and disrupt any malicious activity within the .health TLD.
 
If warranted, DotHealth may take down any .health domains verified to be harboring and⁄or supporting online threats to the .health registry and the broader Internet community of users. This action shuts down all activities associated with the domain name, including all websites. Our philosophy in administering this procedure is that removing threats to the consumer outweighs any potential damage to the registrar⁄registrant relationship. DotHealth will commit to keeping its registrars updated of any malicious activity within the .health TLD through weekly or monthly reporting. We will also leverage our back-end provider’s existing relationships with international law enforcement agencies as necessary and in support of these procedures.

Procedures for Resolving Multiple Requests for Top Level Names
Procedures for resolving requests and limiting unqualified registrations of trademarked names will be implemented in the Sunrise period and on an ongoing basis through notification services in conjunction with the Trademark Clearinghouse. 

Other reserved names for which it is envisioned that multiple applications may be requested shall be sold in conjunction with third-party domain name auction services or brokers as authorized or organized by DotHealth at its own discretion. In support of our enterprise commitment to improving the quality of online health information, we also plan to administer a Request for Information (RFI) Process for select reserved .health names to ensure their trusted and meaningful use among registrants and end-users, and to help promote awareness, usage and uptake of the .health gTLD. All policies and procedures as described herein with respect to reserved names have been developed in accordance with the ICANN New gTLD Registry Agreement and specifically Provision 2.6 as it is currently published and available.

Registry Pricing Policies 

Wholesale Price Stability
With respect to cost benefits for registrants, DotHealth intends to maintain its introductory wholesale pricing model for registrars for the first three (3) years of registry operations. By providing a predictable wholesale price, we believe this will simplify efforts among registrars to facilitate and achieve end-customer (registrant) adoption at levels that have been forecasted for the .health registry. 

Price stability will be particularly meaningful to the health sciences rights-holder segmentation that we have identified for .health. As such, even as a matter of making “defensive registration decisions” we felt it would be important to provide some level of predictability for an initial three-year period, which would avoid concerns for pricing as a barrier to .health’s early-stage market adoption. DotHealth anticipates coordinating pricing incentives for bulk registrations from those with larger numbers of names to register. Bulk registrations above a reasonable number of .health domain names from one registrant will be eligible for such discounting incentives through the coordination of our registrar network. Registrants will be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years.

Contractual Commitments
Pursuant to provision 2.10 as contained in the current ICANN New gTLD Registry Agreement, DotHealth will make several contractual commitments to registrants regarding the magnitude of price escalation. We will provide ICANN and each ICANN accredited registrar that has executed the registry-registrar agreement for the .health TLD advance written notice of any price increase of no less than thirty (30) calendar days. With respect to renewal of domain name registrations, DotHealth shall provide ICANN and each ICANN accredited registrar that has executed the registry-registrar agreement for the .health TLD advance written notice of any price increase, including as a result of the elimination of any refunds, rebates, discounts, product tying, Qualified Marketing Programs or other programs (which had the effect of reducing the price charged to registrars) of no less than one hundred eighty (180) calendar days.

Notwithstanding the foregoing, with respect to renewal of domain name registrations, DotHealth will provide at least thirty (30) calendar days notice of any price increase if the resulting price is less than or equal to (A) for the period beginning on the Effective Date and ending twelve (12) months following the Effective Date, the initial price charged for registrations in the .health TLD, or (B) for subsequent periods, a price for which DotHealth provided a notice within the twelve (12) month period preceding the effective date of the proposed price increase.

DotHealth shall offer registrars the option to obtain domain name registration renewals at the current price (i.e. the price in place prior to any noticed increase) for periods of one to ten years at the discretion of the registrar, but no greater than ten years. In addition, DotHealth will maintain uniform pricing for renewals of domain name registrations, for which the price for each domain registration renewal must be identical to the price of all other domain name registration renewals in place at the time of such renewal. Such price must take into account universal application of any refunds, rebates, discounts, product tying or other programs in place at the time of renewal. 

DotHealth will make available to registrars Qualified Marketing Programs in which discounted renewal pricing will be offered for up to one hundred eighty (180) calendar days. All ICANN accredited registrars for the .health TLD will be provided the same opportunity to qualify for such discounted Renewal Pricing. These programs will not to exclude any particular class or classes of registrations or increase the renewal price of any particular classes of registrations.

For complete transparency, DotHealth will provide public query-based DNS lookup service for the TLD at its sole expense.

No

Not Available

No

DotHealth, LLC (ʺDotHealthʺ) believes that in countries and territories throughout the world, health authorities will value the .health TLD as an appropriate resource that can be used to inform citizens and other stakeholders about public health policies and strategies. 

In preparation for answering this question, DotHealthreviewed the following relevant background material regarding the protection of geographic names in the DNS, including: 

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

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

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

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

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

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

-The short form (in English) of all country and territory names contained on the ISO 3166- 1 list, as updated from time to time, including the European Union, which is exceptionally reserved on the ISO 3166-1 list, and its scope extended in August 1999 to any application needing to represent the name European Union (see http:⁄⁄www.iso.org⁄iso⁄support⁄country_codes⁄iso_3166_code_lists⁄iso-3166-1_decoding_table.htm#EU);
-The United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardization of Geographical Names, Part III Names of Countries of the World; and
-The list of United Nations member states in six official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names.
Potential Allocation and Future Release of Names

During its Sunrise period, DotHealth will implement an outreach campaign targeting senior leadership representing health ministries and⁄or government agencies in each Country or Territory to inform them about .health and to facilitate the responsible release of names as previously described. Ministers of Health as identified and verified by the U.S. Food and Drug Administration (FDA) will be established as the primary point of contact for each Country or Territory. For reference, these can be accessed at the FDA’s web site featuring International Organizations and Foreign Government Agencies at http:⁄⁄www.fda.gov⁄InternationalPrograms⁄Agreements⁄ucm131179.htm. 

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

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

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

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

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

〈MALDIVIAN.AERO〉 - Is the dominant domestic air carrier in Maldives, and provides a range of commercial and leisure air transport services.
The more likely request by DotHealth will come in connection with the un-reservation and allocation of two-letter .health domain names, e.g. 95.health, 12.health, etc. If DotHealth should decide in the future to attempt and allocate these domain names, it would submit the proper Registry Service Evaluation Processes (RSEP) with ICANN. In evaluating similar RSEP requests that have been submitted to ICANN by other gTLD registry operators, DotHealth believes that its request would be favorably granted.

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

23.1 Introduction 

DotHealth, LLC (“DotHealth”) has elected to partner with Neustar, Inc. to provide back-end services for the .health TLD registry. In making this decision, DotHealth recognized that Neustar already possesses a production-proven registry system that can be quickly deployed and smoothly operated over its robust, flexible, and scalable world-class infrastructure The existing registry services will be leveraged for the .health TLD registry. The following section describes the registry services to be provided.

23.2 Standard Technical and Business Components
Neustar will provide the highest level of service while delivering a secure, stable and comprehensive registry platform. DotHealth will use Neustar’s Registry Services platform to deploy the .health registry, by providing the following Registry Services (none of these services are offered in a manner that is unique to .health: 

• Registry-Registrar Shared Registration Service (SRS)
• Extensible Provisioning Protocol (EPP)
• Domain Name System (DNS)
• WHOIS
• DNSSEC
• Data Escrow
• Dissemination of Zone Files using Dynamic Updates
• Access to Bulk Zone Files
• Dynamic WHOIS Updates
• IPv6 Support
• Rights Protection Mechanisms
• Internationalized Domain Names (IDN). [Optional – should be deleted if not being offered].

The following is a description of each of the services. 

SRS 
Neustar’s secure and stable SRS is a production-proven, standards-based, highly reliable, and high-performance domain name registration and management system. The SRS includes an EPP interface for receiving data from registrars for the purpose of provisioning and managing domain names and name servers. The response to Question 24 provides specific SRS information. 

EPP
The .health registry will use the Extensible Provisioning Protocol (EPP) for the provisioning of domain names. The EPP implementation will be fully compliant with all RFCs. Registrars are provided with access via an EPP API and an EPP based Web GUI. With more than 10 gTLD, ccTLD, and private TLDs implementations, Neustar has extensive experience building EPP-based registries. Additional discussion on the EPP approach is presented in the response to Question 25.

DNS
DotHealth will leverage Neustar’s world-class DNS network of geographically distributed nameserver sites to provide the highest level of DNS service. The service utilizes “Anycast” routing technology, and supports both IPv4 and IPv6. The DNS network is highly proven, and currently provides service to over 20 TLDs and thousands of enterprise companies. Additional information on the DNS solution is presented in the response to Questions 35.

WHOIS
Neustar’s existing standard WHOIS solution will be used for the .health. The service provides supports for near real-time dynamic updates. The design and construction is agnostic with regard to data display policy is flexible enough to accommodate any data model. In addition, a searchable WHOIS service that complies with all ICANN requirements will be provided. The following WHOIS options will be provided:
Standard WHOIS (Port 43)
Standard WHOIS (Web)
Searchable WHOIS (Web)

DNSSEC
An RFC compliant DNSSEC implementation will be provided using existing DNSSEC capabilities. Neustar is an experienced provider of DNSSEC services, and currently manages signed zones for three large top level domains: .biz, .us, and .co. Registrars are provided with the ability to submit and manage DS records using EPP, or through a web GUI. Additional information on DNSSEC, including the management of security extensions is found in the response to Question 43.

Data Escrow
Data escrow will be performed in compliance with all ICANN requirements in conjunction with an approved data escrow provider. The data escrow service will:

• Protect against data loss
• Follow industry best practices
• Ensure easy, accurate, and timely retrieval and restore capability in the event of a hardware failure
• Minimizes the impact of software or business failure.

Additional information on the Data Escrow service is provided in the response to Question 38.

Dissemination of Zone Files using Dynamic Updates
Dissemination of zone files will be provided through a dynamic, near real-time process. Updates will be performed within the specified performance levels. The proven technology ensures that updates pushed to all nodes within a few minutes of the changes being received by the SRS. Additional information on the DNS updates may be found in the response to Question 35.

Access to Bulk Zone Files
DotHealth will provide third party access to the bulk zone file in accordance with specification 4, Section 2 of the Registry Agreement. Credentialing and dissemination of the zone files will be facilitated through the Central Zone Data Access Provider.

Dynamic WHOIS Updates
Updates to records in the WHOIS database will be provided via dynamic, near real-time updates. Guaranteed delivery message oriented middleware is used to ensure each individual WHOIS server is refreshed with dynamic updates. This component ensures that all WHOIS servers are kept current as changes occur in the SRS, while also decoupling WHOIS from the SRS. Additional information on WHOIS updates is presented in response to Question 26.

IPv6 Support
The .health registry will provide IPv6 support in the following registry services: SRS, WHOIS, and DNS⁄DNSSEC. In addition, the registry supports the provisioning of IPv6 AAAA records. A detailed description on IPv6 is presented in the response to Question 36.
Required Rights Protection Mechanisms

DotHealth, will provide all ICANN required Rights Mechanisms, including: 
• Trademark Claims Service
• Trademark Post-Delegation Dispute Resolution Procedure (PDDRP)
• Registration Restriction Dispute Resolution Procedure (RRDRP)
• UDRP
• URS
• Sunrise service.

More information is presented in the response to Question 29.
Internationalized Domain Names (IDN)

IDN registrations are provided in full compliance with the IDNA protocol. Neustar possesses extensive experience offering IDN registrations in numerous TLDs, and its IDN implementation uses advanced technology to accommodate the unique bundling needs of certain languages. Character mappings are easily constructed to block out characters that may be deemed as confusing to users. A detailed description of the IDN implementation is presented in response to Question 44.

23.3 Unique Services 
DotHealth will not be offering services that are unique to .health.

23.4 Security or Stability Concerns 
All services offered are standard registry services that have no known security or stability concerns. Neustar has demonstrated a strong track record of security and stability within the industry. 

24.1 Introduction

DotHealth, LLC (“DotHealth”) has partnered with Neustar, Inc, an experienced TLD registry operator, for the operation of the .health Registry. The applicant is confident that the plan in place for the operation of a robust and reliable Shared Registration System (SRS) as currently provided by Neustar will satisfy the criterion established by ICANN.
Neustar built its SRS from the ground up as an EPP based platform and has been operating it reliably and at scale since 2001. The software currently provides registry services to five TLDs (.BIZ, .US, TEL, .CO and .TRAVEL) and is used to provide gateway services to the .CN and .TW registries. Neustar’s state of the art registry has a proven track record of being secure, stable, and robust. It manages more than 6 million domains, and has over 300 registrars connected today. 

The following describes a detailed plan for a robust and reliable SRS that meets all ICANN requirements including compliance with Specifications 6 and 10.

24.2 The Plan for Operation of a Robust and Reliable SRS

High-level SRS System Description
The SRS to be used for .health will leverage a production-proven, standards-based, highly reliable and high-performance domain name registration and management system that fully meets or exceeds the requirements as identified in the new gTLD Application Guidebook. The SRS is the central component of any registry implementation and its quality, reliability and capabilities are essential to the overall stability of the TLD. Neustar has a documented history of deploying SRS implementations with proven and verifiable performance, reliability and availability. The SRS adheres to all industry standards and protocols. By leveraging an existing SRS platform, DotHealth is mitigating the significant risks and costs associated with the development of a new system. Highlights of the SRS include:

• State-of-the-art, production proven multi-layer design
• Ability to rapidly and easily scale from low to high volume as a TLD grows
• Fully redundant architecture at two sites
• Support for IDN registrations in compliance with all standards 
• Use by over 300 Registrars
• EPP connectivity over IPv6
• Performance being measured using 100% of all production transactions (not sampling).
 
SRS Systems, Software, Hardware, and Interoperability 
The systems and software that the registry operates on are a critical element to providing a high quality of service. If the systems are of poor quality, if they are difficult to maintain and operate, or if the registry personnel are unfamiliar with them, the registry will be prone to outages. Neustar has a decade of experience operating registry infrastructure to extremely high service level requirements. The infrastructure is designed using best of breed systems and software. Much of the application software that performs registry-specific operations was developed by the current engineering team and a result the team is intimately familiar with its operations. The architecture is highly scalable and provides the same high level of availability and performance as volumes increase. It combines load balancing technology with scalable server technology to provide a cost effective and efficient method for scaling.The Registry is able to limit the ability of any one registrar from adversely impacting other registrars by consuming too many resources due to excessive EPP transactions. The system uses network layer 2 level packet shaping to limit the number of simultaneous connections registrars can open to the protocol layer.

All interaction with the Registry is recorded in log files. Log files are generated at each layer of the system. These log files record at a minimum:

• The IP address of the client
• Timestamp
• Transaction Details
• Processing Time.

In addition to logging of each and every transaction with the SRS Neustar maintains audit records, in the database, of all transformational transactions. These audit records allow the Registry, in support of the applicant, to produce a complete history of changes for any domain name.

SRS Design
The SRS incorporates a multi-layer architecture that is designed to mitigate risks and easily scale as volumes increase. The three layers of the SRS are:

• Protocol Layer
• Business Policy Layer
• Database. 

Each of the layers is described below. 

Protocol Layer
The first layer is the protocol layer, which includes the EPP interface to registrars. It consists of a high availability farm of load-balanced EPP servers. The servers are designed to be fast processors of transactions. The servers perform basic validations and then feed information to the business policy engines as described below. The protocol layer is horizontally scalable as dictated by volume.

The EPP servers authenticate against a series of security controls before granting service, as follows:

• The registrar’s host exchanges keys to initiates a TLS handshake session with the EPP server.
• The registrar’s host must provide credentials to determine proper access levels.
• The registrar’s IP address must be preregistered in the network firewalls and traffic-shapers.

Business Policy Layer 
The Business Policy Layer is the “brain” of the registry system. Within this layer, the policy engine servers perform rules-based processing as defined through configurable attributes. This process takes individual transactions, applies various validation and policy rules, persists data and dispatches notification through the central database in order to publish to various external systems. External systems fed by the Business Policy Layer include backend processes such as dynamic update of DNS, WHOIS and Billing. Similar to the EPP protocol farm, the SRS consists of a farm of application servers within this layer. This design ensures that there is sufficient capacity to process every transaction in a manner that meets or exceeds all service level requirements. Some registries couple the business logic layer directly in the protocol layer or within the database. This architecture limits the ability to scale the registry. Using a decoupled architecture enables the load to be distributed among farms of inexpensive servers that can be scaled up or down as demand changes.
The SRS today processes over 30 million EPP transactions daily. 

Database
The database is the third core components of the SRS. The primary function of the SRS database is to provide highly reliable, persistent storage for all registry information required for domain registration services. The database is highly secure, with access limited to transactions from authenticated registrars, trusted application-server processes, and highly restricted access by the registry database administrators. A full description of the database can be found in response to Question 33.
Figure 24-1 depicts the overall SRS architecture including network components.
  
Number of Servers
As depicted in the SRS architecture diagram above Neustar operates a high availability architecture where at each level of the stack there are no single points of failures. Each of the network level devices run with dual pairs as do the databases. For the .health registry, the SRS will operate with 8 protocol servers and 6 policy engine servers. These expand horizontally as volume increases due to additional TLDs, increased load, and through organic growth. In addition to the SRS servers described above, there are multiple backend servers for services such as DNS and WHOIS. These are discussed in detail within those respective response sections. 

Description of Interconnectivity with Other Registry Systems
The core SRS service interfaces with other external systems via Neustar’s external systems layer. The services that the SRS interfaces with include:

• WHOIS 
• DNS 
• Billing
• Data Warehouse (Reporting and Data Escrow). 

Other external interfaces may be deployed to meet the unique needs of a TLD. At this time there are no additional interfaces planned for .health.

The SRS includes an “external notifier” concept in its business policy engine as a message dispatcher. This design allows time-consuming backend processing to be decoupled from critical online registrar transactions. Using an external notifier solution, the registry can utilize “control levers” that allow it to tune or to disable processes to ensure optimal performance at all times. For example, during the early minutes of a TLD launch, when unusually high volumes of transactions are expected, the registry can elect to suspend processing of one or more back end systems in order to ensure that greater processing power is available to handle the increased load requirements. This proven architecture has been used with numerous TLD launches, some of which have involved the processing of over tens of millions of transactions in the opening hours. 

The following are the standard three external notifiers used the SRS: 

WHOIS External Notifier
The WHOIS external notifier dispatches a work item for any EPP transaction that may potentially have an impact on WHOIS. It is important to note that, while the WHOIS external notifier feeds the WHOIS system, it intentionally does not have visibility into the actual contents of the WHOIS system. The WHOIS external notifier serves just as a tool to send a signal to the WHOIS system that a change is ready to occur. The WHOIS system possesses the intelligence and data visibility to know exactly what needs to change in WHOIS. See response to Question 26 for greater detail.

DNS External Notifier
The DNS external notifier dispatches a work item for any EPP transaction that may potentially have an impact on DNS. Like the WHOIS external notifier, the DNS external notifier does not have visibility into the actual contents of the DNS zones. The work items that are generated by the notifier indicate to the dynamic DNS update sub-system that a change occurred that may impact DNS. That DNS system has the ability to decide what actual changes must be propagated out to the DNS constellation. See response to Question 35 for greater detail.

Billing External Notifier
The billing external notifier is responsible for sending all billable transactions to the downstream financial systems for billing and collection. This external notifier contains the necessary logic to determine what types of transactions are billable. The financial systems use this information to apply appropriate debits and credits based on registrar.

Data Warehouse
The data warehouse is responsible for managing reporting services, including registrar reports, business intelligence dashboards, and the processing of data escrow files. The Reporting Database is used to create both internal and external reports, primarily to support registrar billing and contractual reporting requirement. The data warehouse databases are updated on a daily basis with full copies of the production SRS data. 

Frequency of Synchronization between Servers
The external notifiers discussed above perform updates in near real-time, well within the prescribed service level requirements. As transactions from registrars update the core SRS, update notifications are pushed to the external systems such as DNS and WHOIS. These updates are typically live in the external system within 2-3 minutes.

Synchronization Scheme (e.g., hot standby, cold standby) 
Neustar operates two hot databases within the data center that is operating in primary mode. These two databases are kept in sync via synchronous replication. Additionally, there are two databases in the secondary data center. These databases are updated real time through asynchronous replication. This model allows for high performance while also ensuring protection of data. See response to Question 33 for greater detail. 

Compliance with Specification 6 Section 1.2
The SRS implementation for .health is fully compliant with Specification 6, including section 1.2. EPP Standards are described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. Extensible Provisioning Protocol or EPP is defined by a core set of RFCs that standardize the interface that make up the registry-registrar model. The SRS interface supports EPP 1.0 as defined in the following RFCs shown in Table 24-1. 
 
Additional information on the EPP implementation and compliance with RFCs can be found in the response to Question 25.

Compliance with Specification 10
Specification 10 of the New TLD Agreement defines the performance specifications of the TLD, including service level requirements related to DNS, RDDS (WHOIS), and EPP. The requirements include both availability and transaction response time measurements. As an experienced registry operator, Neustar has a long and verifiable track record of providing registry services that consistently exceed the performance specifications stipulated in ICANN agreements. This same high level of service will be provided for the .health Registry. The following section describes Neustar’s experience and its capabilities to meet the requirements in the new agreement.

To properly measure the technical performance and progress of TLDs, Neustar collects data on key essential operating metrics. These measurements are key indicators of the performance and health of the registry. Neustar’s current .biz SLA commitments are among the most stringent in the industry today, and exceed the requirements for new TLDs. Table 24-2 compares the current SRS performance levels compared to the requirements for new TLDs, and clearly demonstrates the ability of the SRS to exceed those requirements.Their ability to commit and meet such high performance standards is a direct result of their philosophy towards operational excellence. See response to Question 31 for a full description of their philosophy for building and managing for performance.

24.3 Resourcing Plans 
The development, customization, and on-going support of the SRS are the responsibility of a combination of technical and operational teams, including:

• Development⁄Engineering
• Database Administration
• Systems Administration
• Network Engineering.

Additionally, if customization or modifications are required, the Product Management and Quality Assurance teams will be involved in the design and testing. Finally, the Network Operations and Information Security play an important role in ensuring the systems involved are operating securely and reliably.

The necessary resources will be pulled from the pool of operational resources described in detail in the response to Question 31. Neustar’s SRS implementation is very mature, and has been in production for over 10 years. As such, very little new development related to the SRS will be required for the implementation of the .health registry. The following resources are available from those teams:

Development⁄Engineering – 19 employees
Database Administration- 10 employees
Systems Administration – 24 employees
Network Engineering – 5 employees

The resources are more than adequate to support the SRS needs of all the TLDs operated by Neustar, including the .health registry. 

25.1 Introduction

DotHealth’s back-end registry operator, Neustar, has over 10 years of experience operating EPP based registries. They deployed one of the first EPP registries in 2001 with the launch of .biz. In 2004, they were the first gTLD to implement EPP 1.0. Over the last ten years Neustar has implemented numerous extensions to meet various unique TLD requirements. Neustar will leverage its extensive experience to ensure DotHealth is provided with an unparalleled EPP based registry. The following discussion explains the EPP interface which will be used for the .health registry. This interface exists within the protocol farm layer as described in Question 24 and is depicted in Figure 25-1.
 
25.2 EPP Interface

Registrars are provided with two different interfaces for interacting with the registry. Both are EPP based, and both contain all the functionality necessary to provision and manage domain names. The primary mechanism is an EPP interface to connect directly with the registry. This is the interface registrars will use for most of their interactions with the registry. 
However, an alternative web GUI (Registry Administration Tool) that can also be used to perform EPP transactions will be provided. The primary use of the Registry Administration Tool is for performing administrative or customer support tasks. 

The main features of the EPP implementation are: 

• Standards Compliance: The EPP XML interface is compliant to the EPP RFCs. As future EPP RFCs are published or existing RFCs are updated, Neustar makes changes to the implementation keeping in mind of any backward compatibility issues.
• Scalability: The system is deployed keeping in mind that it may be required to grow and shrink the footprint of the Registry system for a particular TLD. 
• Fault-tolerance: The EPP servers are deployed in two geographically separate data centers to provide for quick failover capability in case of a major outage in a particular data center. The EPP servers adhere to strict availability requirements defined in the SLAs.
• Configurability: The EPP extensions are built in a way that they can be easily configured to turn on or off for a particular TLD.
• Extensibility: The software is built ground up using object oriented design. This allows for easy extensibility of the software without risking the possibility of the change rippling through the whole application. 
• Auditable: The system stores detailed information about EPP transactions from provisioning to DNS and WHOIS publishing. In case of a dispute regarding a name registration, the Registry can provide comprehensive audit information on EPP transactions.
• Security: The system provides IP address based access control, client credential-based authorization test, digital certificate exchange, and connection limiting to the protocol layer. 

25.3 Compliance with RFCs and Specifications

The registry-registrar model is described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. As shown in Table 25-1, EPP is defined by the core set of RFCs that standardize the interface that registrars use to provision domains with the SRS. As a core component of the SRS architecture, the implementation is fully compliant with all EPP RFCs. Neustar ensures compliance with all RFCs through a variety of processes and procedures. Members from the engineering and standards teams actively monitor and participate in the development of RFCs that impact the registry services, including those related to EPP. When new RFCs are introduced or existing ones are updated, the team performs a full compliance review of each system impacted by the change. Furthermore, all code releases include a full regression test that includes specific test cases to verify RFC compliance.

Neustar has a long history of providing exceptional service that exceeds all performance specifications. The SRS and EPP interface have been designed to exceed the EPP specifications defined in Specification 10 of the Registry Agreement and profiled in Table 25-2. Evidence of Neustar’s ability to perform at these levels can be found in the .biz monthly progress reports found on the ICANN website.
 
EPP Toolkits
Toolkits, under open source licensing, are freely provided to registrars for interfacing with the SRS. Both Java and C++ toolkits will be provided, along with the accompanying documentation. The Registrar Tool Kit (RTK) is a software development kit (SDK) that supports the development of a registrar software system for registering domain names in the registry using EPP. The SDK consists of software and documentation as described below.

The software consists of working Java and C++ EPP common APIs and samples that implement the EPP core functions and EPP extensions used to communicate between the registry and registrar. The RTK illustrates how XML requests (registration events) can be assembled and forwarded to the registry for processing. The software provides the registrar with the basis for a reference implementation that conforms to the EPP registry-registrar protocol. The software component of the SDK also includes XML schema definition files for all Registry EPP objects and EPP object extensions. The RTK also includes a “dummy” server to aid in the testing of EPP clients.

The accompanying documentation describes the EPP software package hierarchy, the object data model, and the defined objects and methods (including calling parameter lists and expected response behavior). New versions of the RTK are made available from time to time to provide support for additional features as they become available and support for other platforms and languages.

25.3 Proprietary EPP Extensions
The .health registry will not include proprietary EPP extensions. Neustar has implemented various EPP extensions for both internal and external use in other TLD registries. These extensions use the standard EPP extension framework described in RFC 5730. Table 25-3 provides a list of extensions developed for other TLDs. Should the .health registry require an EPP extension at some point in the future, the extension will be implemented in compliance with all RFC specifications including RFC 3735.
 
The full EPP schema to be used in the .health registry is attached in the document titled “EPP Schema.”

25.4 Resourcing Plans
The development and support of EPP is largely the responsibility of the Development⁄Engineering and Quality Assurance teams. As an experience registry operator with a fully developed EPP solution, on-going support is largely limited to periodic updates to the standard and the implementation of TLD specific extensions.

The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:
Development⁄Engineering – 19 employees
Quality Assurance - 7 employees.

These resources are more than adequate to support any EPP modification needs of the .health registry.

26.1 Introduction

For the .health TLD, DotHealth, LLC (“DotHealth”) recognizes the importance of an accurate, reliable, and up-to-date WHOIS database to governments, law enforcement, intellectual property holders and the public as a whole and is firmly committed to complying with all of the applicable WHOIS specifications for data objects, bulk access, and lookups as defined in Specifications 4 and 10 to the Registry Agreement. DotHealth’s back-end registry services provider, Neustar, has extensive experience providing ICANN and RFC-compliant WHOIS services for each of the TLDs that it operates both as a Registry Operator for gTLDs, ccTLDs and back-end registry services provider. As one of the first “thick” registry operators in the gTLD space, Neustar’s WHOIS service has been designed from the ground up to display as much information as required by the .health TLD and respond to a very stringent availability and performance requirement.

Some of the key features of .health TLD’s solution include: 

• Fully compliant with all relevant RFCs including 3912
• Production proven, highly flexible, and scalable with a track record of 100% availability over the past 10 years
• Exceeds current and proposed performance specifications 
• Supports dynamic updates with the capability of doing bulk updates 
• Geographically distributed sites to provide greater stability and performance
• In addition, .health’s thick-WHOIS solution also provides for additional search capabilities and mechanisms to mitigate potential forms of abuse as discussed below. (e.g., IDN, registrant data).

26.2 Software Components

The WHOIS architecture comprises the following components:

• An in-memory database local to each WHOIS node: To provide for the performance needs, the WHOIS data is served from an in-memory database indexed by searchable keys. 
• Redundant servers: To provide for redundancy, the WHOIS updates are propagated to a cluster of WHOIS servers that maintain an independent copy of the database. 
• Attack resistant: To ensure that the WHOIS system cannot be abused using malicious queries or DOS attacks, the WHOIS server is only allowed to query the local database and rate limits on queries based on IPs and IP ranges can be readily applied.
• Accuracy auditor: To ensure the accuracy of the information served by the WHOIS servers, a daily audit is done between the SRS information and the WHOIS responses for the domain names which are updated during the last 24-hour period. Any discrepancies are resolved proactively.
• Modular design: The WHOIS system allows for filtering and translation of data elements between the SRS and the WHOIS database to allow for customizations.
• Scalable architecture: The WHOIS system is scalable and has a very small footprint. Depending on the query volume, the deployment size can grow and shrink quickly.
• Flexible: It is flexible enough to accommodate thin, thick, or modified thick models and can accommodate any future ICANN policy, such as different information display levels based on user categorization.
• SRS master database: The SRS database is the main persistent store of the Registry information. The Update Agent computes what WHOIS updates need to be pushed out. A publish-subscribe mechanism then takes these incremental updates and pushes to all the WHOIS slaves that answer queries.

26.3 Compliance with RFC and Specifications 4 and 10
Neustar has been running thick-WHOIS Services for over 10+ years in full compliance with RFC 3912 and with Specifications 4 and 10 of the Registry Agreement.RFC 3912 is a simple text based protocol over TCP that describes the interaction between the server and client on port 43. Neustar built a home-grown solution for this service. It processes millions of WHOIS queries per day.
Table 26-1 describes Neustar’s compliance with Specifications 4 and 10.
 
Neustar ensures compliance with all RFCs through a variety of processes and procedures. Members from the engineering and standards teams actively monitor and participate in the development of RFCs that impact the registry services, including those related to WHOIS. When new RFCs are introduced or existing ones are updated, the team performs a full compliance review of each system impacted by the change. Furthermore, all code releases include a full regression test that includes specific test cases to verify RFC compliance.

26.4 High-level WHOIS System Description

26.4.1 WHOIS Service (port 43)
The WHOIS service is responsible for handling port 43 queries. Our WHOIS is optimized for speed using an in-memory database and master-slave architecture between the SRS and WHOIS slaves.
The WHOIS service also has built-in support for IDN. If the domain name being queried is an IDN, the returned results include the language of the domain name, the domain name’s UTF-8 encoded representation along with the Unicode code page.

26.4.2 Web Page for WHOIS queries
In addition to the WHOIS Service on port 43, Neustar provides a web based WHOIS application (www.whois..health). It is an intuitive and easy to use application for the general public to use. WHOIS web application provides all of the features available in the port 43 WHOIS. This includes full and partial search on:

• Domain names
• Nameservers
• Registrant, Technical and Administrative Contacts
• Registrars

It also provides features not available on the port 43 service. These include:

1. Redemption Grace Period calculation: Based on the registry’s policy, domains in pendingDelete can be restorable or scheduled for release depending on the date⁄time the domain went into pendingDelete. 
For these domains, the web based WHOIS displays “Restorable” or “Scheduled for Release” to clearly show this additional status to the user.

2. Extensive support for international domain names (IDN)

3. Ability to perform WHOIS lookups on the actual Unicode IDN

4. Display of the actual Unicode IDN in addition to the ACE-encoded name

5. A Unicode to Punycode and Punycode to Unicode translator

6. An extensive FAQ

7. A list of upcoming domain deletions

26.5 IT and Infrastructure Resources
As described above the WHOIS architecture uses a workflow that decouples the update process from the SRS. This ensures SRS performance is not adversely affected by the load requirements of dynamic updates. It is also decoupled from the WHOIS lookup agent to ensure the WHOIS service is always available and performing well for users. Each of Neustar’s geographically diverse WHOIS sites use:

• Firewalls, to protect this sensitive data 
• Dedicated servers for MQ Series, to ensure guaranteed delivery of WHOIS updates 
• Packetshaper for source IP address-based bandwidth limiting 
• Load balancers to distribute query load 
• Multiple WHOIS servers for maximizing the performance of WHOIS service.

The WHOIS service uses HP BL 460C servers, each with 2 X Quad Core CPU and a 64GB of RAM. The existing infrastructure has 6 servers, but is designed to be easily scaled with additional servers should it be needed.
Figure 26-1 depicts the different components of the WHOIS architecture.

 
26.6 Interconnectivity with Other Registry System
As described in Question 24 about the SRS and further in response to Question 31, “Technical Overview”, when an update is made by a registrar that impacts WHOIS data, a trigger is sent to the WHOIS system by the external notifier layer. The update agent processes these updates, transforms the data if necessary and then uses messaging oriented middleware to publish all updates to each WHOIS slave. The local update agent accepts the update and applies it to the local in-memory database. A separate auditor compares the data in WHOIS and the SRS daily and monthly to ensure accuracy of the published data.

26.7 Frequency of Synchronization between Servers
Updates from the SRS, through the external notifiers, to the constellation of independent WHOIS slaves happens in real-time via an asynchronous publish⁄subscribe messaging architecture. The updates are guaranteed to be updated in each slave within the required SLA of 95% ≤ 60 minutes. Please note that Neustar’s current architecture is built towards the stricter SLAs (95% ≤ 15 minutes) of .BIZ. The vast majority of updates tend to happen within 2-3 minutes.

26.8 Provision for Searchable WHOIS Capabilities
Neustar will create a new web-based service to address the new search features based on requirements specified in Specification 4 Section 1.8. The application will enable users to search the WHOIS directory using any one or more of the following fields: 

• Domain name
• Registrar ID
• Contacts and registrant’s name
• Contact and registrant’s postal address, including all the sub-fields described in EPP (e.g., street, city, state or province, etc.)
• The system will also allow search using non-Latin character sets which are compliant with IDNA specification.

The user will choose one or more search criteria, combine them by Boolean operators (AND, OR, NOT) and provide partial or exact match regular expressions for each of the criterion name-value pairs. The domain names matching the search criteria will be returned to the user.

Figure 26-2 shows an architectural depiction of the new service. 

To mitigate the risk of this powerful search service being abused by unscrupulous data miners, a layer of security will be built around the query engine which will allow the registry to identify rogue activities and then take appropriate measures. Potential abuses include, but are not limited to:

• Data Mining
• Unauthorized Access
• Excessive Querying
• Denial of Service Attacks

To mitigate the abuses noted above, Neustar will implement any or all of these mechanisms as appropriate:

• Username-password based authentication 
• Certificate based authentication
• Data encryption
• CAPTCHA mechanism to prevent robo invocation of Web query
• Fee-based advanced query capabilities for premium customers.

The searchable WHOIS application will adhere to all privacy laws and policies of the .health registry.

26.9 Resourcing Plans 
As with the SRS, the development, customization, and on-going support of the WHOIS service is the responsibility of a combination of technical and operational teams. The primary groups responsible for managing the service include:

• Development⁄Engineering – 19 employees
• Database Administration – 10 employees
• Systems Administration – 24 employees
• Network Engineering – 5 employees 

Additionally, if customization or modifications are required, the Product Management and Quality Assurance teams will also be involved. Finally, the Network Operations and Information Security play an important role in ensuring the systems involved are operating securely and reliably. The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. Neustar’s WHOIS implementation is very mature, and has been in production for over 10 years. As such, very little new development will be required to support the implementation of the .health registry. The resources are more than adequate to support the WHOIS needs of all the TLDs operated by Neustar, including the .health registry. 

27.1 Registration Life Cycle

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

Domain Lifecycle - Description

The registry will use the EPP 1.0 standard for provisioning domain names, contacts and hosts. Each domain record is comprised of three registry object types: domain, contacts, and hosts 

Domains, contacts and hosts may be assigned various EPP defined statuses indicating either a particular state or restriction placed on the object. Some statuses may be applied by the Registrar; other statuses may only be applied by the Registry. Statuses are an integral part of the domain lifecycle and serve the dual purpose of indicating the particular state of the domain and indicating any restrictions placed on the domain. The EPP standard defines 17 statuses, however only 14 of these statuses will be used in the .health TLD registry per the defined .health TLD business rules.

The following is a brief description of each of the statuses. Server statuses may only be applied by the Registry, and client statuses may be applied by the Registrar.

• OK – Default status applied by the Registry.
• Inactive – Default status applied by the Registry if the domain has less than 2 nameservers.
• PendingCreate – Status applied by the Registry upon processing a successful Create command, and indicates further action is pending. This status will not be used in the .health TLD registry.
• PendingTransfer – Status applied by the Registry upon processing a successful Transfer request command, and indicates further action is pending.
• PendingDelete – Status applied by the Registry upon processing a successful Delete command that does not result in the immediate deletion of the domain, and indicates further action is pending.
• PendingRenew – Status applied by the Registry upon processing a successful Renew command that does not result in the immediate renewal of the domain, and indicates further action is pending. This status will not be used in the .health TLD registry.
• PendingUpdate – Status applied by the Registry if an additional action is expected to complete the update, and indicates further action is pending. This status will not be used in the .health TLD registry.
• Hold – Removes the domain from the DNS zone.
• UpdateProhibted – Prevents the object from being modified by an Update command.
•TransferProhibted – Prevents the object from being transferred to another Registrar by the Transfer command.
• RenewProhibted – Prevents a domain from being renewed by a Renew command.
• DeleteProhibted – Prevents the object from being deleted by a Delete command. 

The lifecycle of a domain begins with the registration of the domain. All registrations must follow the EPP standard, as well as the specific business rules described in the response to Question 18 above. Upon registration a domain will either be in an active or inactive state. Domains in an active state are delegated and have their delegation information published to the zone. Inactive domains either have no delegation information or their delegation information in not published in the zone. Following the initial registration of a domain, one of five actions may occur during its lifecycle:

• Domain may be updated
• Domain may be deleted, either within or after the add-grace period
• Domain may be renewed at anytime during the term
• Domain may be auto-renewed by the Registry
• Domain may be transferred to another registrar. 

Each of these actions may result in a change in domain state. This is described in more detail in the following section. Every domain must eventually be renewed, auto-renewed, transferred, or deleted. A registrar may apply EPP statuses described above to prevent specific actions such as updates, renewals, transfers, or deletions.

27.1.1 Registration States

Domain Lifecycle – Registration States
As described above the .health TLD registry will implement a standard domain lifecycle found in most gTLD registries today. There are five possible domain states:

• Active 
• Inactive
• Locked
• Pending Transfer
• Pending Delete.

All domains are always in either an Active or Inactive state, and throughout the course of the lifecycle may also be in a Locked, Pending Transfer, and Pending Delete state. Specific conditions such as applied EPP policies and registry business rules will determine whether a domain can be transitioned between states. Additionally, within each state, domains may be subject to various timed events such as grace periods, and notification periods. 

Active State
The active state is the normal state of a domain and indicates that delegation data has been provided and the delegation information is published in the zone. A domain in an Active state may also be in the Locked or 
Pending Transfer states.

Inactive State
The Inactive state indicates that a domain has not been delegated or that the delegation data has not been published to the zone. A domain in an Inactive state may also be in the Locked or Pending Transfer states. By default all domain in the Pending Delete state are also in the Inactive state.

Locked State
The Locked state indicates that certain specified EPP transactions may not be performed to the domain. A domain is considered to be in a Locked state if at least one restriction has been placed on the domain; however up to eight restrictions may be applied simultaneously. Domains in the Locked state will also be in the Active or Inactive, and under certain conditions may also be in the Pending Transfer or Pending Delete states.

Pending Transfer State
The Pending Transfer state indicates a condition in which there has been a request to transfer the domain from one registrar to another. The domain is placed in the Pending Transfer state for a period of time to allow the current (losing) registrar to approve (ack) or reject (nack) the transfer request. Registrars may only nack requests for reasons specified in the Inter-Registrar Transfer Policy.

Pending Delete State
The Pending Delete State occurs when a Delete command has been sent to the Registry after the first 5 days (120 hours) of registration. The Pending Delete period is 35-days during which the first 30-days the name enters the Redemption Grace Period (RGP) and the last 5-days guarantee that the domain will be purged from the Registry Database and available to public pool for registration on a first come, first serve basis.

27.1.2 Typical Registration Lifecycle Activities

Domain Creation Process
The creation (registration) of domain names is the fundamental registry operation. All other operations are designed to support or compliment a domain creation. The following steps occur when a domain is created. 

1. Contact objects are created in the SRS database. The same contact object may be used for each contact type, or they may all be different. If the contacts already exist in the database this step may be skipped.
2. Nameservers are created in the SRS database. Nameservers are not required to complete the registration process; however any domain with less than 2 name servers will not be resolvable.
3. The domain is created using the each of the objects created in the previous steps. In addition, the term and any client statuses may be assigned at the time of creation.

The actual number of EPP transactions needed to complete the registration of a domain name can be as few as one and as many as 40. The latter assumes seven distinct contacts and 13 nameservers, with Check and Create commands submitted for each object. 

Update Process
Registry objects may be updated (modified) using the EPP Modify operation. The Update transaction updates the attributes of the object. For example, the Update operation on a domain name will only allow the following attributes to be updated:

• Domain statuses
• Registrant ID
• Administrative Contact ID
• Billing Contact ID
• Technical Contact ID
• Nameservers
• AuthInfo
• Additional Registrar provided fields.

The Update operation will not modify the details of the contacts. Rather it may be used to associate a different contact object (using the Contact ID) to the domain name. To update the details of the contact object the Update transaction must be applied to the contact itself. For example, if an existing registrant wished to update the postal address, the Registrar would use the Update command to modify the contact object, and not the domain object. 

Renew Process 
The term of a domain may be extended using the EPP Renew operation. ICANN policy general establishes the maximum term of a domain name to be 10 years, and Neustar recommends not deviating from this policy. A domain may be renewed⁄extended at any point time, even immediately following the initial registration. The only stipulation is that the overall term of the domain name may not exceed 10 years. If a Renew operation is performed with a term value will extend the domain beyond the 10 year limit, the Registry will reject the transaction entirely.

Transfer Process
The EPP Transfer command is used for several domain transfer related operations: 

• Initiate a domain transfer
• Cancel a domain transfer
• Approve a domain transfer
• Reject a domain transfer.

To transfer a domain from one Registrar to another the following process is followed:

1. The gaining (new) Registrar submits a Transfer command, which includes the AuthInfo code of the domain name.
2. If the AuthInfo code is valid and the domain is not in a status that does not allow transfers the domain is placed into pendingTransfer status
3. A poll message notifying the losing Registrar of the pending transfer is sent to the Registrar’s message queue
4. The domain remains in pendingTransfer status for up to 120 hours, or until the losing (current) Registrar Acks (approves) or Nack (rejects) the transfer request
5. If the losing Registrar has not Acked or Nacked the transfer request within the 120 hour timeframe, the Registry auto-approves the transfer
6. The requesting Registrar may cancel the original request up until the transfer has been completed.

A transfer adds an additional year to the term of the domain. In the event that a transfer will cause the domain to exceed the 10 year maximum term, the Registry will add a partial term up to the 10 year limit. Unlike with the Renew operation, the Registry will not reject a transfer operation.

Deletion Process
A domain may be deleted from the SRS using the EPP Delete operation. The Delete operation will result in either the domain being immediately removed from the database or the domain being placed in pendingDelete status. The outcome is dependent on when the domain is deleted. If the domain is deleted within the first five days (120 hours) of registration, the domain is immediately removed from the database. A deletion at any other time will result in the domain being placed in pendingDelete status and entering the Redemption Grace Period (RGP). Additionally, domains that are deleted within five days (120) hours of any billable (add, renew, transfer) transaction may be deleted for credit.

27.1.3 Applicable Time Elements
The following section explains the time elements that are involved. 

Grace Periods
There are six grace periods:

• Add-Delete Grace Period (AGP)
• Renew-Delete Grace Period
• Transfer-Delete Grace Period
• Auto-Renew-Delete Grace Period
• Auto-Renew Grace Period
• Redemption Grace Period (RGP). 

The first four grace periods listed above are designed to provide the Registrar with the ability to cancel a revenue transaction (add, renew, or transfer) within a certain period of time and receive a credit for the original transaction. The following describes each of these grace periods in detail:

Add-Delete Grace Period 
The APG is associated with the date the Domain was registered. Domains may be deleted for credit during the initial 120 hours of a registration, and the Registrar will receive a billing credit for the original registration. If the domain is deleted during the Add Grace Period, the domain is dropped from the database immediately and a credit is applied to the Registrar’s billing account. 

Renew-Delete Grace Period 
The Renew-Delete Grace Period is associated with the date the Domain was renewed. Domains may be deleted for credit during the 120 hours after a renewal. The grace period is intended to allow Registrars to correct domains that were mistakenly renewed. It should be noted that domains that are deleted during the renew grace period will be placed into pendingDelete and will enter the RGP (see below). 

Transfer-Delete Grace Period 
The Transfer-Delete Grace Period is associated with the date the Domain was transferred to another Registrar. Domains may be deleted for credit during the 120 hours after a transfer. It should be noted that domains that are deleted during the renew grace period will be placed into pendingDelete and will enter the RGP. A deletion of domain after a transfer is not the method used to correct a transfer mistake. Domains that have been erroneously transferred or hijacked by another party can be transferred back to the original registrar through various means including contacting the Registry.

Auto-Renew-Delete Grace Period 
The Auto-Renew-Delete Grace Period is associated with the date the Domain was auto-renewed. Domains may be deleted for credit during the 120 hours after an auto-renewal. The grace period is intended to allow Registrars to correct domains that were mistakenly auto-renewed. It should be noted that domains that are deleted during the auto-renew delete grace period will be placed into pendingDelete and will enter the RGP. 

Auto-Renew Grace Period 
The Auto-Renew Grace Period is a special grace period intended to provide registrants with an extra amount of time, beyond the expiration date, to renew their domain name. The grace period lasts for 45 days from the expiration date of the domain name. Registrars are not required to provide registrants with the full 45 days of the period.

Redemption Grace Period 
The RGP is a special grace period that enables Registrars to restore domains that have been inadvertently deleted but are still in pendingDelete status within the Redemption Grace Period. All domains enter the RGP except those deleted during the AGP. The RGP period is 30 days, during which time the domain may be restored using the EPP RenewDomain command as described below. Following the 30day RGP period the domain will remain in pendingDelete status for an additional five days, during which time the domain may NOT be restored. The domain is released from the SRS, at the end of the 5 day non-restore period. A restore fee applies and is detailed in the Billing Section. A renewal fee will be automatically applied for any domain past expiration.Neustar has created a unique restoration process that uses the EPP Renew transaction to restore the domain and fulfill all the reporting obligations required under ICANN policy. The following describes the restoration process.

27.2 State Diagram
Figure 27-1 provides a description of the registration lifecycle. 

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

The details of each trigger are described below:

• Create: Registry receives a create domain EPP command.
• WithNS: The domain has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
• WithOutNS: The domain has not met the minimum number of nameservers required by registry policy. The domain will not be in the DNS zone.
• Remove Nameservers: Domainʹs nameserver(s) is removed as part of an update domain EPP command. The total nameserver is below the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
• Add Nameservers: Nameserver(s) has been added to domain as part of an update domain EPP command. The total number of nameservers has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
• Delete: Registry receives a delete domain EPP command.
• DeleteAfterGrace: Domain deletion does not fall within the add grace period.
• DeleteWithinAddGrace: Domain deletion falls within add grace period.
• Restore: Domain is restored. Domain goes back to its original state prior to the delete command.
• Transfer: Transfer request EPP command is received.
• Transfer Approve⁄Cancel⁄Reject: Transfer requested is approved or cancel or rejected.
• TransferProhibited: The domain is in clientTransferProhibited and⁄or serverTranferProhibited status. This will cause the transfer request to fail. The domain goes back to its original state.
• DeleteProhibited: The domain is in clientDeleteProhibited and⁄or serverDeleteProhibited status. This will cause the delete command to fail. The domain goes back to its original state.

Note: the locked state is not represented as a distinct state on the diagram as a domain may be in a locked state in combination with any of the other states: inactive, active, pending transfer, or pending delete.

27.2.1 EPP RFC Consistency
As described above, the domain lifecycle is determined by ICANN policy and the EPP RFCs. Neustar has been operating ICANN TLDs for the past 10 years consistent and compliant with all the ICANN policies and related EPP RFCs. 

27.3 Resources
The registration lifecycle and associated business rules are largely determined by policy and business requirements; as such the Product Management and Policy teams will play a critical role in working Applicant to determine the precise rules that meet the requirements of the TLD. Implementation of the lifecycle rules will be the responsibility of Development⁄Engineering team, with testing performed by the Quality Assurance team. Neustar’s SRS implementation is very flexible and configurable, and in many case development is not required to support business rule changes. 

The .health TLD registry will be using standard lifecycle rules, and as such no customization is anticipated. However should modifications be required in the future, the necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:

Development⁄Engineering – 19 employees
Registry Product Management – 4 employees

These resources are more than adequate to support the development needs of all the TLDs operated by Neustar, including the .health TLD registry. 

At DotHealth, LLC (“DotHealth”) our mission is to establish .health as a safe, trustworthy and secure top-level domain for global health stakeholders. As part of its enterprise commitment to abuse mitigation, DotHealth will utilize Neustar’s malicious monitoring and cyber-threat mitigation services. As the back-end registry service provider for .health, Neustar is at the forefront of the prevention of such abusive practices and is one of the few registry operators to have actually developed and implemented an active “domain takedown” policy. DotHealth and Neustar will also collaborate with LegitScript, LLC (“LegitScript”) on an exclusive enterprise basis for the .health TLD and in support of its abuse prevention and mitigation approaches. LegitScript is the healthcare industry’s leading provider of online fraud intelligence and monitoring services. 

Numerous policies and procedures have been identified and shall be established and enforced to combat or prevent abusive, malicious or fraudulent activities that have a negative impact on Internet users and registrants. Affirmations of support for these policies and procedures have been secured from numerous global and regional health and wellness industry associations and non-governmental organizations, including the Inter-American College of Physicians, National Association of Boards of Pharmacy (NABP), the World Federation of Chiropractic, the Association of Black Cardiologists and the Regulatory Harmonization Institute which have been described in DotHealth’s response to Question 18 and are affirmed in the attached exhibits.

In active coordination with Neustar and LegitScript, DotHealth will vigilantly monitor the .health namespace for the illicit promotion or sale of prescription drugs, controlled substances, tainted dietary supplements, ingredients for psychoactive highs, and others which are have been validated by regulatory authorities as safety concerns. LegitScript is the only verification and monitoring service for Internet pharmacies recognized by the National Association of Boards of Pharmacy (NABP), the non-profit organization that represents the government agencies that license and regulate pharmacies and pharmacists in the US, Canada, and other jurisdictions. Major search engines and e-commerce providers including Google, Microsoft, Amazon utilize LegitScript’s services to prevent “rogue” Internet pharmacies from operating in violation of applicable laws and regulations. LegitScript also works with multiple Registrars to verify violations of the Registrars’ Terms of Service.

Acceptable Use Policy
DotHealth will adopt and enforce compliance with an Acceptable Use Policy that clearly defines the types of activities that will not be permitted for users of the .health TLD. Each ICANN-Accredited Registrar must agree to pass through the Acceptable Use Policy to its Resellers (if applicable) and ultimately to all .health registrants: 

This Acceptable Use Policy gives the .health registry the ability to quickly lock, cancel, transfer or take ownership of any .health domain name, either temporarily or permanently, if the domain name is being used in a manner that appears to threaten the stability, integrity or security of the Registry, or any of its registrar partners – and⁄or that may put the safety and security of any registrant or user at risk. 
The process also allows the .health registry to take preventive measures to avoid any such criminal or security threats which may be triggered through a variety of channels, including, among other things, private complaint, public alert, government or enforcement agency outreach, and the ongoing monitoring by the Registry or its partners. In all cases, the Registry or its designees will alert Registry’s registrar partners about any identified threats, and will work closely with them to bring offending sites into compliance.

The following activities are subject to compliance with this policy:
• Phishing: the attempt to acquire personally identifiable information by masquerading as a website other than .health.
• Pharming: the redirection of Internet users to websites other than those the user intends to visit, usually through unauthorized changes to the Hosts file on a victim’s computer or DNS records in DNS servers.
• Dissemination of Malware: the intentional creation and distribution of ʺmaliciousʺ software designed to infiltrate a computer system without the owner’s consent, including, without limitation, computer viruses, worms, key loggers, and Trojans.
• Fast Flux Hosting: a technique used to shelter Phishing, Pharming and Malware sites and networks from detection and to frustrate methods employed to defend against such practices, whereby the IP address associated with fraudulent websites are changed rapidly so as to make the true location of the sites difficult to find.
• Botnetting: the development and use of a command, agent, motor, service, or software which is implemented: (1) to remotely control the computer or computer system of an Internet user without their knowledge or consent, (2) to generate direct denial of service (DDOS) attacks.
• Malicious Hacking: the attempt to gain unauthorized access (or exceed the level of authorized access) to a computer, information system, user account or profile, database, or security system.
• Child Pornography: the storage, publication, display and⁄or dissemination of pornographic materials depicting individuals under the age of majority in the relevant jurisdiction.
• Illicit Promotion or Sale of Harmful Substances: the illicit promotion or sale of prescription drugs, controlled substances, tainted dietary supplements, ingredients for psychoactive highs, and others which are have been validated by regulatory authorities as safety concerns. 

The Registry reserves the right, in its sole discretion, to take any administrative and operational actions necessary, including the use of computer forensics and information security technological services, among other things, in order to implement the Acceptable Use Policy. In addition, the Registry reserves the right to deny, cancel or transfer any registration or transaction, or place any domain name(s) on registry lock, hold or similar status, that it deems necessary, in its discretion; (1) to protect the integrity and stability of the registry; (2) to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of Registry as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement or (5) to correct mistakes made by the Registry or any Registrar in connection with a domain name registration. Registry also reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a dispute.

Domain Name Takedown Processes and Procedures
Because domain names are sometimes used as a mechanism to enable various illegitimate activities on the Internet, often the best preventative measure to thwart these attacks is to remove the names completely from the DNS before they can impart harm to unsuspecting Internet users. DotHealth’s back end registry partner, Neustar, is one of only a few registry operators to have actually developed and implemented an active “domain takedown” policy in which the registry itself takes down abusive domain names. Neustar’s approach is quite different from a number of other gTLD Registries and the results have been unmatched. For the .health TLD, Neustar will target verified abusive domain names and remove them within 12 hours regardless of whether or not there is cooperation from the domain name registrar. Given their potentially harmful implications, removing such threats from the consumer outweighs any potential damage to the registrar⁄registrant relationship. Removing the domain name from the zone has the effect of shutting down all activity associated with the domain name, including the use of all websites and e-mail. 

Rapid Takedown Process
DotHealth and Neustar have defined and documented process for taking the necessary action of removing a domain from the zone when its presence in the zone poses a threat to the security and stability of the infrastructure of the Internet or the registry. Since implementing malicious monitoring service-levels, Neustar has developed two basic variations of the process. The more common process variation is a lightweight process that is triggered by “typical” notices. The less-common variation is the full process that is triggered by unusual notices. These notices tend to involve the need for accelerated action by the registry in the event that a complaint is received by Neustar which alleges that a domain name is being used to threaten the stability and security of the .health TLD, or is part of a real-time investigation by law enforcement or security researchers. 

Lightweight Process 
In addition to having an active Information Security group that, on its own initiatives, seeks out abusive practices in the .health TLD, Neustar is an active member in a number of security organizations that have the expertise and experience in receiving and investigating reports of abusive DNS practices, including but not limited to, the Anti-Phishing Working Group, Castle Cops, NSP-SEC, the Registration Infrastructure Safety Group and others. Each of these sources are well-known security organizations that have developed a reputation for the prevention of harmful agents affecting the Internet. Aside from these organizations, Neustar also actively participates in privately run security associations whose basis of trust and anonymity makes it much easier to obtain information regarding abusive DNS activity.Once a complaint is received from a trusted source, third-party, or detected by Neustar’s internal security group, information about the abusive practice is forwarded to an internal mail distribution list that includes members of the operations, legal, support, engineering, and security teams for immediate response (“CERT Team”). Although the impacted URL is included in the notification e-mail, the CERT Team is trained not to investigate the URLs themselves since often times the URLs in Question have scripts, bugs, etc. that can compromise the individual’s own computer and the network safety. Rather, the investigation is done by a few members of the CERT team that are able to access the URLs in a laboratory environment so as to not compromise the Neustar network. The lab environment is designed specifically for these types of tests and is scrubbed on a regular basis to ensure that none of Neustar’s internal or external network elements are harmed in any fashion.

Once the complaint has been reviewed and the alleged abusive domain name activity is verified to the best of the ability of the CERT Team, the sponsoring registrar is given 12 hours to investigate the activity and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hNeustar’s period (i.e., is unresponsive to the request or refuses to take action), Neustar places the domain on “ServerHold”. Although this action removes the domain name from the .health TLD zone, the domain name record still appears in the .health TLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved.

Full Process 
In the event that DotHealth and⁄or Neustar receives a complaint which claims that a domain name is being used to threaten the stability and security of the .health TLD or is a part of a real-time investigation by law enforcement or security researchers, Neustar follows a slightly different course of action. Upon initiation of this process, members of the CERT Team are paged and a teleconference bridge is immediately opened up for the CERT Team to assess whether the activity warrants immediate action. If the CERT Team determines the incident is not an immediate threat to the security and the stability of critical internet infrastructure, they provide documentation to the Neustar Network Operations Center to clearly capture the rationale for the decision and either refers the incident to the Lightweight process set forth above. If no abusive practice is discovered, the incident is closed. However, if the CERT TEAM determines there is a reasonable likelihood that the incident warrants immediate action as described above, a determination is made to immediately remove the domain from the zone. As such, Customer Support contacts the responsible registrar immediately to communicate that there is a domain involved in a security and stability issue. The registrar is provided only the domain name in Question and the broadly stated type of incident. Given the sensitivity of the associated security concerns, it may be important that the registrar not be given explicit or descriptive information in regards to data that has been collected (evidence) or the source of the complaint. The need for security is to fully protect the chain of custody for evidence and the source of the data that originated the complaint. 

Additional Abuse Mitigation Procedures and Measures

Abuse Point of Contact 
As required by the Registry Agreement, DotHealth, LLC (“DotHealth”) will establish and publish on its website a single abuse point of contact responsible for addressing inquiries from law enforcement and the public related to malicious and abusive conduct. DotHealth will also provide such information to ICANN prior to the delegation of any domain names in the .health TLD. This information shall consist of, at a minimum, a valid e-mail address dedicated solely to the handling of malicious conduct complaints, and a telephone number and mailing address for the primary contact. We will ensure that this information will be kept accurate and up to date and will be provided to ICANN if and when changes are made. In addition, with respect to inquiries from ICANN-Accredited registrars, our back-end registry service provider, Neustar, shall provide an additional point of contact, as it does today, handling requests by registrars related to abusive domain name practices. 

Measures for Removal of Orphan Glue Records
As the Security and Stability Advisory Committee of ICANN (SSAC) rightly acknowledges, although orphaned glue records may be used for abusive or malicious purposes, the “dominant use of orphaned glue supports the correct and ordinary operation of the DNS.” See http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf. While orphan glue often support correct and ordinary operation of the DNS, we understand that such glue records can be used maliciously to point to name servers that host domains used in illegal phishing, bot-nets, malware, and other abusive behaviors. Problems occur when the parent domain of the glue record is deleted but its children glue records still remain in DNS. Therefore, when the .health TLD Registry has written evidence of actual abuse of orphaned glue, the Registry will take action to remove those records from the zone to mitigate such malicious conduct. For the .health TLD, Neustar will run a daily audit of entries in its DNS systems and will compare those with its provisioning system. This serves as an umbrella protection to make sure that items in the DNS zone are valid. Any DNS record that shows up in the DNS zone but not in the provisioning system will be flagged for investigation and removed if necessary. This daily DNS audit serves to not only prevent orphaned hosts but also other records that should not be in the zone. In addition, if either DotHealth or Neustar become aware of actual abuse on orphaned glue after receiving written notification by a third party through its Abuse Contact or through its customer support, such glue records will be removed from the zone. 

Measures to Promote WHOIS Accuracy
DotHealth acknowledges that ICANN has developed a number of mechanisms over the past decade that are intended to address the issue of inaccurate WHOIS information. Such measures alone have not proven to be sufficient and DotHealth will offer a mechanism whereby third parties can submit complaints directly to the Applicant (as opposed to ICANN or the sponsoring Registrar) about inaccurate or incomplete WHOIS data. Such information shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Thirty days after forwarding the complaint to the registrar, DotHealth will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, Applicant reserves the right to suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.

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

Resourcing Plans

For the .health TLD, responsibility for abuse mitigation rests with a variety of functional groups within Neustar. The Abuse Monitoring team is primarily responsible for providing analysis and conducting investigations of reports of abuse. The customer service team also plays an important role in assisting with the investigations, responded to customers, and notifying registrars of abusive domains. The necessary resources from Neustar will be pulled from the pool of available resources described in detail in the response to Question 31. 

The following resources are available from Neustar’s various teams:

• Customer Support – 12 employees
• Policy⁄Legal – 2 employees

LegitScript’s enterprise service-levels in support of abuse mitigation will be provided to DotHealth on an outsourcing basis. Resource allocation for these services are assumed in the financial models as an outsourced cost which is expected to increase in conjunction with registration volume and overall growth of the .health TLD. 

Rights Protection Mechanisms

DotHealth, LLC (“DotHealth”) is firmly committed to the protection of Intellectual Property rights and to implementing the mandatory rights protection mechanisms for the .health TLD as contained in the Applicant Guidebook and detailed in Specification 7 of the Registry Agreement. 
Numerous operating procedures, safeguards and policies have been identified and orchestrated in conjunction with our proposed efforts to operate the .health TLD registry. These include the following:

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

Trademark Clearinghouse Including Sunrise and Trademark Claims

The first mandatory rights protection mechanism (“RPM”) required to be implemented by each new gTLD Registry is support for, and interaction with, the trademark clearinghouse. The trademark clearinghouse is intended to serve as a central repository for information to be authenticated, stored and disseminated pertaining to the rights of trademark holders. The data maintained in the clearinghouse will support and facilitate other RPMs, including the mandatory Sunrise Period and Trademark Claims service. 

Although many of the details of how the trademark clearinghouse will interact with each registry operator and registrars, DotHealth is actively monitoring the developments of the Implementation Assistance Group (“IAG”) designed to assist ICANN staff in firming up the rules and procedures associated with the policies and technical requirements for the trademark clearinghouse. In addition, DotHealth’s back-end registry services provider, Neustar, is actively participating in the IAG to ensure that the protections afforded by the clearinghouse and associated RPMs are feasible and implementable.

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

Neustar’s Experience in Implementing Sunrise and Trademark Claims Processes

DotHealth will leverage Neustar’s experience in order to implement a successful Sunrise and Trademark Claims process for the .health TLD. DotHealth’s registry service provider for the .health, Neustar, has already implemented Sunrise and⁄or Trademark Claims programs for numerous TLDs including .biz, .us, .travel, .tel and .co and will implement the both of these services on behalf of the .health TLD. 
In early 2002, Neustar became the first registry operator to launch a successful authenticated Sunrise process. This process permitted qualified trademark owners to pre-register their trademarks as domain names in the .us TLD space prior to the opening of the space to the general public. Unlike any other “Sunrise” plans implemented (or proposed before that time), Neustar validated the authenticity of Trademark applications and registrations with the United States Patent and Trademark Office (USPTO). 

Subsequently, as the back-end registry operator for the .tel gTLD and the .co ccTLD, Neustar launched validated Sunrise programs employing processes. These programs are very similar to those that are to be employed by the Trademark Clearinghouse for new gTLDs. Below is a high level overview of the implementation of the .co Sunrise period that demonstrates Neustar’s experience and ability to provide a Sunrise service and an overview of Neustar’s experience in implementing a Trademark Claims program to trademark owners for the launch of .BIZ. Neustar’s experience in each of these rights protection mechanisms will enable it to seamlessly provide these services on behalf of DotHealth and the .health TLD as required by ICANN. 

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

• Local Sunrise giving holders of eligible trademarks that have obtained registered status from the Colombian trademark office the opportunity apply for the .CO domain names corresponding with their marks 

• Global Sunrise program giving holders of eligible registered trademarks of national effect, that have obtained a registered status in any country of the world the opportunity apply for the .CO domain names corresponding with their marks for a period of time before registration is open to the public at large. Like the new gTLD process set forth in the Applicant Guidebook, trademark owners had to have their rights validated by a Clearinghouse provider prior to the registration being accepted by the Registry. The Clearinghouse used a defined process for checking the eligibility of the legal rights claimed as the basis of each Sunrise application using official national trademark databases and submitted documentary evidence. Applicants and⁄or their designated agents had the option of interacting directly with the Clearinghouse to ensure their applications were accurate and complete prior to submitting them to the Registry pursuant to an optional “Pre-validation Process”. Whether or not an applicant was “pre-validated”, the applicant had to submit its corresponding domain name application through an accredited registrar. When the Applicant was pre-validated through the Clearinghouse, each was given an associated approval number that it had to supply the registry. If they were not pre-validated, applicants were required to submit the required trademark information through their registrar to the Registry.

At the registry level, Neustar, subsequently either delivered the: 

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

Information was then used by the Clearinghouse as either further validation of those pre-validated applications, or initial validation of those that did not go through pre-validation. If the applicant was validated and their trademark matched the domain name applied-for, the Clearinghouse communicated that fact to the Registry via EPP. When there was only one validated sunrise application, the application proceeded to registration when the .co launched. If there were multiple validated applications (recognizing that there could be multiple trademark owners sharing the same trademark), those were included in the .co Sunrise auction process. Neustar tracked all of the information it received and the status of each application and posted that status on a secure Website to enable trademark owners to view the status of its Sunrise application. 
Although the exact process for the Sunrise program and its interaction between the trademark owner, Registry, Registrar, and IP Clearinghouse is not completely defined in the Applicant Guidebook and is dependent on the current RFI issued by ICANN in its selection of a Trademark Clearinghouse provider, Neustar’s expertise in launching multiple Sunrise processes and its established software will implement a smooth and compliant Sunrise process for the new gTLDs.

With Neustar’s biz TLD launched in 2001, Neustar became the first TLD with a Trademark Claims service. Neustar developed the Trademark Claim Service by enabling companies to stake claims to domain names prior to the commencement of live .biz domain registrations. During the Trademark Claim process, Neustar received over 80,000 Trademark Claims from entities around the world. Recognizing that multiple intellectual property owners could have trademark rights in a particular mark, multiple Trademark Claims for the same string were accepted. All applications were logged into a Trademark Claims database managed by Neustar. 

The Trademark Claimant was required to provide various information about their trademark rights, including the:

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

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

The domain name applicant had the option to proceed with the application or cancel the application. Proceeding on an application meant that the applicant wanted to go forward and have the application proceed to registration despite having been notified of an existing Trademark Claim. By choosing to “cancel,” the applicant made a decision in light of an existing Trademark Claim notification to not proceed. If the applicant did not respond to the e-mail notification from Neustar, or elected to cancel the application, the application was not processed. This resulted in making the applicant ineligible to register the actual domain name. If the applicant affirmatively elected to continue the application process after being notified of the claimant’s (or claimants’) alleged trademark rights to the desired domain name, Neustar processed the application. 

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

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

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

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

The URS is not meant to address Questionable cases of alleged infringement (e.g., use of terms in a generic sense) or for anti-competitive purposes or denial of free speech, but rather for those cases in which there is no genuine contestable issue as to the infringement and abuse that is taking place. Unlike the UDRP which requires little involvement of gTLD registries, the URS for the .health TLD envisages much more of an active role at the registry-level. For example, rather than requiring the registrar to lock down a domain name subject to a UDRP dispute, under the URS, DotHealth will lock the domain within 24hours of receipt of the complaint from the URS Provider to restrict all changes to the registration data, including transfer and deletion of the domain names. In addition, in the event of a determination in favor of the complainant, the .health registry will suspend the domain name. This suspension remains for the balance of the registration period and will not resolve the original website. Rather, the nameservers would be redirected to an informational web page provided by the URS Provider about the URS. Additionally, the WHOIS reflects that the domain name will not be able to be transferred, deleted, or modified for the life of the registration. Finally, there is an option for a successful complainant to extend the registration period for one additional year at commercial rates. 

DotHealth is fully aware of each of these requirements and will have the capability to implement these requirements for the .health TLD. In fact, during the IRT’s development of the URS, Neustar began examining the implications of the URS on its registry operations and provided the IRT with feedback on whether the recommendations from the IRT would be feasible for registries to implement. Although there have been a few changes to the URS since the IRT recommendations, Neustar continued to participate in the development of the URS by providing comments to ICANN, many of which were adopted. As a result, in addition to .health, Neustar is committed to supporting the URS for all of the registries that it provides back-end registry services.

Implementation of Thick WHOIS

The .health TLD registry will include a thick WHOIS database as required in Specification 4 of the Registry agreement. A thick WHOIS provides numerous advantages including a centralized location of registrant information, the ability to more easily manage and control the accuracy of data, and a consistent user experience. 
Policies Handling Complaints Regarding Abuse. In addition the Rights Protection mechanisms addressed above, DotHealth will implement a number of measures to handle complaints regarding the abusive registration of domain names in the .health TLD as described in DotHealth’s response to Question 28.

Registry Acceptable Use Policy

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

Monitoring for Malicious Activity 

DotHealth is committed to ensuring that those domain names associated with abuse or malicious conduct in violation of the Acceptable Use Policy are dealt with in a timely and decisive manner. These include taking action against those domain names that are being used to threaten the stability and security of the .health TLD, or is part of a real-time investigation by law enforcement. Once a complaint is received from a trusted source, a third-party, or detected by the Registry in conjunction with Neustar and⁄or LegitScript, the Registry will use commercially reasonable efforts to verify the information in the complaint. If that information can be verified to the best of the ability of the Registry, the sponsoring registrar will be notified and be given 12 hours to investigate the activity and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the Registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), the Registry will place the domain on “ServerHold”. Although this action removes the domain name from the .health TLD zone, the domain name record still appears in the .health TLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved.

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

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

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

LegitScript’s enterprise service-levels in support of rights protection will be provided to DotHealth on an outsourcing basis (See exhibit “Q29_LegitScript LOI”). Resource allocation for these services are assumed in the financial models as an outsourced cost which is expected to increase in conjunction with registration volume and overall growth of the .health TLD. 

DotHealth, LLC (“DotHealth”) and our back-end operator, Neustar, recognize the vital need to secure the systems and the integrity of the data in commercial solutions. The .health TLD registry solution will leverage industry-best security practices including the consideration of physical, network, server, and application elements. 
Neustar’s approach to information security starts with comprehensive information security policies. These are based on the industry best practices for security including SANS (SysAdmin, Audit, Network, Security) Institute, NIST (National Institute of Standards and Technology), and Center for Internet Security (CIS). Policies are reviewed annually by Neustar’s information security team.

The following is a summary of the security policies that will be used in the .health TLD registry, including:

1. Summary of the security policies used in the registry operations
2. Description of independent security assessments
3. Description of security features that are appropriate for .health
4. List of commitments made to registrants regarding security levels

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

Neustar, Inc. has developed a comprehensive Information Security Program in order to create effective administrative, technical, and physical safeguards for the protection of its information assets, and to comply with Neustarʹs obligations under applicable law, regulations, and contracts. This Program establishes Neustarʹs policies for accessing, collecting, storing, using, transmitting, and protecting electronic, paper, and other records containing sensitive information.

The Program defines:

• The policies for internal users and our clients to ensure the safe, organized and fair use of information resources.
• The rights that can be expected with that use. 
• The standards that must be met to effectively comply with policy.
• The responsibilities of the owners, maintainers, and users of Neustar’s information resources.
• Rules and principles used at Neustar to approach information security issues

The following policies are included in the Program:

1. Acceptable Use Policy
The Acceptable Use Policy provides the “rules of behavior” covering all Neustar Associates for using Neustar resources or accessing sensitive information.

2. Information Risk Management Policy
The Information Risk Management Policy describes the requirements for the on-going information security risk management program, including defining roles and responsibilities for conducting and evaluating risk assessments, assessments of technologies used to provide information security and monitoring procedures used to measure policy compliance.

3. Data Protection Policy 
The Data Protection Policy provides the requirements for creating, storing, transmitting, disclosing, and disposing of sensitive information, including data classification and labeling requirements, the requirements for data retention. Encryption and related technologies such as digital certificates are also covered under this policy.

4. Third Party Policy
The Third Party Policy provides the requirements for handling service provider contracts, including specifically the vetting process, required contract reviews, and on-going monitoring of service providers for policy compliance.

5. Security Awareness and Training Policy
The Security Awareness and Training Policy provide the requirements for managing the on-going awareness and training program at Neustar. This includes awareness and training activities provided to all Neustar Associates. 

6. Incident Response Policy
The Incident Response Policy provides the requirements for reacting to reports of potential security policy violations. This policy defines the necessary steps for identifying and reporting security incidents, remediation of problems, and conducting “lessons learned” post-mortem reviews in order to provide feedback on the effectiveness of this Program. Additionally, this policy contains the requirement for reporting data security breaches to the appropriate authorities and to the public, as required by law, contractual requirements, or regulatory bodies.

7. Physical and Environmental Controls Policy
The Physical and Environment Controls Policy provides the requirements for securely storing sensitive information and the supporting information technology equipment and infrastructure. This policy includes details on the storage of paper records as well as access to computer systems and equipment locations by authorized personnel and visitors.

8. Privacy Policy
Neustar supports the right to privacy, including the rights of individuals to control the dissemination and use of personal data that describes them, their personal choices, or life experiences. Neustar supports domestic and international laws and regulations that seek to protect the privacy rights of such individuals.

9. Identity and Access Management Policy
The Identity and Access Management Policy covers user accounts (login ID naming convention, assignment, authoritative source) as well as ID lifecycle (request, approval, creation, use, suspension, deletion, review), including provisions for system⁄application accounts, shared⁄group accounts, guest⁄public accounts, temporary⁄emergency accounts, administrative access, and remote access. This policy also includes the user password policy requirements. 

10. Network Security Policy
The Network Security Policy covers aspects of Neustar network infrastructure and the technical controls in place to prevent and detect security policy violations. 

11. Platform Security Policy
The Platform Security Policy covers the requirements for configuration management of servers, shared systems, applications, databases, middle-ware, and desktops and laptops owned or operated by Neustar Associates.

12. Mobile Device Security Policy
The Mobile Device Policy covers the requirements specific to mobile devices with information storage or processing capabilities. This policy includes laptop standards, as well as requirements for PDAs, mobile phones, digital cameras and music players, and any other removable device capable of transmitting, processing or storing information.

13. Vulnerability and Threat Management Policy
The Vulnerability and Threat Management Policy provides the requirements for patch management, vulnerability scanning, penetration testing, threat management (modeling and monitoring) and the appropriate ties to the Risk Management Policy.

14. Monitoring and Audit Policy
The Monitoring and Audit Policy covers the details regarding which types of computer events to record, how to maintain the logs, and the roles and responsibilities for how to review, monitor, and respond to log information. This policy also includes the requirements for backup, archival, reporting, forensics use, and retention of audit logs.

15. Project and System Development and Maintenance Policy
The System Development and Maintenance Policy covers the minimum security requirements for all software, application, and system development performed by or on behalf of Neustar and the minimum security requirements for maintaining information systems.

30. (a).2 Independent Assessment Reports
Neustar IT Operations is subject to yearly Sarbanes-Oxley (SOX), Statement on Auditing Standards #70 (SAS70) and ISO audits. Testing of controls implemented by Neustar management in the areas of access to programs and data, change management and IT Operations are subject to testing by both internal and external SOX and SAS70 audit groups. Audit Findings are communicated to process owners, Quality Management Group and Executive Management. Actions are taken to make process adjustments where required and remediation of issues is monitored by internal audit and QM groups.External Penetration Test is conducted by a third party on a yearly basis. As authorized by Neustar, the third party performs an external Penetration Test to review potential security weaknesses of network devices and hosts and demonstrate the impact to the environment. 

The assessment is conducted remotely from the Internet with testing divided into four phases:

• A network survey is performed in order to gain a better knowledge of the network that was being tested
• Vulnerability scanning is initiated with all the hosts that are discovered in the previous phase
• Identification of key systems for further exploitation is conducted
• Exploitation of the identified systems is attempted.

Each phase of the audit is supported by detailed documentation of audit procedures and results. Identified vulnerabilities are classified as high, medium and low risk to facilitate management’s prioritization of remediation efforts. Tactical and strategic recommendations are provided to management supported by reference to industry best practices.

30.(a).3 Augmented Security Levels and Capabilities
There are no increased security levels specific for .health TLD. However, Neustar will provide the same high level of security provided across all of the registries it manages. 

A key to Neustar’s Operational success is Neustar’s highly structured operations practices. The standards and governance of these processes: 

• Include annual independent review of information security practices 
• Include annual external penetration tests by a third party 
• Conform to the ISO 9001 standard (Part of Neustar’s ISO-based Quality Management System)
• Are aligned to Information Technology Infrastructure Library (ITIL) and CoBIT best practices 
• Are aligned with all aspects of ISO IEC 17799
• Are in compliance with Sarbanes-Oxley (SOX) requirements (audited annually)
• Are focused on continuous process improvement (metrics driven with product scorecards reviewed monthly).

A summary view to Neustar’s security policy in alignment with ISO 17799 can be found in section 30.(a).4 below.

30.(a).4 Commitments and Security Levels 
The .health TLD registry commits to high security levels that are consistent with the needs of the TLD. These commitments include:

Compliance with High Security Standards

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

Highly Developed and Document Security Policies

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

High Levels of Registry Security

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