Application number: 1-1714-80638 for C.V. TLDcare

C.V. TLDcare

+31622884491

+31135332991

Mr. Tacco Merlijn Marijnen

CEO

+31622884491

tmarijnen@tvision.nl

Mr. Johannes Hubertus Antonius Maria Baeten

Investor

+31653166698

tmarijnen@hotmail.com

Limited Partnership

The Dutch equivalent of a Limited Partnership is Commanditaire Vennootschap (C.V.), defined in Civil Code book 2 (Burgelijk Wetboek 2).

Not Available

Tacco Merlijn Marijnen
CEO

Handelsonderneming Baeten B.V.
Not Applicable
Het Participatiehuys B.V.
Not Applicable
Tacco Marijnen Holding B.V.
Not Applicable

LTD

Not Available

As is the case with any new TLD that is added to the DNS root zone, some general technical acceptance issues with the delegation of this TLD are expected. The Registry Service Provider selected by the Applicant has a significant experience in introducing new TLDs to the DNS root, including .EU in 2005 and .SX in 2010.
The applied-for gTLD string consists only of ASCII characters (no IDN), which significantly reduces the risk of introducing confusion for the general public of character similarity
With the Registry Service Provider, the Applicant has carried out a series of tests in order to review whether the applied-for gTLD presented any operational or rendering issues. This included the deployment of a testing infrastructure for the applied-for Registry that operated:
1) a SRS (Shared Registration System) of which the features have been limited to what was strictly necessary to carry out the tests described below
2) a WHOIS system, displaying domain names registered in the test environment
3) an EPP (Extensible Provisioning Protocol) and web interface for Registrars
4) a DNS system, serving authoritative responses for the gTLD
5) a web server on which different basic websites were deployed;
6) an email server with mailboxes linked to various test domain names in the TLD and entered into a limited zone file which was made available through the DNS system referred to above.
The following tests have been carried out, by connecting various clients to the infrastructure described above:
1) logging into the Registry SRS with a Registrar account – using both EPP and Web interfaces
2) performing basic transactions (create, update, delete, transfer, allocate name servers, etc.) with this Registrar test account
3) generating of a test-zone file for this TLD
4) navigating to and within websites using both direct navigation to the respective domain names and navigation through hyperlinks displayed on the web sites that were hosted in the testing environment
5) sending FTP requests to and receiving correct responses from FTP environments matched to domain names registered in the gTLD testing environment
6) sending email messages to and receiving email messages from domain names registered in the TLD’s testing environment.
Within each of the above steps, the Applicant and its selected back-end registry operator reviewed:
1) whether Registrar transactions with respect to these domain names were performed successfully
2) whether the zone file was correctly generated and deployed in the DNS of the test environment
3) whether domain names registered in the TLD displayed correctly in browser address bars and email clients
4) whether email filters, spam detectors, etc. were correctly functioning.
Using web browsers, email and FTP clients, these tests have been carried out successfully. Therefore, to the Applicant’s best knowledge and belief, no specific issues are to be expected as regards the operation and rendering of the applied-for gTLD

The internet as we know today has become very generic. Although that is has become an incredible tool giving the possibility to millions of internet users worldwide to search any and all kind of information, there is a lot of confusing and malicious information that is available. Consequently, it has become more and more difficult for companies and brand owners to differentiate themselves in the eyes of the internet user from the other of millions of domain names that have no primary or secondary meaning. In many cases internet users do not really know anymore whether they are dealing with a true company with all kinds of negative experiences as a result Also if you look at some of existing gTLDs that were set up with an initial purpose to serve the corporate market, you can see that that purpose has diluted.

With .ltd TLD we as the Applicant want to change that experience, bringing back the true meaning of a specific TLD that will allow companies that are registered within a specific region to be able to register their company names within the .ltd TLD, making it clearer for the user that he is dealing with the corporate market. As such, this specific TLD will provide companies the opportunity to differentiate themselves from any other TLD due to the fact that the Applicant will ensure and enhance restricted policies (i.e. only companies registered within the Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil will be allowed to apply for a domain name). The result will be a genuine, safe and secure TLD that will not tolerate any abuses or misuse of domain names or websites and will ensure that all companies that apply for a domain name do indeed meet the requirements of the policies as laid down by the Applicant. In addition companies that were not entitled to register their company names as a domain name due to unavailability will now have the opportunity to do so.

In addition, the Applicant is convinced that an .ltd TLD will be an added value to the internet community as a whole and to the internet user in specific. As the internet domain space- as we know today- will entirely change the internet users will search the internet on a whole different level. The internet will no longer exist primarily of “.com” domain names, but the domain name space will become more segregated. Consequently, the Applicant truly believes that the .ltd TLD will provide an added value by setting up and managing a TLD that will only allow companies that are registered in the Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil to apply for a domain name. The Applicant wants to ensure that all registrants have a link within the TLD, as the term ʺltdʺ is used by the majority of companies that are registered under the laws and regulations of Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil.

I.The .ltd TLD will target essentially the companies registered with the local Chambers of Commerce in the Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil as limited companies. Since the Applicant will have a restricted target audience it will be able to limit the risk of fraudulent registrations. We will hence be able to increase the trust of the public toward .ltd TLD. Once consumers know that they can trust the .ltd TLD as a sign of quality and as a place where they can find reliable information this will trickle down to the limited companies that choose for a .ltd domain name. We will therefore be able to offer these companies a chance to assert their reputation on the internet.

In addition to that with the .ltd TLD, we will create a new specific space on the internet where the public will know right away that they can find all the corporate information related to a limited company. 

The creation of a .ltd TLD will also benefit the registrants who will be able to gain a different visibility among the million of domain names already registered under .com.


II.By choosing for a .ltd TLD, limited companies will be able to differentiate themselves from the rest of the companies that have registered a domain name, for instance a . com domain name. It will offer them the opportunity to assert their identity as limited companies. It will allow them to send a message to the consumers that if they are interested in their companies, they can find all the relevant information about them on a trusted space. We will thus bring an added value to what already exists in terms of domain names. Our .ltd domain name will create visibility for the limited companies and trust for the consumers.


III.The .ltd TLD will allow users to find easily the information they need concerning a particular company. It will also increase their trust since our .ltd TLD will only allow registration by companies that are duly registered by the Chambers of Commerce of the Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil.

IV. Applicant will at all times implement and adhere to any and all consensus policies introduced by ICANN, so as to further the development and stability of the Internet and the global Internet community. Applicant also intends to create a governance committee that will consists of legal, technical, commercial and business advisors to review and propose policies and ensure that all polices are adhered to.

A brief description of the registration polices can be summarized below:

Prior to issuing .ltd domain names, Applicant intends to reserve i) a number of domain names that are necessary for the operation of the .ltd TLD and ii) a number of generic words, phrases, character and⁄or digits as second-level and third level domain names. These domain names will be allocated in a later stage to be determined by the Applicant in accordance to the requirements as set out by the Applicant. The purpose of the latter will ensure that company names that include generic words will be submitted to an additional check in order to ensure that they have a legitimate right to use these generic terms.

In addition, Applicant will also include in its master database words and phrases which it, in its sole and exclusive discretion, considers to be abusive, obscene and⁄or offensive, thereby preventing any reputational loss to . ltd TLD. These domain names will come up as unavailable.

Similarly, Applicant intends to reserve all two character labels and all country and territory names, taking into account the relevant provisions laid down in Specification 5 of the Registry Agreement. More information in this respect will be provided in our answer to Question 22. 

Restricted registration

In order to comply with the above mission, the Applicant will only allow companies registered in the Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil to register a domain name within the .ltd TLD. In order to ensure that the restricted policy is in place, Applicant will request from all registrant documentary evidence that proves that the registrant is indeed listed with the local chambers of commerce. Furthermore, the Applicant plans to include specific provisions in its registry-registrar agreement in order to ensure that Applicant’s mission and vision outlined above are implemented to their fullest extent possible. By doing so, the Applicant ensures that the restricted policies as described above and below are adhered to and this will also allow a smoother implementation of the issuance of the domain names. 

If and when deemed appropriate or laid down in the Registry Operator Agreement to be entered into with ICANN, Applicant intends to launch its TLD in different phases:

Sunrise period: Applicant intends to open this phase for all registrants that have a company registered in the Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil and that have registered trademarks . In this phase, Applicant intends to use the trademark clearinghouse as set out by ICANN. Once the Applicant has received notification of the trademark clearinghouse that a registrant has indeed a corresponding trademark, it will put this domain name “on hold”. Consequently, an additional check could be made on the basis of the local chamber of commerce or other documentation to be provided by the registrant in order to ensure that the company is indeed registered in the Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil. We intend to implement a Sunrise Phase for a period of 2 months.

Land Rush: During Land Rush, the reserved generic domain names (Premium Names) will become available. 

General Availability: In this phase all companies that are registered within the Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil will be allowed to register a domain name. 

V. We will not collect more data than necessary to comply with ICANN’s WHOIS standards. We may also collect personal information in order to verify if the requested domain name corresponds to a validly registered limited company in order to increase users’ trust toward the .ltd TLD. In this case we will not collect more information that is necessary to achieve this verification purpose. For any personal information we will collect, we will comply with the laws in force in terms of data protection.


VI. With the .ltd domain names, we will bring added value to both users, in terms of trust and facilitated researches, and the limited companies, in terms of increased visibility. To achieve these goals we are aware that we need to put the .ltd gTLD in the spotlight. We will therefore publish advertisements in magazines in the Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil. We will also contact with the Chambers of Commerce of Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil to let them see how the registration to a .ltd domain name could make limited companies gain visibility, especially with regards to smaller businesses that sometimes struggle to find the right channel to get the exposure they need and hence reach more customers

I. If multiple applications should occur during any of the sunrise phases, this will be resolved by an auction. Applicant intends to enter into agreement with Sedo Holding AG in order to ensure that the auction is done in correct and legitimate manner. 

II. Applicant intends to implement a discount of 35% when registrants will register their domain names for a period of 2 years. Applicant does not intend to implement any other cost benefits for registrants.

III.Applicant does not intend to apply any price increases.

No

Not Available

No

Given the fact that the Applicant that will only allow companies that are registered in Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil to apply for a domain name, Applicant has no interest in allocating any second or third level domain names that correspond with any geographic names. Consequently, and in accordance with Specification 5 of the Agreement, the Applicant will reserve at all times all geographic names at the second level and any other levels within the gTLD. Applicant does not intend to release these domain names.

1. Overview
The internet today, with 22 generic top-level domain names and approximately 270 country code TLDs, is about to change. As the domain name space will be opened to organizations applying for gTLDs associated with particular interests and businesses sectors, this will help organizations and communities enhance branding, community building, security, and user interaction. Hundreds of new extensions may be introduced and each applicant will have to look for a stable and secure Registry system and technical provider. The Registry Operator has therefore chosen to outsource the technical back-end operations for the domain name Registry to Sensirius (the Registry Service Provider). Sensirius combines a steady track record with modular software to help applicants take advantage of this opportunity.
When it is stated that the Registry service Provider will perform certain services or comply with certain standards and processes, the Registry Service Provider will do this in the name and on behalf of the Applicant, who itself is committed to comply with these standards and processes towards ICANN under the Registry Agreement and the terms and conditions of the new gTLD program. Unless it is expressly stated otherwise, all services described in this question will be provided by the Registry Service Provider in the name and on behalf of the Applicant, who will monitor the Registry Service Provider’s compliance with its contractual terms and the requirements laid down by ICANN on a regular basis. 

1.1. Registry Service Provider
This document sets out the range of services that Sensirius offers to its customers in compliance with ICANN’s new top level domain application process. The services are fully compliant with ICANN’s requirements regarding the deployment and management of a gTLD Registry System. 
Sensirius’ multilingual staff has over 20 years of combined experience in developing and managing sophisticated solutions for domain name Registrars, domain name Registrants (in particular brand owners) and Registry Operators, as well as being involved in the design of policies for and managing Registrar relationships with several ccTLDs. 
All members of the team (including outsourced personnel) have been specifically trained on the Registry Platform and have an extensive knowledge and hands-on know-how about the DNS. Sensirius has offices in Luxembourg and Belgium.
Sensirius was founded by the three key leaders involved in the successful creation and operation of the .be and .eu Registries, which combined currently represent over four million domain names. The Sensirius team has 20 years of experience in developing and managing sophisticated solutions for Registrars and Registry Operators. The Sensirius system draws on the best features of the .be and .eu systems, combined with new technology that has been introduced, which results in best practice system protocols and software design.
Sensirius offers from a simple, totally outsourced product to a licensed version of the Registry software for clients who wish to manage their own infrastructure. In each and every case, the system meets and even exceeds ICANN’s Registry contract requirements. The software provides the flexibility to offer options to Registry Operators that are in line with its own specific operational and technical circumstances.
(View attachment for Figure 1: Registry Software Capabilities)
There are three key feature groups which address the ICANN evaluation process and which meet and even exceed ICANN’s mission and core values to protect the stability of the global Internet. These are the technical features, financial features and third party modules that are detailed in the next sections. 
(View attachment for Figure 2: Registry Software Features Overview)

1.2. Stability & Security
The Registry Platform that will be deployed for the applied-for gTLD, which meets and even exceeds the technical requirements set by ICANN, combined with the team’s experience in running ccTLD domain extensions, provide a solid basis to assist the Applicant to meet its commitments to ICANN. As a Registry Service Provider, Sensirius is an operationally secure company with highly skilled staff and appropriate premises for running Registry Services conform to the ISO27001 standard.
DNS services are monitored at all times and external high quality any-cast providers are added in the mix to deliver excellent and premium class nameserver infrastructure all over the world.
The main features of the Registry Platform include a complete and extendible set of functionalities that can be controlled by the administrator. Some of the more profound features include support for IPv4, IPv6 and DNSSEC. The Registry Platform relies on standards-based software, carrier-grade hardware and protocol compliant interfaces. These include enabling dynamic zone file updates for immediate use after registration, escrow services and advanced reporting. Extensible Provisioning Protocol (EPP) transactions are only accepted from pre-registered IP addresses and all transactions, whether web or EPP are protected by Secure Socket Layer (SSL). All transactions are monitored, traced and logged.
The Registry Service Provider’s staff are industry-trained (in Java, SQL, Linux) university-certified professionals each with over a decade of experience in building and managing network infrastructure (CISCO, Juniper,… ) using quality hardware appropriate for the array of customers.
Diverse audit trails of all activities across software, hardware, staff movement, building access to ensure the security of our systems, are provided. A penalty system ensures Registrars cannot flood the Registry Platform with invalid requests, which would potentially degrade the system’s performance. New connections (SYN packets) are limited on the domain name Registry’s edge routers to minimize the impact of Denial of Service (DOS) and Distributed Denial of Service (DDOS) attacks. The system is further protected with a redundant intrusion detection⁄intrusion prevention system to exercise deep packet inspection and block risks on SQL-injection and cross site scripting.
Sensirius offers a range of services to increase the security of communications between the Registry Operator and Registrars. By default, the communication channel is encrypted using Secure Socket Layer (SSL)⁄Transport Security Layer (TLS). On top of encryption, the following options are available:
1) User login with passwords and granular authorization;
2) Trade and transfer control to prevent unintentional transfers;
3) Limited access per second to avoid data harvesting;
4) Monitored update allows ownership data to be changed only after manual checks;
5) Temporary take-over by the Registry Operator in case of Registrar bankruptcy;
6) Domain lock avoids malicious transfer or trades;
7) On-hold status can be set pending an Alternative Dispute Resolution (ADR) case;
8) Domain Name Monitoring module exposes typo-squatters by listing similar domain names;
9) The Registrant extranet puts Registrants in charge of their domain names.
The Registry Platform provides a minimum of two anycast addresses, nodes in 52 locations around the world and a capacity of over 500 billion queries a day with a resolution rate of under one millisecond. Each node is set up in a redundant configuration so that a hardware failure on one machine does not prevent the node from responding to queries. 
The Registry’s primary server location is located in Belgium, in a secure, state-of-the-art facility. Special care has been taken to provide several physical layers of security. The Registry database and application servers will be hosted there, with a mirror site in Luxembourg. The Registry Platform is connected using multiple Internet Service Providers (ISPs), all of them Tier 1 providers. 
The applications run on a blade infrastructure, allowing for immediate recovery in the case of failure of any one element and providing easy scalability. The setup provides micro-cloud functionality that allows for easy scalability and multiple layers of redundancy. The local backup (warm standby) server is kept current by a stream of write-ahead log records, so it can take over as the master server with minimal delay. Name servers are distributed over the world for load balancing and robustness. External parties provide anycast functionality. The unicast nodes provided are set up in a redundant configuration so that a hardware failure on one machine does not prevent the node from responding to queries.
All the Registry data are stored on a cluster of database servers, both on the primary and on the mirror site. These databases are synchronized permanently. If the load on the production database is deemed too high to deliver excellent quality service, read-only copies are put in place for read-only service, such as WHOIS and Data Escrow, to off-load traffic from the main database. A special delayed recovery database is available on the primary site to be able to recover quickly from data corruption should it have spread to all on-line database servers.
(View attachment for Figure 3: Registry Services interfacing the Registry Database)
The Registry Platform is feature rich with a multitude of parameters that can be set to suit the applicant’s requirements. At system level software modules and functionalities can be switched on and off by the system administrator. 
The Registry Platform contains all functionality required by ICANN for a TLD to operate efficiently through two main interfaces or more if necessary. The XML based EPP interface provides excellent means for Registrars who want to offer their customers a fully automated interface. A web interface provides extra functions that are difficult to automate next to a set of commands that are fully compatible with EPP.
The audit trail ensures that from day one every single activity in the system is logged and copied, including all associated data. This allows for going back in time and examining the situation both before and after a transaction took place. Journaling is built straight in the database, so it is hassle free for programmers and works with all programming languages.
The full and flexible audit log eliminates huge log files or endless searching. The audit log can be searched using filters and detailed search criteria, so the requested is found fast and efficiently.
The system was created for the current domain name Registry-Registrar-Registrant model but could easily accommodate a direct Registry-Registrant relationship, for which a web interface is particularly useful. 

2. Technical Features

2.1. WHOIS and Domain Availability Service (DAS)
End users (Registrants) are expected to have access to the contact details of a domain name holder. The WHOIS module complies with the ICANN standards, but offers optional flexibility with two different accesses : the WHOIS giving the full details (if allowed) of the domain name holder, and DAS (Domain Availability Service) which only shows whether the domain name is available or not. WHOIS data is fully configurable to meet existing or future data protection requirements, with each field able to be switched on or off. It can be accessed via both a web interface (CAPTCHA protected, where the user needs to enter a verification code to avoid machine-generated queries) or via port 43.
Open Registries may find other uses for their WHOIS data to benefit both the Registry Operator and Registrants, such as a search capable WHOIS on the domain name database to find domain names or Registrants in a particular industry or area. Profiles can be set up to determine which information is displayed.
WHOIS and DAS functionalities are described in detail in response to question 26.

2.2. DNSSEC Enabled
In compliance with ICANN requirements, the applied-for TLD will be DNSSEC enabled from day one. Additionally, a DNSSEC solution is offered for the Registrars that they can implement with minimum disruption to their own systems. The implementation of DNSSec is described in detail in response to question 43.

2.3. DNS Service
The DNS infrastructure consists of an own set of redundant unicast nameservers running various flavors of operating systems and DNS software, and a set of high quality anycast nameserver providers. These services are provided by machines distributed all over the world over the IPv4 and IPv6 network and using DNSSEC.
1) Real-time DNS updates compliant with RFC 2136
2) DNS Services implemented using ISC BIND, compliant with RFC 1034, RFC 1035, RFC 1101, RFC 2181, RFC 2182, and RFC 3007
A detailed description of the DNS service is provided in the response to question 35.

2.4. Tailored Contact Types
When a domain name is registered, the Registrant must provide the Registrar of the domain name with valid and up-to-date contact information. In theory, by looking up the domain name in any public WHOIS database, anyone is supposed to be able to view this registration information, and thus contact the person or company that owns it (Registrant or Licensee). The Registry Platform allows specifying tailored contact types to suit the Registry Operator’s need. Each contact type can contain the default set of contact data or fields specified.

2.5. Dynamic Zone Files
The Registry Platform provides a dynamic zone file update, ensuring that, when a domain name is registered, it is available for use immediately.

2.6. Internationalized Domain Name (IDN) Compatible
The Registry Platform is IDN compatible and does not rely on the domain name Registrar to convert natural script into punycode. The Registrar simply needs to enter the required information in natural language and the Registry Platform will do the rest. This applies for both EPP and web interfaces.
A detailed description of the implementation of IDN is provided in the response to question 44.

2.7. Nameserver Groups
The Registry Platform can create nameserver groups. A nameserver group contains a list of nameservers that can be linked to a domain name. This can be used instead of individual nameservers on a domain name. When one nameserver is replaced by another, nameserver groups deal with this change in one update that is then propagated to all domain names linked to that group. When using individual name-servers, all domain names using the old name servers need to be updated.

2.8. Extranet
The extranet option allows the Registrant to access and, when permitted, modify his data at the Registry Operator level. It can also be used by the Registrant to approve trade or transfer of a domain name. If needed, the Registrant can be given access to the extranet to switch on some levels of control. For instance, the Registrant can ask to be informed of any change of data made by the Registrar. Similarly, the Registrant can choose to be informed by e-mail when his domain name is scheduled for deletion. In this case, the modification or deletion can only be executed after confirmation from the Registrant.

2.9. Sunrise
The Registry Platform accommodates multiple types of Sunrise arrangements, including first-come-first-served validations or a defined Sunrise window that sends all applications for validation. Rules for the sunrise period can be set such as the type and location of applicant and type, or the dates and geographical coverage of prior IP rights.

2.10. Validation Management
The Registry Platform can provide a direct link to any Trademark Clearinghouse that ICANN may choose, thus encouraging more brand owners to participate in the Sunrise. Validation options include selection of names which are excluded from registration, which are Premium names, and include an auction process for competing applications.

2.11. SRS Registration and Flexible Permissions
SRS is short for Shared Registry System. The Registry Platform offers, besides the access through EPP required by ICANN, the capability to register domain names via the web. The Registry Platform includes a module that allows for flexible permissions for all users. This is very useful to give different permissions to different types of users for different sets of actions, for example to define what certain Registrars or Resellers can or cannot do. These permissions can be applied to different transactions in the system, allowing staying in total control of the TLD.

2.12. Registrar Interface
1) Fully documented client Application Programming Interface (API)
2) Web interface to allow Registrars full control of names under their management
3) Easy to use and fully compatible with Extensible Provisioning Protocol (EPP)
4) Extra modules provide feature rich experience

2.13. Extensible Provisioning Protocol (EPP)
1) Full EPP compliance with RFC 3730 and RFC 4930
2) Supports standard EPP object mappings for an Internet Domain Name Registry RFC 4931, RFC 4932, and RFC 4933
3) Multi-layer authentication
4) Includes support for implementing EPP extensions
5) Highly configured EPP Service to ensure that Regulator and Registry Operator Policy is adhered to with minimal intervention
6) Works with any RFC compliant EPP server
A detailed description of the implementation of EPP is provided in response to question 25.

2.14. Hidden Master Nameservers
The master nameserver, which interfaces directly with the Registry Database, provides all slave nameservers with the current registration and database information, but cannot be accessed by third party users. This provides optimal security and integrity for the Registry Database.

2.15. Variable Renewal Period
The Registry Platform allows for configuration of the renewal period, with a maximum of 10 years. By default, domain names are renewed every year, but this could be set to any other period, within the limits imposed by ICANN.

2.16. Length Limitations
The Registry Platform allows for the definition of criteria in terms of the length of the registered domain name. This feature can be used for example, to avoid the creation of two and three letter domain names within the TLD.

2.17. String Blocking
This feature allows for blocking of simple or complex ‘strings’ from being used in domain names. Examples include the name of competitors of the Registry Operator for a brand TLD, parts of that name, or foul language.

2.18. Automatic Transfer and Trade Handling
The Registry Platform is capable of automatically handling all transfers and trades using a proven automated process of approval by the Registrants. When a transfer is initiated, the current owner receives an e-mail requesting approval. In case of a trade, the new owner also receives an e-mail. Only when all parties involved have electronically given their approval is the transfer or trade scheduled for automatic execution.

2.19. Registrar Dashboard
The Registrar has a dashboard to verify the current status of the Registrar account. This includes a number of statistics on domain names in portfolio, domain names recently registered, transferred in and out, etc. These statistics are also provided over a longer period of time, allowing the Registrar to conduct statistical analysis of the portfolio. The interface also provides an overview of transaction failures and the reason why, if applicable. It also shows a detailed financial status.

2.20. Registrar Export
The Registrar web provides a separate page where the Registrar has bulk access to the entire portfolio of domain names, contacts and all other useful information stored in the database linked to the Registrar’s account. The data is available in various formats including XLS, CVS and XML. This provides the Registrar with ample facility to verify portfolio and import data into and verify data against any external system used by the Registrar.

3. Financial Features

3.1. Pricing Model
The Registry Platform’s management module allows the Registry Operator to create pricing models as needed. Prices can be set for each type of operation and can have an associated validity period. Price changes can easily be implemented and put in the system with a specific starting date.

3.2. Pre-payment System
For each domain name Registrar, an account is provisioned in the Registry Platform. Every paying transaction reduces the account balance by the corresponding fee. When the account does not contain enough funds, the transaction will not finish successfully. This method eliminates the risk of bad debtors. Invoices are generated at the end of each month for the transactions executed and paid for in the previous period. This flexible system also allows for a post-payment application.

3.3. Credit Lines
While the pre-payment system does not allow a Registrar to execute paying transactions, such as registering a new domain name, a credit mechanism is available that allows the Registry Operator to give a Registrar a credit line for a specific period and a specific amount. During that period, the Registrar’s account may temporarily run negative for the specified amount.

3.4. Invoicing
The Registry Platform allows for both an automated as well as an explicit renewal. Both options occur at the end of the month in which the renewal is due. Payments must be made with the Registrar’s pre-payment accounts, although the Registry Operator can give a particular Registrar a credit line for a specific period. Monthly invoices, detailing all transactions that have occurred in the previous month, are generated by the Registry Platform.

3.5. Payments
The Registry Platform’s management module keeps track of all payments that have been entered into the system. Registrars can access their complete invoice and payment history via the web interface.

3.6. Early Warning System
The Registry Platform contains a system of threshold to prevent the Registrar’s account from going negative. When the prepay account drops below a certain threshold level, an email will be sent to the Registrar to inform him, thus allowing the Registrar to transfer sufficient funds into the account in time.

4. Third Party Modules

4.1. Alternative Dispute Resolution (ADR) Extranet
In the event that a dispute arises over a domain name, the status of the domain name in question needs to be blocked. This is required to prevent the current holder from changing crucial data. As timing is very important, the Registry Platform includes a simple interface for the Alternative Dispute Resolution (ADR) provider that allows placing the disputed name on hold or in use again according to the outcome of the deliberation. Furthermore, if a complaint is launched against a domain name, the Registry Operator can permit the ADR dispute resolution service provider to log in and suspend any transactions on the name until the process is complete. When the dispute is resolved, the ADR provider can either remove the suspension or force a transfer according to the applicable rules and procedures of the UDRP (Uniform Domain-Name Dispute Resolution Policy).

4.2. Extranet
If applicable, the extranet option allows the Registrant to access and, when permitted, modify his data at the Registry Operator level. It can also be used by the Registrant to approve his trade or transfer. If needed, the Registrant can be given access to the extranet to switch on some levels of control. As a first level, the Registrant can ask to be informed of any change of data made by the Registrar. Similarly, the Registrant can choose to be informed by email when his domain name is scheduled for deletion. If the Registrant chooses the second level of security, the modification or deletion can only be executed after confirmation from the Registrant.

4.3. Sunrise Process Management
The Registry Platform accommodates multiple types of Sunrise arrangements, including first-come-first-served validations or a defined Sunrise window that sends all applications for validation. Rules for the Sunrise period can be set, for example, the type and location of applicant and type, or the dates and geographical coverage of prior IP rights.

4.4. Validation Management
The Registry Platform can provide a direct link to any Trademark ClearingHouse that ICANN may choose to operate, thus encouraging more brand owners to participate in the Sunrise. Validation options include selection of names which are excluded from registration, which are Premium names, and include an auction process for competing applications. The Registry Platform is by default compliant with the Trademark Clearinghouse.

4.5. Escrow Module
The escrow module allows for an easy transfer of full and incremental backups to one of ICANNʹs accredited escrow providers. Reports of all exchanges are kept and combined in a monthly report. Emergency backup procedures and verification scripts can be added.
A detailed description of the data escrow is provided in the response to question 38.
 

1. Overview
The Shared Registration System (SRS) is a computer system for managing a domain name Registry, and allows for the registration, by authorized Registrars, of domain names and modification of information associated with that domain name on the Registry level. 
The SRS has two matching subsystems: an Extensible Provisioning Protocol (EPP) server and a Registrar web interface.

2. High-Level SRS System Description

2.1. Infrastructure
The SRS platform consists of several services. These services provide the Registrar with access to the database. Registrarʹs access is limited to objects created and maintained by the Registrar. No other means than the SRS are provided to the Registrar to modify objects. The SRS system runs on a virtualized and strictly separated infrastructure to maintain consistency and security and provide for scalability and availability. For more information, reference is made to the relevant sections in question 31 (Technical Overview of the Proposed Registry), question 32 (System & Network Architecture) and Q33 (Database Capabilities).

2.2. Extensible Provisioning Protocol
As required by Specification 6 (section 1.2) and as detailed in the answer on Question 25 on the Extensible Provisioning Protocol (EPP), the Registry Operator will comply with the relevant existing RFCs. The Registry Operator will also, if applicable, implement the relevant RFCs published in the future by the Internet Engineering Task Force (IETF) including all successor standards, modifications or additions thereto relating to the provisioning and management of domain names using the Extensible Provisioning Protocol (EPP) in compliance with RFCs 5910, 5730, 5731, 5732, 5733 and 5734.
Extensive testing will verify that the software performs according to the performance specifications as required by Specification 10 for EPP.
The response to question 25 provides full details on the EPP implementation.

2.2.1. Security
Access to the EPP server system is restricted in three ways:
1) Access control to the production EPP server is restricted by IP address filters;
2) SSL encryption is required for the communication channels between the Registrarʹs client system and the OT&E (Operation Test & Evaluation) and Production EPP servers;
3) Authentication by means of a user name and a strong password is required for session establishment.
The EPP server requires that all three mechanisms must be correctly adhered to before access is granted.
The IP addresses from which the Registrar wants to connect to the EPP server must be registered through the Registrar web interface (maximum 5 IP addresses per Registrar, subject to evaluation).

2.3. Registrar Web Interface
The Registry Operator will, in addition to the EPP server system, also run a Registrar web interface. This web interface can be used besides or instead of the EPP server interface to manage the registration and modifications of domain names and the information associated with those names.
The web interface has two parts: managing the objects in the domain name Registry database, and managing the Registrarʹs business account information.

2.3.1. Managing Objects in the domain name Registry Database
The management of the objects in the database via the web interface is based on the same software code as for the EPP server implementation. The different subparts of managing the objects in the database are: maintaining domain names, maintaining contacts and maintaining hosts.
1) Maintain Domain: The interface allows to easily find, check, query, add, update, renew, transfer or delete domain names from the Registrar account. As an extra feature, the history of the domain name can be explored (if the domain name resides in the Registrarʹs account).
2) Maintain Contact: The interface allows to easily find, check, query, add, update or delete contact information. Also the history of the contact can be listed (if the contact stays in the Registrarʹs account).
3) Maintain Host: The interface allows to simply find, check, query, add, update or delete host information from the Registrar account. Also the history of the host object can be viewed (if the host object is in the Registrarʹs account).

2.3.2. Managing the Registrar Account
The Registrar Profile page allows the Registrar to
1) View, add and update own contact information for administrative, technical, commercial and financial purposes;
2) Add and update the IP addresses required for access to the EPP server (see above);
3) Add and update the different email addresses of the Registrar where he can be reached by the Registry Operator for administrative, technical and financial purposes;
4) View hitpoints (attributed when the EPP client software behaves erratically), and resume the Registrar account (when hitpoints reach a defined threshold, the Registrar account is suspended temporarily).
The financial information pages reveals
1) Account balance overview;
2) Overview of invoices and payments, with details; 
3) Overview of possible renewals in coming months.
The reports page provides customized reports on gained and lost domain names (via transfers), on nearly expired domain names and on the latest transactions (per object type and transaction type).
The export page offers downloads of full exports of contacts, domain names and hosts in different formats (CSV, XLS, XML), to allow the Registrar to consolidate and cross-check his own data.

2.3.3. Security
Access to the Registrar web interface is restricted in three ways:
1) HTTPS encryption is required for the communication between the Registrar and the OT&E and production Registrar web interfaces;
2) Authentication by means of a user name and password is required;
3) Extra passphrase authorization to confirm transactional commands (create⁄modify⁄delete).
All communication is encrypted and secured using the SSL⁄TLS protocol. The main idea of HTTPS is to create a secure channel over an insecure network. Adding a trusted and verified server certificate ensures reasonable protection from eavesdroppers and man-in-the-middle attacks.
Security is augmented by requiring an extra passphrase authorization to complete all transactional commands on the SRS system.

2.3.4. Redundancy & Scalability
The SRS system runs on a mini-cloud virtualizing all machine infrastructures needed (for further information on, for instance the number of servers, see question 32). Not only does this improve high-availability and scalability, it also allows for very fine grained access control improving security and mitigating network cross connections. The cloud can be distributed over the two sites allowing for a full hot-standby mirror site. Using network based traffic mirroring, resources are scaled and load balancing and fail-over are implemented.
The synchronization scheme for the Registry database, which contains all information used by the Shared Registration System, is described in full detail in the response to question 33 (Database Capabilities). The database is continuously synchronized. 
Dynamic updates are implemented on the nameserver infrastructure. All changes to the database are immediately synchronized to the worldwide nameserver infrastructure, with an average delay of 10 seconds.

3. Resourcing Plan

3.1. Technical Resources

3.1.1. Network
The Registry Platform is based on a full redundant network setup, based on different technologies that together form a reliable setup. The network setup is greatly detailed in the answer on Question 32 on Network & System Architecture, and consists of:
1) Multi-homed network with own IP-range and Autonomous System number (AS) announce via Border Gate Protocol (BGP);
2) Redundant routers and firewalls;
3) Fully redundant internal network for interconnection between the Registry Services.
Network security measures include: 
1) Traffic shaping (on SYN packets) on the routers to minimize impact of (Distributed) Denial Of Service attacks; 
2) Stateful firewall to limit access to service ports only;
3) Limiting source IP addresses per Registrar to connect to EPP server system;
4) Network separation using VLAN (IEEE802.1q) technology to separate service and data plane;
5) Private firewall on every server.

3.1.2. Servers
The EPP server and the Registrar web interface are running on their own respective machines. Virtualization is used to make the service machines independent of the underlying hardware.

3.1.3. Interconnectivity with other Registry Services 
The Shared Registration System (SRS) maintains the objects in the core database from a Registrarʹs perspective. All other Registry systems such as the WHOIS service, the data escrow system, the (dynamic) zone file generator,... all use the core database.
The Registry Operator implements a thick Registry model, and as such the full data are present in the core database. There is no need to synchronize the data from different source databases into the master database.
As detailed in the answer on Question 33 on Database Capabilities, the Registry Operator is using hot-standby database replication for redundancy and fail-over, and if the load on the system should require so, the WHOIS system can be off-loaded to another hot-standby read-only copy of the core database, which is near-synchronous with the main database.
Note that the network and system setup on the primary site is duplicated on a mirror site.
(View attachment for Figure 1: Interplay of Registry Services)
Other services such as the dynamic updates of the zone file, zone file generation and escrow use the database or a trigger mechanism to update the relevant resources when the Registrar updates objects in the database.
All changes to the database are tagged and linked to a transaction description also specifying the relevant time stamp, user and IP address. The information can be used to provide a full audit trail or to pinpoint invalid or illegal behavior. 

3.2. Personnel
With regards to resourcing, reference is made to the global resourcing scheme as part of response to Question 31 (Technical Overview of the Proposed Registry). Implementation and maintenance of the Shared Registration System is under the authority of the Software Developer, under control of the Operations Manager. The technical infrastructure is implemented and maintained by the Network & System Administrator.

1. Overview
The Registry Operator will comply with the latest version of the Extensible Provisioning Protocol (EPP). The domain name Registry is designed to strict EPP standards from the ground up. No proprietary EPP extensions have been developed. Upon selection of the Trademark Clearinghouse (TMCH) provider by ICANN, the EPP implementation will be complemented with an interface towards the TMCH, in line with community defined interface specifications.

2. EPP Registry – Registrar Model
The domain name Registry implementation features a ʺthickʺ model as represented by the rich object store managed by the centralized domain name Registry. 
This object store can be managed by accredited Registrars via the EPP interface that will be using the interface protocol specified by the current EPP standard. 
The EPP specification is broken up into an extensible object design with each of the primary objects given an individual but consistent interface that meet the base EPP framework as described below.
 
2.1. EPP Protocol Highlights

2.1.1. RFC 5730 - Extensible Provisioning Protocol (EPP)
This document describes the foundation upon which all the specific objects (Domain names, Hosts, Contacts) must adhere to in order to maintain a consistent interface. A standard domain name Registry specific extensible object management framework is also described in this document to handle any extra information need to satisfy policy or other agreements the domain name Registry may be required to sustain.

2.1.2. RFC 5731 - Extensible Provisioning Protocol (EPP) Domain Name Mapping
This document describes an EPP mapping for the provisioning and management of Internet domain names stored in a shared central repository. Specified in XML, the mapping defines EPP command syntax and semantics as applied to domain names.

2.1.3. RFC 5732 - Extensible Provisioning Protocol (EPP) Host Mapping
This document describes an EPP mapping for the provisioning and management of Internet host names stored in a shared central repository. Specified in XML, the mapping defines EPP command syntax and semantics as applied to host names.

2.1.4. RFC 5733 - Extensible Provisioning Protocol (EPP) Contact Mapping
This document describes an EPP mapping for the provisioning and management of identifiers representing individuals or organizations (known as ʺcontactsʺ) stored in a shared central repository. Specified in XML, the mapping defines EPP command syntax and semantics as applied to contacts.

2.1.5. RFC 5734 - Extensible Provisioning Protocol (EPP) Transport over Transmission Control Protocol (TCP)
This document dictates the TCP connection strategies to use. The implemented transport layer is conform to RFC 5734 and RFC 2246. RFC 5734 specifies the low level transport and allows for a typical TCP connection to be used to serve as a client-server communication channel. To secure the communication between client and server, an obligatory Transport Layer Security (TLS) layer is run on top of the TCP connection, as specified in RFC 2246.
A number of security settings no longer comply with current security needs and are prohibited in RFC 6176. The security algorithms that are allowed to communicate were chosen to be secure and compliant with a wide variety of implementations currently in use on most operating systems. These security algorithms include Advanced Encryption Standard (AES) and Triple Data Encryption Standard (TripleDES) for encryption and RSA for negotiation.

2.1.6. RFC 5910 - Domain Name System (DNS) Security Extensions Mapping for the Extensible Provisioning Protocol (EPP)
This document describes the DNSSEC Extensions Mapping for EPP for the provisioning and management of DNS security extensions stored in a shared central repository. Specified in XML, the mapping defines EPP DNSSEC extensions to the command syntax and semantics as applied to domain names.

2.1.7. RFC 3915 - Domain Registry Grace Period Mapping for the Extensible Provisioning Protocol (EPP)
This document describes the Registry Grace Period (RGP) Extensions Mapping for EPP for the management of domain names subject to “grace period” policies defined by ICANN. Specified in XML, the mapping defines EPP RGP extensions to the command syntax and semantics as applied to domains.

2.2. Supported Command Set
A full set of EPP commands is implemented, as specified in the above mentioned RFCs. The EPP service provides all commands specified in the RFCs 5730, 5731, 5732, 5733, 3915 and 5910 in a fully functional fashion. The commands are implemented conform the specifications set forth in the RFCs. The fully compliant XSD schema describing the XML layout which can be used to validate the XML command can be found in RFC 5730-5733, 3915 and 5910. 
Please note that two extensions are implemented:
1) RFC 3915 is a specific extension to implement the “grace period” policies, both in providing extra information to the Registrar, as well as the possibility to restore a domain name from redemption.
2) RFC 5910 is a specific description to comply with the DNSSEC extension, as is required by the Applicant Guidebook, to manage the DNSSEC keys of the domain name.
The domain name Registry will provide the following command sets to support the Registry Service:
1) Greeting
2) Session management
3) Object Query
4) Object Transform 
All commands from the EPP client to the EPP server run over an encrypted connection. The EPP client has to identify itself by using the predefined session management command 〈login〉 using unique and out-of-band communicated credentials.
The command sets are described in detail below.

2.2.1. Greeting
The EPP server will respond to a successful connection by returning a greeting to the client. The greeting response includes information such as:
1) The name of the server
2) The serverʹs current date and time in Coordinated Standard Time (UTC)
3) The features supported by this server, which may include:
a) One or more protocol versions supported by the server
b) One or more languages for the text response supported by the server
c) One or more 〈objURI〉 elements which identify the objects which the server is capable of managing
d) An optional 〈svcExtension〉 element that contains one or more 〈extURI〉 elements that contain namespace URIs representing object extensions supported by the server. Here the EPP server will announce support for rgp-1.0 (as defined in RFC 3915) and for secDNS-1.1 (as defined in RFC 5910).
At any time a 〈hello〉 command can be used to receive a 〈greeting〉 response.

2.2.2. Session Management
EPP provides two commands for session management: 〈login〉 to establish a session with a server, and 〈logout〉 to end a session with a server.
1) Login: The EPP 〈login〉 command is used to establish a session with an EPP server in response to a greeting issued by the server. A 〈login〉 command MUST be sent to a server before any other EPP command.
2) Logout: The EPP 〈logout〉 command is used to end a session with an EPP server.

2.2.3. Object Query Commands
EPP provides three commands to retrieve object information: 
〈info〉 to retrieve detailed information associated with a known object,
〈check〉 to determine if an object is known to the server, and 
〈transfer〉 to retrieve known object transfer status information. These are described into further detail below.
1) Info: The EPP 〈info〉 command is used to retrieve information associated with a known object. The elements needed to identify an object and the type of information associated with an object are both object-specific, so the child elements of the 〈info〉 command are specified using the EPP extension framework.
2) Check: The EPP 〈check〉 command is used to determine if an object is known to the server. The elements needed to identify an object are object-specific, so the child elements of the 〈check〉 command are specified using the EPP extension framework.
3) Poll: The EPP 〈poll〉 command is used to discover and retrieve notification messages queued by the server for individual Registrars. Some elements are object-specific, so the child elements of the 〈poll〉 response are specified using the EPP extension framework.
4) Transfer (Query): The EPP 〈transfer〉 command provides a query operation that allows a client to determine real-time status of pending and completed transfer requests. The elements needed to identify an object that is the subject of a transfer request are object-specific, so the child elements of the 〈transfer〉 query command are specified using the EPP extension framework.

2.2.4. Object Transform Commands
EPP provides five commands to transform objects:
 〈create〉 to create an instance of an object with a server, 
〈delete〉 to remove an instance of an object from a server,
 〈renew〉 to extend the validity period of an object,
 〈update〉 to change information associated with an object, and
 〈transfer〉 to manage changes in client sponsorship of a known object. These are described into further detail below.
1) Create: The EPP 〈create〉 command is used to create an instance of an object. An object may be created for an indefinite period of time, or an object may be created for a specific validity period. The EPP mapping for an object MUST describe the status of an object with respect to time, to include expected client and server behavior if a validity period is used.
2) Delete: The EPP 〈delete〉 command is used to remove an instance of a known object. The elements needed to identify an object are object-specific, therefore the child elements of the 〈delete〉 command are specified using the EPP extension framework.
3) Renew: The EPP 〈renew〉 command is used to extend the validity period of an object. The elements needed to identify and extend the validity period of an object are object-specific, therefor the child elements of the 〈renew〉 command are specified using the EPP extension framework.
4) Transfer: The EPP 〈transfer〉 command is used to manage changes in client sponsorship of a known object. Clients may initiate a transfer request, cancel a transfer request, approve a transfer request, and reject a transfer request.
5) Update: The EPP 〈update〉 command is used to change information associated with a known object. The elements needed to identify and modify an object are object-specific, therefore the child elements of the 〈update〉 command are specified using the EPP extension framework.
All above transform commands can be processed by the Registry Operator in two ways:
1) immediately process the requested action;
2) initiate processing the requested action, but allow for off-line review or further interaction before completing the requested action. The response of the EPP server will clearly note that the requested action is “pending”.
In the latter case the state of the corresponding object will clearly reflect processing of the pending action. For more information on the domain name states, reference is made to the response to Question 27 (Domain Name Lifecycle).

2.3. Functionality to provision Registry services
To comply with the current EPP standard, a fully functional set of commands is at the Registrar’s disposal. These functions are based on the CRUD (Create – Read – Update – Delete) principle. The state of the data is maintained by creating (C), reading (R), updating (U) and eventually deleting (D) the data from the database. 
The following basic objects exist in the database:
1) Domain: The domain object contains all relevant information to the domain name. This includes registration date, renewal date, status and DNSSEC key material.
2) Host: A host object defines a hostname which might be linked to a domain name. It is intrinsically needed to get the domain name working. It contains at least a domain name, possibly IP addresses and other references.
3) Contact: The contact object specifies a person or an organization. It contains various fields to identify such party. When linked to a domain name, a specific role is attributed to the relation.
The following commands, per object, allow for the full CRUD cycle to be implemented conform the above specified relevant RFCʹs. Please note that the read commands as referred to in the CRUD terminology are defined as query commands in the EPP-centric documentation. All objects are attributed to a specific Registrar and remain under its supervision. No other Registrar is granted access to these objects.
Registrars should first verify if the object is manageable (and owned) by using the 〈check〉 command. To get the content of an object, use the 〈info〉 command.
(View attachment for Table 1: Commands per object type)
By assigning a Registrar to all objects, a unique identifiable party is assigned to any object as the owner that is allowed to change and delete the object. To maintain a history of all changes, both a full trace log identifying Registrar, IP address, time and command as well as a history of the objects are stored in the database. This allows for a swift reconstruction of any interaction with the system. For more information we refer to the response to Question 33 of the evaluation criteria (Database Capabilities).

3. EPP Extensions
In order to be compliant with ICANNʹs Applicant Guidebook, an additional extension to maintain the domain object is needed to integrate with the Trademark ClearingHouse (Module V of ICANN’s Applicant Guidebook).
At the moment, no party has been appointed to perform the TradeMark Clearinghouse function, hence no specifications for interfacing have been established.
The function of the TradeMark Clearinghouse is to enable trademark holders to register their right in a central database, from where the trademark holder receives a validation code that can be used to apply for a domain name in a new TLD.
To that extent, ongoing community effort led already to a Launch Phase Mapping for EPP. This Internet-Draft describes an extension mapping for EPP that specifies a flexible scheme that can be used to implement several common use cases related to the provisioning and management of launch phase extension in a domain name Registry.
This mapping enables the Registrar to apply for⁄claim a domain name in the sunrise phase using the Pre-Validation Result Code 〈pvrc〉 from the TM Clearinghouse.

4. Security
It is imperative to make sure the service is not blocked by Denial Of Service attacks (DOS). To prevent this from happening, a number of security barriers are in place:
1) rate limiting the number of connections on the border router;
2) allowing only specific IP addresses specified by the Registrar;
3) limiting the number of concurrent connections per Registrar.
The EPP service will run on its own virtual machine. Resources available to the machine are constantly monitored. Early warnings are sent out in case any of the resources are deemed to be inadequately provisioned.
Security is enhanced by limiting the access to the EPP server to a Transport Layer Security (TLS) connection using high-grade encryption. 
The Registrar is authenticated using the predefined session commands as defined in the above RFCs. The initial credentials are exchanged between the Registry Operator and the Registrar over an out-of-band channel.
A strict object-to-Registrar link exists such that a Registrar can only view, access and modify its own managed objects. 

5. Resourcing Plan

5.1. Technical Resources
This service is delivered by a JAVA application running on a TOMCAT server. To ensure the database is consistent at all times, a lock is set per Registrar to ensure multiple connections set up by a Registrar are serialized at the application level. To maintain high speed at all time, a locking mechanism is also active at the domain name level, ensuring no two domain name registrations for the same domain name are modified, while still allowing the necessary concurrency.
Experience has learned that, under high load conditions, the bottleneck will rather be located at the database level, and not at the application level. If extra CPU power is required to deal with high volumes, an extra EPP service will be provided using an alternate IP address or using a load balancer.
To improve database security, the EPP serverʹs access to the database is limited to a specific separate network. For a more complete and detailed picture, reference is made to the response to Question 32 of the evaluation criteria (System & Network Architecture).

5.2. Personnel
With regards to resourcing, reference is made to the global resourcing scheme as part of response to Question 31 (Technical Overview of the Proposed Registry). Implementation and maintenance of the Extensible Provisioning Protocol is under the authority of the Software Developer, under control of the Operations Manager. The technical infrastructure is implemented and maintained by the Network & System Administrator.

1. Overview
The Registry Operator will operate a WHOIS service available via port 43 in accordance with RFC3912. This standard service is intended as a lookup service for Registry Operators, Registrars, Registrants, as well as for other individuals and businesses that wish to query details of domain names or nameservers stored in the domain name Registry and that are public. The standard WHOIS service provides a central location for all authoritative data the Registry has on the domain name. The Registry Operator also provides a front-end web interface to allow for convenient user access to the WHOIS service.
The Registry Operator will also operate a Domain Availability Service (DAS) via port 4343. Reference is made to section 5 of this response for further detail.
All WHOIS⁄DAS services are connected to the main domain name Registry database. If and when it is necessary for operational stability reasons, the WHOIS server can be duplicated, and connected to one or more read-only hot standby database mirrors. These mirrors are updated a-synchronously via streaming replication, which results in a near real-time data duplication.

2. WHOIS Service

2.1. RFC-3912 Compliant WHOIS
The RFC3912-conformant WHOIS service is engineered to handle moderate transaction load and is part of the standard suite of Registry Services. The WHOIS service will return a single response per domain name or nameserver query. The RFC3912-conform WHOIS service will comply with the requirements of Specification 4 of the Registry Agreement.
The RFC3912-compliant service provided by the Registry Operator will have the following features:
1) Standard protocol accessible over the common WHOIS port 43;
2) Near real-time updates;
3) The format of responses follows a semi-free text format outline below, followed by a blank line and a legal disclaimer specifying the rights of the Registry Operator, and of the user querying the database;
4) Each data object is represented as a set of key⁄value pairs, with lines beginning with keys, followed by a colon and a space as delimiters, followed by the value;
5) For fields where more than one value exists, multiple key⁄value pairs with the same key are allowed (for example to list multiple name servers). The first key⁄value pair after a blank line should be considered the start of a new record, and should be considered as identifying that record, and is used to group data, such as hostnames and IP addresses, or a domain name and Registrant information, together;
6) The format of the following data fields is: domain status, individual and organizational names, street, city, state⁄province, postal code, country, telephone and fax numbers, email addresses, date and times conform to the mappings specified in EPP RFCs 5730-5734 so that the display of this information (or values return in WHOIS responses) can be uniformly processed and understood.

2.2. WHOIS Service data elements
The RFC3912-conform service will include the following data fields:
1) The name of the domain name registered;
2) The IP addresses of the primary nameserver and secondary nameserver(s) of the name registered, if applicable, and the corresponding names of those nameservers;
3) The identity of the Sponsoring Registrar;
4) The original creation date and term of the registration;
5) The name, postal address, e-mail address, voice telephone number, and (if available) fax number of the domain name Registrant;
6) The name, postal address, e-mail address, voice telephone number, and (if available) fax number of the technical contact for the domain name registered;
7) The name, postal address, e-mail address, voice telephone number, and (if available) fax number of the administrative contact for the domain name registered.

2.3. WHOIS Data update frequency
The Registry Operator will be running a thick Registry model, so the data will be readily available and doesnʹt need to be collected from the Registrars. The WHOIS service will query the main database, or, if database load or operational reasons demand, will query a hot standby read-only database mirror. In case of querying the main database, the data is always up-to-date, in case of querying a mirror database, the data is updated continuously via streaming replication and is near real time up-to-date (in a matter of seconds or minutes).

2.4. Privacy Capability
The Registry Operator will protect the privacy of an individual where required. If the Registrant of a domain name is an individual, the WHOIS service could disclose only limited information on the Registrant. If the Registrant wishes to disclose more information, he can instruct the Registrar to update the corresponding contact object in the Registry database (e.g. using the 〈contact:disclose〉 statement in EPP according to RFC5733). 
If legislation mandates to avoid automatic harvesting of the Registrantʹs details (because port 43 WHOIS is plain text), the WHOIS service could omit the Registrant details and refer the initiator of the query to the web-based WHOIS where the WHOIS data will be disclosed in a multiple-step process.

2.5. Query Control – Object Type Control
The following keywords restrict a search to specific object type:
1) Domain: Search only by domain objects. The input string is searched in the Domain Name field.
2) Contact: Search only contact objects. The input string is searched in the Contact ID field.
3) Nameserver: Search only by nameserver objects. The input string is searched in the nameserver field and the IP address field.
4) Registrar: Search only Registrar objects. The input string is searched in the Registrar ID and Registrar Name fields.
By default, if no object type control is specified, then the Name field of the Domain object is searched.

3. WHOIS Output fields

3.1. Domain Records

3.1.1. Introduction
The WHOIS server can answer a domain name query in three different ways:
1) The domain name is registered in the domain name Registry database, a typical response is detailed in section 3.1.2;
2) The domain name is not registered, nor available for registration, because of various reasons, such as appearing on the blocked or reserved list, as specified in the Applicant Guidebook (see article 2.6 of the Registry Agreement), or for policy reasons. A typical response is detailed in section 3.1.3.
3) The domain name Registry has no information on the domain name in the request. A typical response is detailed in section 3.1.4.

3.1.2. Domain Name is registered
A WHOIS query that results in domain name information will return the following fields from the domain object and the associated data from host and contact objects. This set of data is also referred to as the Domain Record.
1) Domain Name (both A-label and U-label for IDN domain names, see response to Question 44 on Internationalized Domain Names);
2) Domain ID;
3) Domain Status (several domain status codes can be shown here, such as OK or INACTIVE, a pending action status and⁄or restriction flags. An overview can be found in the response to Question 27 on Domain Name Lifecycle);
4) Sponsoring Registrar (IANA-assigned identifier) and name of Registrar
5) Registrant, Administrative, Technical Contact Information including:
a) Contact ID
b) Contact Name
c) Contact Organization
d) Contact Address, City, State⁄Province, Country
e) Contact Postal Code
f) Contact Phone, Fax, E-mail
6) Names of Nameservers and IP addresses (IPv4 and⁄or IPv6) associated with this domain
7) Creation Date
8) Domain Expiration Date
9) Domain Last Updated Date
10) DNSSEC status of delegation (signedDelegation, unsigned)
For domain names that are registered in the sunrise phase, the WHOIS can show additional labels containing sunrise information (depending on the information provided by Trademark ClearingHouse, in accordance with Specification 7 in the Applicant Guidebook).

3.1.3. Domain Name is not registered, but not available
A WHOIS query for a domain name that is not registered in the domain name Registry database, but is also not available for registration, will result in a single line with the reason of non-availability (f.i. “Reserved by Registry” or “Blocked by Registry”).

3.1.4. No information on Domain Name
A WHOIS query for a domain name for which the domain name Registry has no information, will result in a single line stating “NOT FOUND”.

3.2. Nameserver Record
A WHOIS query that results in nameserver information will return the following (this set of information is referred to as the Nameserver Record)
1) Nameserver name
2) IP address (if applicable, IPv4 and⁄or IPv6)
3) Sponsoring Registrar (IANA-assigned identifier)

3.3. Contact Record
A WHOIS query that results in contact information will return the following. This set of information is referred to as the Contact Record.
1) Contact ID
2) Contact Name
3) Contact Organization
4) Contact Address, City, State⁄Province, Country + 3 street fields
5) Contact Postal Code
6) Contact Phone, Fax (if available), E-mail
7) Create Date
8) Contact Last Updated Date
9) Contact Status (several contact status codes can be shown here, such as OK or LINKED, a pending action status and⁄or restriction flags)
10) Sponsoring Registrar (IANA-assigned identifier)

3.4. Registrar Record
A WHOIS query that results in Registrar information will return the following (this set of information is referred to as the Registrar Record)
1) Registrar ID (conforming to the IANA Registrar-ids Registry)
2) Registrar Name
3) Registrar Address, City, State⁄Province, Country
4) Registrar Postal Code
5) Registrar Phone, Fax, E-mail
6) Registrar Administrative Contacts
7) Registrar Technical Contacts
8) Registrar Billing Contacts

4. Measures for Abuse Mitigation
Measures are taken to protect the WHOIS port 43 service against bulk access:
1) The number of queries is limited per querying IP address in two different ways: a maximum number of queries per second, and a capped number of queries per hour. Excessive querying will result in a denial of the result of the query. 
2) The web-based WHOIS implements a multiple-step process to obtain the queried data, and is protected by a CAPTCHA image. Here the number of queries per day per IP address is also capped.
3) Data-mining techniques are implemented to monitor the distribution of the querying client’s IP addresses. Anomalies will be brought under the attention of the Registry Operator for further evaluation.
Often the reason for bulk access to the WHOIS service is querying the availability of the domain name (e.g. from Registrarʹs web front-ends). Therefore the domain name Registry Operator will also introduce a Domain Availability Service (DAS).

5. Domain Availability Service (DAS)
The DAS service will run on port 4343 and implements a very simple protocol, similar to the WHOIS protocol. The DAS service only indicates whether the given domain name is still available for registration or not, thereby not giving more information regarding the Registrant.
The query format: whois -p 4343 EXAMPLE.TLD
The response format: 
1) Domain Name: EXAMPLE.TLD
2) Available: yes
3) Available: no
Bulk access to the DAS service is not discouraged, but, if required by stability concerns, the number of queries per second can be capped.

6. Searchable WHOIS Capabilities
The web-based WHOIS service will also offer the possibility to partially match the domain name field. The search string must be at least 4 characters, and the wildcard operator ʹ*ʹ must be added at the beginning and⁄or at the end of the search string. The WHOIS service will then return a HTML page with a maximum of 10 matching domain names, which can be clicked to view full details.
The search capabilities can only be explored by legitimate authorized users. Candidate users of this service need to apply for access to these features, giving a legitimate reason why they would need the service.
If the applicable privacy laws and policies allow to do so, more search capabilities can be enabled on the web-based WHOIS service, conform to Specification 4 of the Applicant Guidebook.
To prevent abuse of the service, all queries are stored per user. The number of queries per month is capped.
The searchable WHOIS capabilities offers the same privacy rules as described above.
Security and Stability. The WHOIS setup has multiple overload protection systems in place: 
1) At the border of the network, rate limiting is implemented; 
2) The stateful firewall prevents abuse from a single IP address; 
3) The IDS⁄IPS prevents malformed WHOIS requests from passing; 
4) To be able to maintain a high load of WHOIS queries, a cluster of virtual machines is set up. By using port replication or broadcast MAC, no load-balancing single points of failure are introduced;
5) If the WHOIS service load on the database experiences decreasing performance, as many extra read-only copies of the Registry database as needed can be set up and used by the WHOIS server(s) to provide extra WHOIS capacity. The capacity of the WHOIS service is therefore only capped by the rate limiting that is implemented at the network edge;
6) All WHOIS (port 43) cluster nodes run as separate virtual machines.
(View attachment for Figure 1: WHOIS Network & Infrastructure Overview)

7. Resourcing Plan
With regards to resourcing, reference is made to the global resourcing scheme as part of response to question 31 (Technical Overview of the Proposed Registry). Implementation and maintenance of the WHOIS and DAS is under the authority of the Software Developer, under control of the Operations Manager. The technical infrastructure is implemented and maintained by the Network & System Administrator.

1. Overview
The registration life cycle for an open brand Domain Name Registry follows the same life cycle as for a general gTLD. 
The following sections give an overview of the different actions that the Registrar can perform to influence the state of a domain name. Some might just change the state of the domain name. Others might alter the domain nameʹs information such as name servers, contacts, DNSSEC keys and client flags. 
Some actions also involve interaction from the Domain Name Registry. 
There are two distinct phases in the TLDʹs lifespan which lead to different behavior. The first phase does not allow free registrations. It typically consists of a number of sunrise periods where different parties under different circumstances are allowed to register certain domain names. The second phase is what is referred to as general availability. It could start with a so called ʹland rushʹ period that allows the Domain Name Registry to identify popular names.

2. Registration Lifecycle
The time line of a domain name is schematically provided in Figure 1.
(View attachment for Figure 1: Domain Timeline)
In the following paragraphs we give more detail on the different steps in the time line.

2.1. Registration (or Sunrise)
1) The Domain Name Registry Operator receives the domain create command
2) The domain name goes into state pendingCreate during sunrise
3) The clearing house does validation of the domain name for the registrant
4) The domain name is registered if properly validated, or canceled otherwise.
5) Domain is registered

2.2. Update
1) Add, remove or change of tech, admin, billing contacts possible
2) Add, remove or change of name servers possible
3) Add, remove or change of DNSSEC keys possible
4) Change of registrant is possible

2.3. Transfer
1) Transfer: changing Registrar, same Registrant
2) Transfer command secured by authentication code
3) Losing Registrar notified to accept or reject the transfer (after consulting registrant and⁄or admin contact)
4) A successful transfer extends the registration period with one year (up to a maximum of ten years)

2.4. Renew
Registrars use the Renew Domain command to extend the registration period of a domain object. A Registrar can only renew domain names for which it is the sponsoring registrar. The Renew Domain command must be specified with a registration period, from one to ten years. The resulting expiry date must not lay more than 10 years in the future.
1) Domain name is renewed automatically on expiry date
2) Explicit renewal of period possible (registration period can be extended up to 10 years)

2.5. Delete
1) Deletion puts domain name in redemption status
2) Deleted from zone file instantly (serverHold)

2.6. Redemption
1) Domain name is no longer available in zone file (serverHold)
2) Domain name can be restored before the end of the redemption grace period (RGP)
3) The domain name will be purged after the pendingDelete interval

2.7. Available
1) Domain comes back in the pool of available domain names

3. RFC5731-Compliant Domain Name Status Codes
The status information on a domain name object is in line with the flags described in RFC5731, section 2.3. It is a combination of the following Status Value Descriptions:
1) clientDeleteProhibited, serverDeleteProhibited: Requests to delete the domain name will be rejected.
2) clientHold, serverHold: DNS delegation information is not published for the domain name .
3) clientRenewProhibited, serverRenewProhibited: Requests to renew the domain name are rejected.
4) clientTransferProhibited, serverTransferProhibited: Requests to transfer the domain name are rejected.
5) clientUpdateProhibited, serverUpdateProhibited: Requests to update the domain name , other than to remove this status value, are rejected.
6) Inactive: Delegation information has not been associated with the domain name . This is the default status when a domain object is first created and there are no associated host objects or host attributes for the DNS delegation. This status can also be set by the server when all host-object associations are removed.
7) Ok: This is the normal status value for an domain name that has no pending operations or prohibitions. This value is set and removed by the server as other status values are added or removed.
8) PendingCreate: Request to create a new domain name has been received and is being processed or evaluated.
9) pendingDelete: Request to delete an existing domain name has been received and is being processed or evaluated.
10) pendingRenew: Request to renew an existing domain name has been received and is being processed or evaluated.
11) pendingTransfer: Request to transfer an existing domain name has been received and is being processed or evaluated.
12) pendingUpdate: Request to update an existing domain name has been received and is being processed or evaluated.
Following combinations are excluded :
1) ok cannot be combined with any other status
2) pendingDelete status cannot be combined with ʺclientDeleteProhibitedʺ or ʺserverDeleteProhibitedʺ status
3) ʺpendingRenewʺ cannot be combined with ʺclientRenewProhibitedʺ or ʺserverRenewProhibitedʺ status
4) ʺpendingTransferʺ status cannot be combined with ʺclientTransferProhibitedʺ or ʺserverTransferProhibitedʺ status
5) ʺpendingUpdateʺ status cannot be combined with ʺclientUpdateProhibitedʺ or ʺserverUpdateProhibitedʺ status
6) pendingCreate, pendingDelete, pendingRenew, pendingTransfer and pendingUpdate cannot be combined
The status flags starting with the word ʹclientʹ can be changed and updated by the Registrar. The status flags starting with ʹserverʹ are handled by the Domain Name Registry Operator.
The Domain Name Registry will implement the above statuses in full.

4. RFC3915-Compliant Domain name status code
RFC3915 defines extra flags on the domain name that can be set or referenced by EPP.
These flags are referred to as the RGP flags (Registry Grace Period). The following flags are defined and can be found in a separately available EPP extension called the RGP extension (RFC3915).
1) addPeriod: This “add grace period” is provided after the initial registration of a domain name. If the domain name is deleted by the registrar during this period, the domain name registry provides a credit to the registrar for the cost of the registration.
2) autoRenewPeriod: This “auto-renew grace period” is provided after a domain name registration period expires and is extended (renewed) automatically by the registry. If the domain name is deleted by the registrar during this period, the registry provides a credit to the registrar for the cost of the renewal.
3) renewPeriod: This “renew grace period” is provided after a domain name registration period is explicitly extended (renewed) by the registrar. If the domain name is deleted by the registrar during this period, the registry provides a credit to the registrar for the cost of the renewal.
4) transferPeriod: This “transfer grace period” is provided after the successful transfer of domain name registration sponsorship from one registrar to another registrar. If the domain name is deleted by the new sponsoring registrar during this period, the registry provides a credit to the registrar for the cost of the transfer.
5) redemptionPeriod: This status value is used to describe a domain for which a 〈delete〉 command has been received, but the domain has not yet been purged because an opportunity exists to restore the domain and abort the deletion process. This status must be combined with the pendingDelete status in the EPP domain mapping.
6) pendingRestore: This status value is used to describe a domain that is in the process of being restored after being in the redemptionPeriod state. This status must be combined with the pendingDelete status in the EPP domain mapping.
7) pendingDelete: This status value is used to describe a domain that has entered the purge processing state after completing the redemptionPeriod state without succesful restoration. This status must be combined with the pendingDelete status in the EPP domain mapping.
The Domain Name Registry will partially implement the above RGP statuses: the statuses concerning the redemption of the domain name (redemptionPeriod, pendingRestore, pendingDelete) and autoRenewPeriod. 
We will not implement the following statuses:
1) addPeriod: because no “domain name tasting” will be allowed
2) renewPeriod: because the registrar has explicitly and successfully issued the renew command, no refund is granted;
3) transferPeriod: because the registrar has explicitly and successfully issued the transfer command, no refund is granted.

5. Status code matrix
There are two types of status values. These may change as a result of the Client initiating a transform command referring to the commands referenced in the ʹClientʹ column or by the domain name Registry referring to the ʹServerʹ column. The last column referred to as ʹGeneralʹ contains flags that transitional status values.
(View attachment for Table 1: Status Code Matrix)
The Prohibited flags have no influence on the status of the domain object. They prevent the denoted command from being executed on the domain name object. As such when set, they prevent the transform command from being executed and hence block the specified domain name life cycle transition. 

6. Status transitions

6.1. Global status transitions
The following domain name states can be determined
1) The domain name status is defined as ʹavailable for registrationʹ (in short ʹavailableʹ) if the domain name is conform to the registration policy and the domain name object does not exist.
2) The domain name is registered (no pending actions).
3) The domain name has a pending action. This can be one of the following
a) pendingCreate
b) pendingTransfer
c) pendingDelete
d) pendingUpdate
e) pendingRenew
(View attachment for Table 2: Exhaustive list of transitions)
Some transitions might be influenced by the registration policy. For instance
4) The create has to be verified by the domain name Registry to see if no conflicts or infringements are detected.
5) The name servers added to the domain name object have to comply with certain rules set forth in the policy.
6) Change of ownership has to be verified.
7) Domain name matches predefined rule set needing registry acceptance.
This is a non-exhaustive list which should reflect domain name registration policy regulations.

6.2. Registry grace period status transitions
The following domain name states are added to the domain name object when it has the EPP pendingDelete status:
1) redemptionPeriod
2) pendingRestore
3) pendingDelete
(View attachment for Table 3: Exhaustive list of 3c pendingDelete state transitions)

6.3. Registration state diagram
The Registration state diagram shows all possible states and transactions between those states.The domain name life cycle can be found in the attached flow chart (Figure 2).
(View attachment for Figure 2: Registration State Diagram)

7. Transition commands
The following domain object commands, requested by the registrar, can be used to trigger status transitions:
(View attachment for Table 4: Transition commands)

8. Registry transitions
The Domain Name Registry triggers also status transitions in case of expiration, time-outs or resolution of pending actions:
(View attachment for Table 5: Registry status transitions)

9. Resourcing Plan

9.1. Personnel
With regards to resourcing, reference is made to the global resourcing scheme as part of response to Question 31 (Technical Overview of the Proposed Registry). Implementation and maintenance of the Registration Lifecycle in the Registry Platform is under the authority of the Software Developer, under control of the Operations Manager.

1. Introduction
Applicant is aware of the fact that existing TLDs have suffered from abusive behavior. Gradually, policies have been implemented in order to prevent such issues from occurring. Hence, it is very important to Applicant that the .ltd TLD is secure and safe gTLD that does not allow such behavior protecting the internet at large. Applicant intends to do the following in order to prevent such uses:

2. An implementation plan to establish and publish on its website a single abuse point of contact responsible for addressing matters requiring expedited attention and providing a timely response to abuse complaints concerning all domain names registered in the TLD.
Applicant commits itself to publish on its website a single abuse of contact for addressing matters regarding abuse. Applicant intends to handle all complaints within 48 hours and take the necessary appropriate actions. 
According to the level of the complaints the Applicant will reserve the right to: 
1) deny, cancel or transfer any registration or transaction;
2) place any domain name(s) on registry lock, hold or similar status during the resolution of a dispute;
This in order to:
1) protect the integrity and stability of the registry; 
2) to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process; 
3) to avoid any liability, civil or criminal, on the part of the Applicant, as well as its affiliates, subsidiaries, officers, directors, and employees; 
4) to correct mistakes made by the Applicant.

3. Proposed measures for removal of orphan glue records for names removed from the zone when provided with evidence in written form that the glue is present in connection with malicious conduct
With the current setup of the Applicant we do not foresee any issues regarding orphan glue records. 
Glue records can only be inserted with the domain name itself. Inclusion is based on the fact that the name servers have the same extension as the domain name. These address records only exist by the grace of the domain name itself. Since the IP address is always linked to the domain name, the address will also disappear from the zone as soon as the domain name is removed from the registration database. Should any evidence be provided that a domain name, registered with the Applicant, is present in connection with malicious conduct, the name and glue will be simultaneously be removed. This limits the possibility of orphan glue records. 
In view of the possible risks and dangers this is a very balanced choice of limitations and it allows for a flexible and consistent handling of glue records.

4. A description of policies and procedures that define malicious or abusive behavior
Applicant intends to create and implement a Domain Name Anti-Abuse Policy containing clear definitions of what constitutes abuse.
The objective of the Domain Name Anti-Abuse Policy is to define abusive uses pertaining to Domain Name registration and Domain Name usage and the sanctions following non-compliance to this policy.
In accordance to the Applicant an abuse is an action that:
1) Causes actual and substantial harm, or is a material predicate of such harm;
2) Is illegal or illegitimate, or is otherwise considered contrary to the intention and design of a stated legitimate purpose, if such purpose is disclosed.
In the section below a distinction is made between Registration Abuses and Malicious Use of Domain Names (Domain Name Usage Abuses), as a failure to do so could lead to confusion.

4.1. Registration Abuses
The following practices are considered registration abuses and will result in sanctions taken by Applicant:
1) Cyber squatting;
2) Front-running;
3) Gripe sites;
4) Deceptive, pornographic and⁄or offensive domain names;
5) Fake renewal notices;
6) Name spinning;
7) Cross-TLD Registration Scam;
8) Domain kiting.
Detailed descriptions of these abuses will be available from the Domain Name Anti-Abuse Policy that will be published on the registration website.

4.2. Malicious Use of Domain Names
Malicious use of domain names applies to what a registrant does with his or her domain name after the domain is created—the purpose the registrant puts the domain to. 
Consequently, the following practices will be deemed to be considered as malicious use of domain names and will result in actions taken by Applicant:
1) Illegal or fraudulent actions;
2) Spam;
3) Phishing;
4) Pharming;
5) Traffic diversion;
6) False affiliation;
7) Wilful distribution of malware;
8) Fast flux hosting;
9) Botnet command and control;
10) Distribution of child pornography;
11) Illegal Access to Other Computers or Networks.
Non-compliance to the Domian Name Policy will be monitored by the Applicant.
The Applicant will reserve the right to deny, cancel or transfer any registration or transaction, or place any domain name(s) on registry lock, hold or similar status, that it deems necessary, in its discretion; (1) to protect the integrity and stability of the registry; (2) to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of Applicant, as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registrations policies or (5) to correct mistakes made by the Application. The Applicant also reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a complaint.
The abusive uses, as described above, undertaken with respect to applicable domain names can give rise to the right of the Applicant to take such actions in its sole discretion. Should a dispute occur, regarding a domain name registered with the Applicant, the domain name will be put on hold immediately. Within 48 hours after the domain name was put on hold the dispute will be resolved and the domain will be accessible again or will be deleted.

5. Adequate controls to ensure proper access to domain functions
Access to other domain functions, such as domain name update and deletion, will only possible after authentication via strong password. The following principles are used for strong passwords:
1) Users shall pick a password of sufficient complexity, which contain characters from at least 3 of following characteristics:
a) English uppercase characters (A through Z);
b) English lowercase characters (a through z);
c) Base 10 digits (0 through 9);
d) Non-alphabetic characters (for example, !, $, #, %).
2) A password should have a minimal length of 8 characters.
3) Passwords & PIN codes shall not be based on easily-guessable information, such as:
a) words from a dictionary;
b) data linked to a user (phone numbers, license plate, date or place of birth, names of the children, ...);
c) significant portions of the userʹs account name or full name.


6. Measures to promote WHOIS accuracy.
As mentioned in response to Question 26, the applied-for WHOIS will be a “thick” WHOIS, where all key contact data relating to every domain name registered in the applied-for TLD will be stored at Applicant level. 
WHOIS accuracy will be the responsibility of the registrant and registrar but will be periodically checked by the Applicant in order to ensure Whois accurarcy. Applicant intends to include this obligation in its domain name registration policies and its registrar-registry agreement.

7. WHOIS abuse prevention measures
Considering the fact that a WHOIS database contains quite some sensitive information that is available to Internet users at large over a web-based interface, the Applicant will put in place various methods in order to avoid abuse of such information by third parties.
First of all, Applicant will only display search results in response to a search query after the user has successfully entered the displayed CAPTCHA code together with such query, this in order to prevent the automatic harvesting of WHOIS data.
Furthermore, private individuals (if at all allowed by the Applicant to register and hold domain names within the TLD) will be allowed to indicate – through their registrars or via a web-based portal provided by the Applicant – that certain personal data will not be automatically displayed following a successful WHOIS query. This measure is taken in order to comply with particular applicable laws and regulations regarding data privacy.
However, parties demonstrating to the Applicant that they have a right or legitimate interest in order to obtain access to this hidden data can request access to a particular, identified record upon request to the Applicant. Positive responses to legitimate requests shall not be unreasonably withheld or delayed.
The features described above can be temporarily or permanently disabled for specific eligible parties, such as law enforcement agencies, and this upon simple request by a competent authority. These eligible parties will then obtain access to all WHOIS information via a secure, web-based portal.

8. Resourcing plans 
Applicant intends to outsource the above to reputable firms that have had experience to handle such complaints. These firms will consist out of highly technical and legal qualified staff.
An estimate of financial projections can be found in question 47.

1. Introduction
As explained above, the Applicant intends the applied-for TLD to be a restricted and closely monitored gTLD. These characteristics are mainly inspired by the Applicant’s desire to implement a trust worthy environment and to protect the reputation and rights of companies.

As stated in Question 18, Applicant will at all times implement and adhere to any and all consensus policies introduced by ICANN, so as to further the development and stability of the Internet and the global Internet community. Applicant also intends to create a governance committee that will consists of legal, technical, commercial and business advisors to review and propose policies and ensure that all polices are adhered to.

In addition, we will include all ICANN mandated and independently developed RPMs in the registry-registrar agreement entered into by ICANN-accredited registrars authorized to register names in the TLD. 
 
2. Preventing abusive domain name registrations
Applicant intends to prevent abusive domain name registrations by:

- Implementing restricted registration policies

- Performing verification and validation checks

- Putting in place a team of highly skilled team of legal and technical knowledge that will handle complaints from a dispute resolution provider or any third party.

- Implementing a Sunrise period and Trademark Services

- Implementing the decisions under the URS and UDRP

2.1. Implementing restricted registration policies.
As already stated by Applicant the purpose of the .ltd TLD is to provide companies with an extension wherein registrants can advertise their companies, services and products and relate to the extension. In addition internet users will be able to rely on the extension, knowing that the domain name and its website are indeed owned by a company registered within the Commonwealth countries (list has been included in attachment) , Ireland, China, Hong Kong and⁄or Brazil 

In addition to the above, all registrants will be requested to provide Applicant with documentary evidence that the company is indeed registered in Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil . The latter will also be applicable during Sunrise as described below. The requirements of requested documentary evidence will be determined at the moment of delegation of the TLD.

2.2. Performing verification checks
It is important to state that during the verification of the eligibility of the registrants, the Applicant will verify that the registrants are only companies registered in the Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil requesting to register a domain name within the applied TLD. In order to ensure that the restricted policy is in place, Applicant will request from all registrants documentary evidence that proves that the registrant is indeed listed with the local chambers of commerce. Furthermore, the Applicant plans to include specific provisions in its registry-registrar agreement in order to ensure that Applicant’s mission and vision outlined above are implemented to their fullest extent possible. By doing so, the Applicant ensures that the restricted policies as described above are adhered to and this will also allow a smoother implementation of the issuance of the domain names.
Applicant intends to outsource these services to reputable firm for the performance of verification procedure (“The verification Agent”). Consequently, all domain names applied for throughout the entire registry agreement will be submitted to a verification process. At a minimum, the verification agent will verify if the company is registered within the Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil .
In the event that based on the finding of the verification agent, Applicant determines that the domain name applied for does not meet the requirements as laid down by the registration policies, the domain name application will not be accepted.

2.3. Handling complaints
Applicant intends to publish on its website a point of complaints. This will allow any third party right to file a complaint in the event that:
 - a third party rights have been infringed; 
- registration policies are not adhered too;
- abusive uses such as but not limited to phising or pharming have been detected.
- etc.

Applicant will investigate the matter and provide with a written response within 2-3 business days. For abusive uses such as phising or pharming, Applicant reserves the right to immediately takedown the website and lock the domain name until the matter has been further investigated. 

2.4. Implementation Sunrise


The Sunrise period will allow holders of a trademark and that have a company registered in the Commonwealth of Nations to apply for a domain name. In this phase, Applicant intends to use the trademark clearinghouse as set out by ICANN. Once the Applicant has received notification from the trademark clearinghouse that a registrant has indeed a corresponding trademark, it will put this domain name “on hold”. Furthermore, registrants will be requested to provide documentary evidence that their company is still registered in the Commonwealth countries, Ireland, China, Hong Kong and⁄or Brazil.

The Applicant will describe the modalities and the process of the sunrise period in a Sunrise Policy. All Sunrise Applicants, Registrars, Verification Agents will be bound by the Sunrise Policy, In this Sunrise Policy the Applicant will describe which trademarks will be considered as eligible, the syntax requirements for domain names applied for to be accepted, the content of the sunrise application, the additional documentary evidence to be provided and the steps of the process including the sunrise reconsideration proceedings.
The Applicant will adhere to the terms and conditions as laid down by ICANN with respect to the interfacing with and use of the trademark clearinghouse. The Applicant ensures that it will deploy the necessary interfaces to the trademark clearinghouse in accordance with the technical specifications to be published by the trademark clearinghouse provider, and will also ensure that all records that are validated by the trademark clearinghouse provider and that meet the conditions of the Applicant’s polices will be registered within the applied-for TLD. However, and as already stated, in order to ensure that the domain name applications meet the conditions of registration, all domain name applications will be submitted to verification process.


2.5. Trademark Claims
Under trademark claim services, Applicant understands that any third party that has eligible rights on a trademark, has submitted such evidence to the trademark clearinghouse, and has been validated will be entitled to send a notification when a registrant applies for a domain name that is an exact match to his⁄her trademark. 

In conformity with what was stated in Question 18, Applicant plans to adhere to the trademark claims services as set out by ICANN. Applicant will support ICANN’s Trademark Claims process. Applicant also understands that in order to allow this service, its registry database will need to interface with the trademark clearinghouse so that trademark holders will automatically be notified when a Registrant applies for a domain name within TLD.
Similar processes have been put in place by various staff members of the Applicant’s back-end registry operator, so also here the Applicant can bow on significant and hands-on experience in handling these types of processes.

 
3. Address abusive use on an ongoing basis
As described above, Applicant intends address and abusive use on an ongoing basis by:

1) Verifying all applied for domain name meet the conditions as laid down by the registration policies
2) Periodic verification of the WHOIS
3) Putting in place a point of contact for complaint handling.


In addition, Applicant will comply with and implement decisions made according to the Trademark Post-Delegation Dispute Resolution Policy (PDDRP) adopted by ICANN. Applicant will also implement decisions made under the Uniform Domain Name Dispute Resolution (UDRP) and the Uniform Rapid Suspension (URS) procedures adopted by ICANN, including suspension of specific domain names within the registry. Applicant understands that such mechanisms constitute a minimum requirement.

Applicant intends to implement and adhere to any remedies ICANN imposes (which may include any reasonable remedy, including for the avoidance of doubt, the termination of the Registry Agreement pursuant to Section 4.3(e) of the Registry Agreement) following a determination by any PDDRP panel and to be bound by any such determination.

By the “Post-delegation Dispute Resolution Procedure (PDDRP)”, we refer to the mechanism that allows a trademark owner to file a complaint against the Applicant claiming that one or more of its trademarks have been infringed, and that it has thereby been harmed, by the Applicant’s manner of operation or use of the applied TLD.

Applicant will therefore commit to answering each complaint within forty-five days after the date of the threshold review panel declaration. Applicant will also comply with the procedure, including additional rules and procedures laid down by the selected dispute service provider. Applicant will respect and implement the final decision by deleting the domain name registration in the event that the outcome of the process is in favor of the complainant.

Furthermore, and as already stated Applicant will set up a contact email where a responsible person will be in charge of making sure that the request from the relevant panels are being answered in due time. 

The term “Uniform Domain Name Dispute Resolution Policy (UDRP)”, refers to a dispute resolution mechanism aiming at resolving disputes occurring between a Registrar and any party other than the Registrar over the registration and use of an Internet domain name registered by the Registrar. Applicant will implement the UDRP policy as laid down by ICANN and will publish this on its website.

In the event that the Applicant is made aware of a complaint, the domain name registration will be put on hold until it receives notification from WIPO. In the event that the complainant is successful, the domain name will be deleted.

We understand that the Uniform Rapid Suspension (URS) is a mechanism designed to offer trademark owners a quick and low-cost procedure to take down infringing websites. We also understand that a complaint will be submitted to an URS provider approved by ICANN. A decision in favor of the complainant will lead to the suspension of the domain name by the Applicant. Unless the decision is reversed, the domain name will lead to a mandatory URS placeholder page for the rest of the registration period.

Concerning the URS, Applicant understands that after the end of the administrative review (i.e. the review which aims at determining that the complaint contains all of the necessary information. This is not a determination as to whether a prima facie case has been established), the URS Provider will notify us immediately that the complaint is considered to be compliant with the filling requirements. Within 24 hours of receipt of the Notice of Complaint from the URS Provider, the Applicant will “lock” the domain, meaning that the Applicant shall restrict all changes to the registration data, including transfer and deletion of the domain names, but the name will continue to resolve. The Applicant will notify the URS Service Provider immediately upon locking the domain name (”Notice of Lock”). If after examination in default case, the examiner rules in favor of the Registrant, the URS service provider shall notify the Applicant to unlock the name and return full control of the domain name registration to the Registrant. Applicant understands it will be transmitted immediately the decision issued if the determination is in favor of the complainant. Immediately upon receipt of the determination, the Applicant will suspend the domain name, which shall remain suspended for the balance of the registration period and will not resolve to the original web site. The nameservers shall be redirected to an informational web page provided by the URS Service Provider about the URS. The URS Service Provider shall not be allowed to offer any other services on such page, nor shall it directly or indirectly use the web page for advertising purposes (either for itself or any other third party). The Whois for the domain name shall continue to display all of the information of the original Registrant except for the redirection of the nameservers. In addition, the Whois shall reflect that the domain name will not be able to be transferred, deleted or modified for the life of the registration.
 
4. Resource Planning

As already stated above, Applicant will outsource all services to reputable firm with legal and technical expertise as from the start-up of the operations. This ensures that Applicant can meet the demands of the registrants.

For further information on the financial projections, Applicant refers to its response to question 47.

The Registry Operator has outsourced the technical back-end registry operations to Sensirius, the (backend) Registry Service Provider. 

The Registry Service Provider has put in place an Information Security Management System (ISMS) for its registry operation activities. For a full description of the ISMS, reference is made to the response to question 30b. 

The ISMS has been recently audited by Deloitte Bedrijfsrevisoren, Belgium. The report for this independent assessment of the security system is attached to question 30b.

For reasons of confidentiality, all elements related to security (including elements indicated in question 30a and a summary of the security policy) have been addressed in the response to question 30b. Attached t
to the response to question 30b are also the policies that are put in place by the Registry Service Provider for assuring the registry operations on behalf of the Registry Operator.