Application number: 1-1888-47714 for The Canadian Real Estate Association

The Canadian Real Estate Association

200 Catherine Street, 6th Floor
Ottawa Ontario K2P 2K9
CA

1 613 237 7111

1 613 234 2567

http:⁄⁄www.crea.ca

Allison McLure

Legal Counsel

1 613 237 7111

1 613 234 2567

amclure@crea.ca

Bill Harrington

General Counsel

1 613 237 7111

1 613 234 2567

bharrington@crea.ca

not-for-profit corporation

Canada Corporations Act

Not Available

Allan Corbett
Canadian Commercial Council Chair
Andrew Peck
Director-at-Large
Ann Cosens
Director-at-Large
Brian Walker
Director-at-Large
Cliff Iverson
Regional Director
Gerry Weir
Regional Director
Marie Josee Guilbert
Regional Director
Maurice Moloney
Regional Director
Mike Pederson
MLS and Technology Council Chair
Pauline Aunger
Director-at-Large
Reg Black
Regional Director
Roy Milley
Regional Director
Wilfred James Briggs
Regional Director
William Elsworth Johnston
Director-at-Large
Willian Raymond Duce
Association Executives Council Chair

Beth Crosbie
Vice President
Gary Morse
Past President
Gary Simonsen
Chief Executive Officer
Laura Leyser
President-Elect
Wayne Moen
President

mls

Not Available

The Canadian Real Estate Association is unaware of any known operational or rendering problems related to the .MLS gTLD.

The Canadian Real Estate Association (CREA) is a trade association whose membership consists of more than 100,000 real estate brokers, agents, and salespeople, (collectively referred to throughout as “REALTORS®”) working through 100 member real estate boards and provincial associations (collectively referred to throughout as “Boards”) across Canada, as well as Foreign Affiliate members outside of Canada.  

CREA is the owner of the MLS® trademarks in Canada and licenses the use of those trademarks to its members. The MLS® trademarks are registered in Canada as “certification marks”, which means that they identify a standard or level of service provided by the members of the group licensed to use the marks. In this case, the MLS® marks, and the proposed .MLS TLD, identify professional services rendered by members of CREA to effect the purchase and sale of real estate as part of a cooperative selling system. 

Member Boards operate cooperative selling systems, which include an inventory of listings of participating RELATORS® and ensures a high level of accuracy of information, professionalism, and cooperation amongst REALTORS® to affect the purchase and sale of real estate. These cooperative selling systems are called MLS® Systems and they date back to 1955 in Canada. 

CREA’s mandate, as set out in its By-laws, Rules, and Regulations includes promoting and protecting the MLS® trademarks and acting as a technological resource for its members by providing technology services and products. The purpose of applying for the .MLS TLD is to further fulfill this mandate.

The mission⁄purpose of .MLS is to allow registration of domain names by CREA’s members. The goal is that the .MLS TLD will indicate to consumers that those websites contain information about MLS® Services or listing content that originates from an MLS® System. 

We believe it is important for there to be awareness of the existence of a new .MLS TLD in order to be of benefit to Internet users. Such awareness will create new choice within the DNS for how to access and locate CREA member related information by users of the Internet. 

For decades, the MLS® trademarks have indicated to Canadian consumers a level of service provided only by professional REALTORS® as part of a cooperative selling system. Just as consumers have come to recognize and know the meaning of the MLS® trademark in marketing and advertising, they will also recognize and know the meaning of the MLS® trademark in domain names and have trust in the associated professional services and listing information offered by those websites. 

Internet users will know that the information on .MLS websites relate to MLS® services or listing information from an MLS® System, both of which require a certain level of professionalism and accuracy of information, as opposed to marketing websites that simply aggregate listing content without any such assurance. We expect registrants of .MLS domains to benefit over time from the increased user awareness such as through access of future .MLS websites and e-mail addresses.

Such information will allow consumers to locate professional services coming from members of CREA etc.

i) What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?

The goal of the .MLS TLD is replicate the standards by which MLS® professional services are known for. CREA is best situated to ensure registrants of .MLS domains are those able to meet this standard.

The trademark MLS® has been used by organized real estate extensively throughout Canada since 1954. Consequently, consumers associate “MLS®” with the provision of professional real estate services and accurate, comprehensive, real estate listing information. The .MLS TLD will reinforce this meaning of MLS® with consumers and easily enable them to identify website that will provide quality information about real estate services and property listings.

ii) What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

Initially, the creation of the .MLS TLD will provide competition to existing TLD’s in the form of a new name space for CREA member Boards and Foreign Affiliates to register domain names. Over time, we anticipate a single dedicated name space under the unique .MLS TLD to resonate with users of the Internet creating differentiation that otherwise could not exist in the very same manner. Internet users will come to know that the information on .MLS websites is guaranteed to be about MLS® real estate services or listing content that originates from an MLS® System, both of which require a high level of professionalism and accuracy of information, whereas no such guarantee exists when accessing a .com or .net real estate website.

iii) What goals does your proposed gTLD have in terms of user experience?

As the Registry Operator of the .MLS TLD, our goal is for users to experience robust DNS industry standards for technical back-end operations including but not limited to 100% uptime, timely zone file dissemination, searchable WHOIS capabilities, and additional security measures such as for DNS Security Extensions (DNSSEC). Over time, our goal is for users to interact with registrants of .MLS domain names Change to same as general application.

Part of CREA’s mandate is to act as a technological resource for its members. CREA has done this in the past by providing technology products, such as an online forms service, an intranet, a data distribution facility, and public facing websites like REALTOR.ca (previously MLS.ca). REALTOR.ca, which CREA owns and operates, is currently the most successful real property website in Canada. This website contains hundreds of thousands of property listings from the MLS® Systems of member Boards all across Canada. From 1994 until approximately 2008 (i.e. some 14 years) this website was known as MLS.ca. CREA is still the owner of the active MLS.ca domain. 

Owning and operating the .MLS TLD is yet another technology product that CREA wishes to offer its members to help them conduct their businesses and is consistent with CREA’s long-standing technological association with MLS® Systems.

iv) Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.

Only members of CREA will be permitted to register .MLS domains. The .MLS TLD will initially be made available to CREA’s member Boards and foreign affiliate members. After undertaking any required assessments, CREA may enter into a second phase where the TLD would be made available to REALTOR® members of CREA.

Each application will be manually reviewed to determine if the applicant is a member of CREA. The applied-for second level domain will also be reviewed to determine if it would make clear to Internet Users what geographical region the MLS® services or listing information on the website represents.

v) Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users? If so, please describe any such measures.

We would institute all privacy protections as required by the Personal Information Protection and Electronic documents Act (PIPEDA) in Canada. PIPEDA requires companies that collect and maintain “personal information” to obtain consent for the collection and use of that information and to take measures to safeguard the information. CREA will obtain consent from domain name applicants to include their personal information in a WHOIS database, and will take all required measures to protect that information. 

vi) Describe whether and in what ways outreach and communications will help to achieve your projected benefits.

The primary outreach and communications that will occur for .MLS will be through CREA’s existing communications and marketing channels. CREA currently communicates to its members through electronic newsletters, its intranet website www.realtorlink.ca, and directly at conferences and meetings. CREA also communicates to consumers through its National Advertising Campaign, namely television and radio ads, and public facing websites. CREA will use these methods to communicate information about the .MLS TLD to its members and to consumers.

vii) What operating rules will you adopt to eliminate or minimize social costs (e.g., time or financial resource costs, as well as various types of consumer vulnerabilities)?

A significant operating rule will be the requirement that all registrants of .MLS domains be members of CREA. Consumers will know that the information provided on .MLS websites relates to MLS® services or listing information that originates from an MLS® System, both of which require a high degree of professionalism and of accuracy of information. REALTOR® members are subject to a high ethical standard set out in the REALTOR® Code of Ethics. 


viii) How will multiple applications for a particular domain name be resolved, for example, by auction or on a first come⁄first serve basis?

Boards will only be allowed to use the TLD with their business name or an acronym of their business name. For example, the Toronto Real Estate Board could register www.torontorealestateboard.mls or www.treb.mls. As no two boards use the same name or acronym, and as these are the only .MLS domains that will be issued in phase one to Canadian applicants, there will not be multiple applications for the same domain name in Canada. 

All Foreign Affiliate members will be required to include a geographical modifier in the second level domain that relates to the geographical area that is serviced by their MLS® System or to clearly indicate the geographical area served by their system on any site page. For example, the Durham MLS would not be able to simply register Durham.mls, as this domain could be confusing with Durham, Ontario. The Durham MLS would be required to include a geographical modifier, like DurhamNorthCarolina.mls, or they would have to display something like a map of North Carolina on their home page. As there are very few areas serviced by more than one of CREA’s Foreign Affiliate members, it is unlikely that there will be many duplicate .MLS domain name applications by applicants outside of Canada. 

In the event that there are multiple applications for the same .MLS domain name, which we consider to be a very limited pool for reasons described above, CREA will default to an auction process for resolution. Any such auction would be performed by an experienced domain auction provider under best auction practices.

ix) Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).

Our plan is to market test the elasticity of the wholesale fee for a .MLS registration in order to gather the market evidence necessary to best determine strategies that have to do with advantageous pricing, introductory discounts, etc.

CREA does not intend to make contractual commitments to registrants regarding the magnitude of price escalation.

x) What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?

The .MLS TLD will be used by CREA members to market their membership in CREA, their professional services, and their real estate listings. All of this information will be provided to consumers in the context of a group of highly skilled professionals, all of whom belong to an integrated system of real estate Boards across Canada that provide national support for those services. Consumers will have the benefit of being able to recognize quality MLS® services and accurate MLS® listing content in a competitive and open environment where they will be able to make informed choices in terms of representation. This encourages healthy competition for consumer loyalty and benefits all consumers from both a cost and service level perspective.

Yes

The community will be CREA membership, as defined in its By-laws, Rules, Regulations, which includes its Boards, REALTORS®, and Foreign Affiliates. All members of CREA must adhere to the standards set out in its Bylaws, Rules, and Regulations, a copy of which is attached to this answer. The existence of CREA dates back to 1943 when eleven real estate boards collaborated to form a national association. Its membership has steadily grown since then and now totals more than 100,000 REALTOR® members in Canada as well as Canadian member Boards and Foreign Affiliate Members outside of Canada.

CREA is a national trade association that represents its members at the federal level of government and acts as a watchdog on national legislation that pertains to the real estate industry. It also owns or controls the REALTOR® and MLS® trademarks in Canada and licenses those marks to its members. Boards operate MLS® Systems in association with the MLS® trademark that CREA licenses the Boards to use. REALTOR® members provide consumers with MLS® services using the MLS® Systems operated by Boards. CREA is the national body in organized real estate that brings its members together to address emerging issues, such as the future of the real estate industry in an increasingly technological world.
CREA is accountable to its community in many ways primarily through its Board of Directors. The Board is comprised of twenty (20) persons as follows:
1. President
2. Immediate Past President
3. The Chair of the Canadian Commercial Council (CCC)
4. The Chair of the MLS Technology Council (MTS)
5. The Chair of the Association Executives Council (AEC)
6. The President of the National Association of REALTORS®(NAR) (non-voting)
7. Eight Regional Directors
8. Six Directors-at-Large
The Board of Directors, as the senior policy-making body, shall ensure that the objects and purposes of CREA are actively pursued. Directors cannot serve more than four consecutive two-year terms.
CREA has a process to receive complaints with regards to membership compliance, which may come from any source so long as in writing and directed at CREA’s Chief Executive Officer who will cause an investigation to be conducted. In addition, CREA maintains and administers a dispute resolution process to adjudicate disputes amongst its members.

The MLS® trademarks are certification marks, which are a type of trademark that is used to distinguish services that are of a defined standard with respect to the quality with respect to the character and quality of the services and the people who preform them.  The MLS® Marks identify professional services rendered by members in good standing of CREA to affect the purchase and sale of real estate as part of a “plural system arrangement”, also known as a co-operative selling system (the “MLS® Services”). Only members of CREA are licensed to use the MLS® trademarks in Canada, and only then in compliance with CREA’s rules on the proper use of the trademarks. 
Part of CREA’s mandate set out in its By-laws, Rules, and Regulations is to promote and protect the MLS® family of certification marks by exclusively licensing the marks to and encouraging their use by members, by promoting the acceptance and understanding of these marks and the associated professional services through public advertising and member education, and by monitoring and preventing improper uses. It is also part of CREA’s mandate that it act as a technological resource for its members by providing technology services and products. The purpose of the .MLS TLD is to help fulfill CREA’s mandate.
Ever since the MLS® trademarks were first registered in the 1950’s, CREA has been taking measures to enforce the proper use of those marks to ensure that they maintain their distinctiveness and value for organized real estate. This has been achieved by creating compliance materials explaining how the marks are to be used, contacting our members to help them correct any misuses, and sending cease and desist letters to non-members who are not licensed to use the trademarks. Applying for the .MLS TLD is another step CREA is taking to help protect and promote the MLS® marks.
By only allowing members of CREA to register and use the .MLS TLD in Canada and the United States, it is hoped that such use will reinforce to consumers that the MLS® marks represent cooperative services provided by members of organized real estate. Further, consumers on .MLS website will be able to rely on the fact that the information on those websites relates to MLS® services or is information originating from an MLS® System, which must meet standards for accuracy of information. Reinforcing this message with CREA’s members and consumers will hopefully strengthen and promote the MLS® trademarks. 
Further, by owning the .MLS TLD, CREA will be able to provide another technology service to its members that will benefit all of organized real estate as well as purchasers and sellers of real estate throughout North America.

As is explained above, CREA is the owner of the MLS® trademarks in Canada and it licenses the use of this mark to its members. The MLS® certification marks were registered at different times, with the earliest registration taking place in 1959. However, the MLS® marks have been used since at least 1954 to describe the standard of service provided by members of organized real estate.
In order to be registerable as a trademark, the word in question must be distinctive and enable consumers to distinguish between the goods and services provided by others in a market. The very fact that Multiple Listing Service® and MLS® are registered trademarks indicates that these marks are distinctive and unique to the real estate industry. As only members of CREA are licensed to use the MLS® marks, they are unique to CREA’s community.
The MLS® Marks identify professional services rendered by members in good standing of CREA to affect the purchase and sale of real estate as part of a “plural system arrangement”, also known as a co-operative selling system (the “MLS® Services”). An MLS® System is a cooperative selling system operated and promoted by a board or association under the MLS® trademarks. An MLS® System includes an inventory of listings of participating REALTORS®, and ensures a high level of accuracy of information, professionalism, and cooperation amongst REALTORS® to effect the purchase and sale of real estate. CREA has rules regarding the operation of MLS® Systems that all Boards and REALTORS® must comply with when they take MLS® listings.
The connection to the community is that CREA is the overarching body that maintains rules and regulations and provides services to benefit all of its members, in particular relating to the operation of MLS® Systems, and CREA’s members are the members of the community.

Only members of CREA and its Foreign Affiliates will be permitted to register .MLS websites. The .MLS TLD will initially be made available to CREA’s Board members and Foreign Affiliate members. After undertaking any required assessments, CREA may enter into a second phase where the TLD would be made available to broker and salespeople members of CREA. Boards using the .MLS TLD will be required to use their corporate name, or an acronym of their corporate name, as the second level domain. Foreign Affiliate members will be required to include geographical modifiers in their second level domains on the .MLS TLD or clearly indicate the geographical area served by their system on any site page. For example, the Durham MLS would not be able to simply register Durham.mls, as this domain could be confusing with Durham, Ontario. The Durham MLS would be required to include a geographical modifier, like DurhamNorthCarolina.mls, or they would have to display something like a map of North Carolina on their home page.
CREA does not expect significant enforcement efforts to be necessary after registration since each application will be manually reviewed to determine if the applicant is a member of CREA and if the second level domain complies with the rules set out above. If, however, there are misuses of the .MLS TLD, CREA has existing process for misuse of the MLS® trademark in domain names.
For example, Boards and Associations are required to use a geographical modifier in domain names that contain MLS® to indicate the area in which they operate, as in TorontoRealEstateBoard.mls. If a Board managed to register a domain name that did not contain such a modifier, like RealEstateBoard.mls, this misuse of the trademark would be a violation of CREA’s rules.
CREA may investigate misuse of its trademarks on its own initiative or as a result of receiving a complaint. Complaints are sent to helpdesk@crea.ca, which are then forwarded to the legal department. Complaints are logged and investigated and, if warranted, the domain name owner is contacted about their use of the trademark. If the domain name owner refuses to make the required changes, CREA has provisions for termination of membership (after reasonable notice and a hearing) in its By-laws, Rules, and Regulations. Termination of membership will result in the loss of the .MLS domain name.
CREA will not allow the .MLS TLD to be used in association with a website that features illegal, unethical or otherwise objectionable content, or that includes content that could violate a third party’s intellectual property rights. As part of the terms and conditions for registration, each second level domain on the .MLS TLD will be required to resolve to a landing or login page that primarily promotes the real estate services of the member. CREA will be enforcing these restrictions on use of the .MLS TLD.

Not Available

No

In responding to the issues indicated in Question 22, The Canadian Real Estate Association (CREA) has considered GAC advice set forth at https:⁄⁄gacweb.icann.org⁄display⁄gacweb⁄New+gTLDs and https:⁄⁄gacweb.icann.org⁄download⁄attachments⁄1540128⁄gTLD_principles_0.pdf?version=1&modificationDate=1312358178000. CREA has also considered the methodology developed for the reservation and release of country names in the .INFO tld, and specifically the information relating to .INFO at Resolution 01-92 at http:⁄⁄www.icann.org⁄en⁄minutes⁄minutes-10sep01.htm and ICANN’s proposed action plan at http:⁄⁄www.icann.org⁄en⁄meetings⁄montevideo⁄action-plan-country-names-09oct01.htm . CREA has also reviewed the Second WIPO Internet Domain Name Process – The Recognition and Rights and the Use of Names in the Internet Domain Name System, Section 6, Geographical Identifiers, at http:⁄⁄www.wipo.int⁄amc⁄en⁄processes⁄process2⁄report⁄html⁄report.html and ICANN’s Generic Names Supporting Organization Reserved Names Working Group – Final Report at http:⁄⁄gnso.icann.org⁄issues⁄new-gtlds⁄final-report-rn-wg-23may07.htm.

Initial Reservation of Country and Territory Names

CREA is committed to initially reserving, at no cost to governments, public authorities or inter-governmental organizations, the country and territory names contained in the internationally recognized lists described in Article 5 of Specification 5 attached to the New gTLD Applicant Guidebook Draft New gTLD Registry Agreement at the second level and at all other levels within the .MLS generic top-level domain (gTLD) at which CREA will provide for registrations. Specifically, CREA will reserve:

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

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

3. The list of United Nations member states in 6 official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names.

To the extent Article 5 of Specification 5 of the final version of the New gTLD Registry Agreement is amended to include additional country, territory or other geographic identifiers, CREA will similarly initially reserve all such names.

It is CREA’s intent to initially reserve the names mentioned above by blocking them from registration at the registry level (for example, CREA’s back end provider, Verisign, would block the names from registration), but CREA may use any other method for initially reserving the names as not prohibited by the final version of the New gTLD Registry Agreement, such as, for example, registering such names in its own name in order to withhold them from delegation or use.

Use of Non-Reserved Geographical Identifiers

As stated in response to Question 18, the mission⁄purpose of the .MLS gTLD is to allow registration of .MLS domain names by CREA’s member Boards and Foreign Affiliate members. The .MLS TLD will initially be made available to CREA’s member Boards and Foreign Affiliate members. After undertaking any required assessments, CREA may enter into a second phase where the TLD would be made available to broker and salespeople members of CREA.

In Canada, boards and associations will only be allowed to use the TLD with their business name or an acronym of their business name. All the domain names that Foreign Affiliates apply for must contain a geographical modifier that relates to the area of the country that the Foreign Affiliate services or clearly indicate the geographical area served by their system on any site page. Under these rules, it is highly likely that non-reserved geographical identifiers will be used.

Such use, however, is consistent with the mission⁄purpose of the .MLS gTLD. As many Boards in Canada incorporate non-reserved geographical identifiers in their entity names, use of such identifiers in second level domains in the .MLS gTLD maintains the mission⁄purpose of the .MLS gTLD. Furthermore, potential Board members currently provide real estate information which is by its nature geographic in origin, such as real estate purchase⁄sale information for real estate within a certain geographic area. CREA believes that it is a logical and intuitive use of the .MLS namespace for such Board and Foreign Affiliate members to use geographic identifiers, which identify the geographic area in which such Board or Foreign Affiliate members already provide geographically-related information, in second level domains in .MLS.

CREA recognizes that there is concern regarding misuse of geographical identifiers in the international, regional and national levels. However, CREA provides several mechanisms to counter misuse concerns. As set forth in the answer to Question 18, CREA will manually review all domain requests. Registration is limited, in phase one, to Board members and Foreign Affiliate members, who are legitimate providers of professional real estate related information. In phase two, registration is limited to brokers and salespeople who are members of CREA. Further, CREA’s interest in the MLS® brand as a trademark provides CREA with incentive to vet out any potential misuse. As such, CREA is confident that concerns regarding misuse of non-reserved geographical identifiers are being appropriately addressed.

CREA, acting as a responsible business, generally seeks to avoid business practices that could potentially mislead consumers and misuse geographical identifiers. CREA believes that it is important, pursuant to the mission⁄purpose of the .MLS gTLD, to be able to use geographical identifiers in a fair, non-misleading manner and consistent with the use and registration guidelines set forth herein, as such use can benefit Internet users, Board members, Foreign Affiliate members and consumers as proposed in .MLS’s business model. CREA is committed to operating the .MLS namespace in a manner that minimizes potential consumer confusion, and will actively work with others in the ICANN community regarding any future policy development in this area.

Alleged Abuses of Geographic Names

CREA does not anticipate any disputes with governments or public authorities arising in connection with the registration and use of geographic names within the .MLS gTLD based upon its proposed use set forth in Answer 18 of this application and the statements made herein. Nevertheless, CREA is committed to working with governments, public authorities, or IGOs to quickly resolve any such potential disputes, and as such ensure that such governments, public authorities and IGO’s will at minimum have access to .MLS’s abuse prevention procedure(s) and rights protection mechanisms set forth in answers to Questions 28 and 29 of this Application in order to ensure an ability to address alleged abuses of names with national or geographic significance at the second level of .MLS.

Potential Future Release of Initially Reserved Names

CREA looks forward to collaborating with other new gTLD Registry Operators in potentially working with the GAC and ICANN to explore processes that could permit the release of initially reserved country names, such as Registry Service Evaluation Processes (RSEP) requests that have been filed by existing gTLD Registry Operators in releasing previously reserved domain names. 

Creation and Updating the Policies

Should the need arise in the future for the creation or updating of the policies regarding this class of domain names, CREA will act in an open and transparent manner to develop such a policy and⁄or recommendation.

CREA is also committed to the ongoing review and updating of these lists to prevent the misleading use of geographical identifiers. Consistent with this commitment, CREA intends to participate in any ongoing ICANN policy discussion regarding the protection of geographic names within the DNS.

1 CUSTOMARY REGISTRY SERVICES

As The Canadian Real Estate Association’s (CREA) selected provider of backend registry services, Verisign provides a comprehensive system and physical security solution that is designed to ensure a TLD is protected from unauthorized disclosure, alteration, insertion, or destruction of registry data. Verisign’s system addresses all areas of security including information and policies, security procedures, the systems development lifecycle, physical security, system hacks, break-ins, data tampering, and other disruptions to operations. Verisign’s operational environments not only meet the security criteria specified in its customer contractual agreements, thereby preventing unauthorized access to or disclosure of information or resources on the Internet by systems operating in accordance with applicable standards, but also are subject to multiple independent assessments as detailed in the response to Question 30, Security Policy. Verisign’s physical and system security methodology follows a mature, ongoing lifecycle that was developed and implemented many years before the development of the industry standards with which Verisign currently complies. Please see the response to Question 30, Security Policy, for details of the security features of Verisign’s registry services. 

Verisign’s registry services fully comply with relevant standards and best current practice RFCs published by the Internet Engineering Task Force (IETF), including all successor standards, modifications, or additions relating to the DNS and name server operations including without limitation RFCs 1034, 1035, 1982, 2181, 2182, 2671, 3226, 3596, 3597, 3901, 4343, and 4472. Moreover, Verisign’s Shared Registration System (SRS) supports the following IETF Extensible Provisioning Protocol (EPP) specifications, where the Extensible Markup Language (XML) templates and XML schemas are defined in RFC 3915, 5730, 5731, 5732, 5733, and 5734. By strictly adhering to these RFCs, Verisign helps to ensure its registry services do not create a condition that adversely affects the throughput, response time, consistency, or coherence of responses to Internet servers or end systems. Besides its leadership in authoring RFCs for EPP, Domain Name System Security Extensions (DNSSEC), and other DNS services, Verisign has created and contributed to several now well-established IETF standards and is a regular and long-standing participant in key Internet standards forums.

Figure 23-1 summarizes the technical and business components of those registry services, customarily offered by a registry operator (i.e., Verisign), that support this application. These services are currently operational and support both large and small Verisign-managed registries. Customary registry services are provided in the same manner as Verisign provides these services for its existing gTLDs.

Through these established registry services, Verisign has proven its ability to operate a reliable and low-risk registry that supports millions of transactions per day. Verisign is unaware of any potential security or stability concern related to any of these services. 

Registry services defined in the Figures below are not intended to be offered in a manner unique to the new generic top-level domain (gTLD) nor are such services unique to this application’s registry. An additional registry service which CREA will offer, commonly used in the marketplace today, is the use of RFPs (Request for Proposals) to determine string allocation in appropriate circumstances. 

Figure 23-1: See attached

As further evidence of Verisign’s compliance with ICANN mandated security and stability requirements, Verisign allocates the applicable RFCs to each of the five customary registry services (items A – E above). For each registry service, Verisign also provides evidence in Figure 23-2 of Verisign’s RFC compliance and includes relevant ICANN prior-service approval actions. 

Figure 23-2: See attached

1.1 Critical Operations of the Registry 

i. Receipt of Data from Registrars Concerning Registration of Domain Names and Name Servers 

See Item A in Figure 23-1 and Figure 23-2. 

ii. Provision to Registrars Status Information Relating to the Zone Servers

Verisign is CREA’s selected provider of backend registry services. Verisign registry services provisions to registrars status information relating to zone servers for the TLD. The services also allow a domain name to be updated with clientHold, serverHold status, which removes the domain name server details from zone files. This ensures that DNS queries of the domain name are not resolved temporarily. When these hold statuses are removed, the name server details are written back to zone files and DNS queries are again resolved. Figure 23-3 describes the domain name status information and zone insertion indicator provided to registrars. The zone insertion indicator determines whether the name server details of the domain name exist in the zone file for a given domain name status. Verisign also has the capability to withdraw domain names from the zone file in near-real time by changing the domain name statuses upon request by customers, courts, or legal authorities as required.

Figure 23-3: See attached 

iii. Dissemination of TLD Zone Files

See Item B in Figure 23-1 and Figure 23-2.

iv. Operation of the Registry Zone Servers

Verisign is CREA’s selected provider of backend registry services. Verisign, as a company, operates zone servers and serves DNS resolution from 76 geographically distributed resolution sites located in North America, South America, Africa, Europe, Asia, and Australia. Currently, 17 DNS locations are designated primary sites, offering greater capacity than smaller sites comprising the remainder of the Verisign constellation. Verisign also uses Anycast techniques and regional Internet resolution sites to expand coverage, accommodate emergency or surge capacity, and support system availability during maintenance procedures. Verisign operates CREA’s gTLD from a minimum of eight of its primary sites (two on the East Coast of the United States, two on the West Coast of the United States, two in Europe, and two in Asia) and expands resolution sites based on traffic volume and patterns. Further details of the geographic diversity of Verisign’s zone servers are provided in the response to Question 34, Geographic Diversity. Moreover, additional details of Verisign’s zone servers are provided in the response to Question 32, Architecture and the response to Question 35, DNS Service. 

v. Dissemination of Contact and Other Information Concerning Domain Name Server Registrations

See Item C in Figure 23-1 and Figure 23-2.

2 OTHER PRODUCTS OR SERVICES THE REGISTRY OPERATOR IS REQUIRED TO PROVIDE BECAUSE OF THE ESTABLISHMENT OF A CONSENSUS POLICY

Verisign, CREA’s selected provider of backend registry services, is a proven supporter of ICANN’s consensus-driven, bottom-up policy development process whereby community members identify a problem, initiate policy discussions, and generate a solution that produces effective and sustained results. Verisign currently provides all of the products or services (collectively referred to as services) that the registry operator is required to provide because of the establishment of a Consensus Policy. For the .MLS gTLD, Verisign implements these services using the same proven processes and procedures currently in-place for all registries under Verisign’s management. Furthermore, Verisign executes these services on computing platforms comparable to those of other registries under Verisign’s management. Verisign’s extensive experience with consensus policy required services and its proven processes to implement these services greatly minimize any potential risk to Internet security or stability. Details of these services are provided in the following subsections. It shall be noted that consensus policy services required of registrars (e.g., Whois Reminder, Expired Domain) are not included in this response. This exclusion is in accordance with the direction provided in the question’s Notes column to address registry operator services. 

2.1 Inter-Registrar Transfer Policy (IRTP)

Technical Component: In compliance with the IRTP consensus policy, Verisign, CREA’s selected provider of backend registry services, has designed its registration systems to systematically restrict the transfer of domain names within 60 days of the initial create date. In addition, Verisign has implemented EPP and “AuthInfo” code functionality, which is used to further authenticate transfer requests. The registration system has been designed to enable compliance with the five-day Transfer grace period and includes the following functionality:

* Allows the losing registrar to proactively ‘ACK’ or acknowledge a transfer prior to the expiration of the five-day Transfer grace period
* Allows the losing registrar to proactively ‘NACK’ or not acknowledge a transfer prior to the expiration of the five-day Transfer grace period 
* Allows the system to automatically ACK the transfer request once the five-day Transfer grace period has passed if the losing registrar has not proactively ACK’d or NACK’d the transfer request.

Business Component: All requests to transfer a domain name to a new registrar are handled according to the procedures detailed in the IRTP. Dispute proceedings arising from a registrarʹs alleged failure to abide by this policy may be initiated by any ICANN-accredited registrar under the Transfer Dispute Resolution Policy. CREA’s compliance office serves as the first-level dispute resolution provider pursuant to the associated Transfer Dispute Resolution Policy. As needed Verisign is available to offer policy guidance as issues arise. 

Security and Stability Concerns: Verisign is unaware of any impact, caused by the service, on throughput, response time, consistency, or coherence of the responses to Internet servers or end-user systems. By implementing the IRTP in accordance with ICANN policy, security is enhanced as all transfer commands are authenticated using the AuthInfo code prior to processing. 

ICANN Prior Approval: Verisign has been in compliance with the IRTP since November 2004 and is available to support CREA in a consulting capacity as needed. 

Unique to the TLD: This service is not provided in a manner unique to the .MLS TLD.

2.2 Add Grace Period (AGP) Limits Policy

Technical Component: Verisign’s registry system monitors registrars’ Add grace period deletion activity and provides reporting that permits CREA to assess registration fees upon registrars that have exceeded the AGP thresholds stipulated in the AGP Limits Policy. Further, CREA accepts and evaluates all exemption requests received from registrars and determines whether the exemption request meets the exemption criteria. CREA maintains all AGP Limits Policy exemption request activity so that this material may be included within CREA’s Monthly Registry Operator Report to ICANN.

Registrars that exceed the limits established by the policy may submit exemption requests to CREA for consideration. CREA’s compliance office reviews these exemption requests in accordance with the AGP Limits Policy and renders a decision. Upon request, CREA submits associated reporting on exemption request activity to support reporting in accordance with established ICANN requirements.

Business Component: The Add grace period (AGP) is restricted for any gTLD operator that has implemented an AGP. Specifically, for each operator: 

* During any given month, an operator may not offer any refund to an ICANN-accredited registrar for any domain names deleted during the AGP that exceed (i) 10% of that registrarʹs net new registrations (calculated as the total number of net adds of one-year through ten-year registrations as defined in the monthly reporting requirement of Operator Agreements) in that month, or (ii) fifty (50) domain names, whichever is greater, unless an exemption has been granted by an operator. 
* Upon the documented demonstration of extraordinary circumstances, a registrar may seek from an operator an exemption from such restrictions in a specific month. The registrar must confirm in writing to the operator how, at the time the names were deleted, these extraordinary circumstances were not known, reasonably could not have been known, and were outside the registrarʹs control. Acceptance of any exemption will be at the sole and reasonable discretion of the operator; however ʺextraordinary circumstancesʺ that reoccur regularly for the same registrar will not be deemed extraordinary. 

In addition to all other reporting requirements to ICANN, CREA identifies each registrar that has sought an exemption, along with a brief description of the type of extraordinary circumstance and the action, approval, or denial that the operator took. 

Security and Stability Concerns: Verisign is unaware of any impact, caused by the policy, on throughput, response time, consistency, or coherence of the responses to Internet servers or end-user systems.

ICANN Prior Approval: Verisign, CREA’s backend registry services provider, has had experience with this policy since its implementation in April 2009 and is available to support CREA in a consulting capacity as needed. 

Unique to the TLD: This service is not provided in a manner unique to the .MLS TLD.

2.3 Registry Services Evaluation Policy (RSEP)

Technical Component: Verisign, CREA’s selected provider of backend registry services, adheres to all RSEP submission requirements. Verisign has followed the process many times and is fully aware of the submission procedures, the type of documentation required, and the evaluation process that ICANN adheres to. 

Business Component: In accordance with ICANN procedures detailed on the ICANN RSEP website (http:⁄⁄www.icann.org⁄en⁄registries⁄rsep⁄), all gTLD registry operators are required to follow this policy when submitting a request for new registry services.

Security and Stability Concerns: As part of the RSEP submission process, Verisign, CREA’s backend registry services provider, identifies any potential security and stability concerns in accordance with RSEP stability and security requirements. Verisign never launches services without satisfactory completion of the RSEP process and resulting approval.

ICANN Prior Approval: Not applicable.

Unique to the TLD: gTLD RSEP procedures are not implemented in a manner unique to the .MLS TLD.

3 PRODUCTS OR SERVICES ONLY A REGISTRY OPERATOR IS CAPABLE OF PROVIDING BY REASON OF ITS DESIGNATION AS THE REGISTRY OPERATOR

Verisign, CREA’s selected backend registry services provider, has developed a Registry-Registrar Two-Factor Authentication Service that complements traditional registration and resolution registry services. In accordance with direction provided in Question 23, Verisign details below the technical and business components of the service, identifies any potential threat to registry security or stability, and lists previous interactions with ICANN to approve the operation of the service. The Two-Factor Authentication Service is currently operational, supporting multiple registries under ICANN’s purview. 

CREA is unaware of any competition issue that may require the registry service(s) listed in this response to be referred to the appropriate governmental competition authority or authorities with applicable jurisdiction. ICANN previously approved the service(s), at which time it was determined that either the service(s) raised no competitive concerns or any applicable concerns related to competition were satisfactorily addressed.

3.1 Two-Factor Authentication Service

Technical Component: The Registry-Registrar Two-Factor Authentication Service is designed to improve domain name security and assist registrars in protecting the accounts they manage. As part of the service, dynamic one-time passwords augment the user names and passwords currently used to process update, transfer, and⁄or deletion requests. These one-time passwords enable transaction processing to be based on requests that are validated both by “what users know” (i.e., their user name and password) and “what users have” (i.e., a two-factor authentication credential with a one-time-password).

Registrars can use the one-time-password when communicating directly with Verisign’s Customer Service department as well as when using the registrar portal to make manual updates, transfers, and⁄or deletion transactions. The Two-Factor Authentication Service is an optional service offered to registrars that execute the Registry-Registrar Two-Factor Authentication Service Agreement.

Business Component: There is no charge for the Registry-Registrar Two-Factor Authentication Service. It is enabled only for registrars that wish to take advantage of the added security provided by the service.

Security and Stability Concerns: Verisign is unaware of any impact, caused by the service, on throughput, response time, consistency, or coherence of the responses to Internet servers or end-user systems. The service is intended to enhance domain name security, resulting in increased confidence and trust by registrants.

ICANN Prior Approval: ICANN approved the same Two-Factor Authentication Service for Verisign’s use on .com and .net on 10 July 2009 (RSEP Proposal 2009004) and for .name on 16 February 2011 (RSEP Proposal 2011001). 

Unique to the TLD: This service is not provided in a manner unique to the .MLS TLD.

3.2 Other allocation methods

As set forth above, an additional registry service which CREA will offer, commonly used in the marketplace today, is the use of RFPs (Request for Proposals) to determine string allocation in appropriate circumstances.

1 ROBUST PLAN FOR OPERATING A RELIABLE SRS

1.1 High-Level Shared Registration System (SRS) System Description

Verisign, The Canadian Real Estate Association’s (“CREA”) selected provider of backend registry services, provides and operates a robust and reliable SRS that enables multiple registrars to provide domain name registration services in the top-level domain (TLD). Verisign’s proven reliable SRS serves approximately 915 registrars, and Verisign, as a company, has averaged more than 140 million registration transactions per day. The SRS provides a scalable, fault-tolerant platform for the delivery of gTLDs through the use of a central customer database, a web interface, a standard provisioning protocol (i.e., Extensible Provisioning Protocol, EPP), and a transport protocol (i.e., Secure Sockets Layer, SSL). 

The SRS components include:

* Web Interface: Allows customers to access the authoritative database for accounts, contacts, users, authorization groups, product catalog, product subscriptions, and customer notification messages.

* EPP Interface: Provides an interface to the SRS that enables registrars to use EPP to register and manage domains, hosts, and contacts.

* Authentication Provider: A Verisign developed application, specific to the SRS, that authenticates a user based on a login name, password, and the SSL certificate common name and client IP address. 

The SRS is designed to be scalable and fault tolerant by incorporating clustering in multiple tiers of the platform. New nodes can be added to a cluster within a single tier to scale a specific tier, and if one node fails within a single tier, the services will still be available. The SRS allows registrars to manage the .MLS gTLD domain names in a single architecture.

To flexibly accommodate the scale of its transaction volumes, as well as new technologies, Verisign employs the following design practices:

* Scale for Growth: Scale to handle current volumes and projected growth.

* Scale for Peaks: Scale to twice base capacity to withstand “registration add attacks” from a compromised registrar system.

* Limit Database CPU Utilization: Limit utilization to no more than 50 percent during peak loads.

* Limit Database Memory Utilization: Each user’s login process that connects to the database allocates a small segment of memory to perform connection overhead, sorting, and data caching. Verisign’s standards mandate that no more than 40 percent of the total available physical memory on the database server will be allocated for these functions. 

Verisign’s SRS is built upon a three-tier architecture as illustrated in Figure 24-1 and detailed here: 

* Gateway Layer: The first tier, the gateway servers, uses EPP to communicate with registrars. These gateway servers then interact with application servers, which comprise the second tier.

* Application Layer: The application servers contain business logic for managing and maintaining the registry business. The business logic is particular to each TLD’s business rules and requirements. The flexible internal design of the application servers allows Verisign to easily leverage existing business rules to apply to the .MLS gTLD. The application servers store CREA’s data in the registry database, which comprises the third and final tier. This simple, industry-standard design has been highly effective with other customers for whom Verisign provides backend registry services.

* Database Layer: The database is the heart of this architecture. It stores all the essential information provisioned from registrars through the gateway servers. Separate servers query the database, extract updated zone and Whois information, validate that information, and distribute it around the clock to Verisign’s worldwide domain name resolution sites.

Figure 24-1: See Canadian Real Estate Assoc_Q24_shared registration system performance

Scalability and Performance. Verisign, CREA’s selected backend registry services provider, implements its scalable SRS on a supportable infrastructure that achieves the availability requirements in Specification 10. Verisign employs the design patterns of simplicity and parallelism in both its software and systems, based on its experience that these factors contribute most significantly to scalability and reliable performance. Going counter to feature-rich development patterns, Verisign intentionally minimizes the number of lines of code between the end user and the data delivered. The result is a network of restorable components that provide rapid, accurate updates. Figure 24-2 depicts EPP traffic flows and local redundancy in Verisign’s SRS provisioning architecture. As detailed in the figure, local redundancy is maintained for each layer as well as each piece of equipment. This built-in redundancy enhances operational performance while enabling the future system scaling necessary to meet additional demand created by this or future registry applications. 

Figure 24-2: See attached

Besides improving scalability and reliability, local SRS redundancy enables Verisign to take down individual system components for maintenance and upgrades, with little to no performance impact. With Verisign’s redundant design, Verisign can perform routine maintenance while the remainder of the system remains online and unaffected. For the .MLS gTLD registry, this flexibility minimizes unplanned downtime and provides a more consistent end-user experience. 

1.2 Representative Network Diagrams

Figure 24-3 provides a summary network diagram of CREA’s selected backend registry services provider’s (Verisign’s) SRS. This configuration at both the primary and alternate-primary Verisign data centers provides a highly reliable backup capability. Data is continuously replicated between both sites to ensure failover to the alternate-primary site can be implemented expeditiously to support both planned and unplanned outages. 

Figure 24-3: See attached

1.3 Number of Servers

As CREA’s selected provider of backend registry services, Verisign continually reviews its server deployments for all aspects of its registry service. Verisign evaluates usage based on peak performance objectives as well as current transaction volumes, which drive the quantity of servers in its implementations. Verisign’s scaling is based on the following factors:

* Server configuration is based on CPU, memory, disk IO, total disk, and network throughput projections.

* Server quantity is determined through statistical modeling to fulfill overall performance objectives as defined by both the service availability and the server configuration. 

* To ensure continuity of operations for the .MLS gTLD, Verisign uses a minimum of 100 dedicated servers per SRS site. These servers are virtualized to meet demand. 

1.4 Description of Interconnectivity with Other Registry Systems

Figure 24-4 provides a technical overview of the CREA’s selected backend registry services provider’s (Verisign’s) SRS, showing how the SRS component fits into this larger system and interconnects with other system components. 

Figure 24-4: See attached

1.5 Frequency of Synchronization Between Servers

As CREA’s selected provider of backend registry services, Verisign uses synchronous replication to keep the Verisign SRS continuously in sync between the two data centers. This synchronization is performed in near-real time, thereby supporting rapid failover should a failure occur or a planned maintenance outage be required.

1.6 Synchronization Scheme

Verisign uses synchronous replication to keep the Verisign SRS continuously in sync between the two data centers. Because the alternate-primary site is continuously up, and built using an identical design to the primary data center, it is classified as a “hot standby.” 

2 SCALABILITY AND PERFORMANCE ARE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY

Verisign is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies. 

Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the .MLS gTLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to CREA fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.

3 TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION

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

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

Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support SRS performance:

* Application Engineers: 19
* Database Administrators: 8 
* Database Engineers: 3
* Network Administrators: 11 
* Network Architects: 4 
* Project Managers: 25
* Quality Assurance Engineers: 11 
* SRS System Administrators: 13 
* Storage Administrators: 4
* Systems Architects: 9

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

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

4 EVIDENCE OF COMPLIANCE WITH SPECIFICATION 6 AND 10 TO THE REGISTRY AGREEMENT

Section 1.2 (EPP) of Specification 6, Registry Interoperability and Continuity Specifications. Verisign, CREA’s selected backend registry services provider, provides these services using its SRS, which complies fully with Specification 6, Section 1.2 of the Registry Agreement. In using its SRS to provide backend registry services, Verisign implements and complies with relevant existing RFCs (i.e., 5730, 5731, 5732, 5733, 5734, and 5910) and intends to comply with RFCs that may be published in the future by the Internet Engineering Task Force (IETF), including successor standards, modifications, or additions thereto relating to the provisioning and management of domain names that use EPP. In addition, Verisign’s SRS includes a Registry Grace Period (RGP) and thus complies with RFC 3915 and its successors. Details of the Verisign SRS’ compliance with RFC SRS⁄EPP are provided in the response to Question 25, Extensible Provisioning Protocol. Verisign does not use functionality outside the base EPP RFCs, although proprietary EPP extensions are documented in Internet-Draft format following the guidelines described in RFC 3735 within the response to Question 25. Moreover, prior to deployment, CREA will provide to ICANN updated documentation of all the EPP objects and extensions supported in accordance with Specification 6, Section 1.2.

Specification 10, EPP Registry Performance Specifications. Verisign’s SRS meets all EPP Registry Performance Specifications detailed in Specification 10, Section 2. Evidence of this performance can be verified by a review of the .com and .net Registry Operator’s Monthly Reports, which Verisign files with ICANN. These reports detail Verisign’s operational status of the .com and .net registries, which use an SRS design and approach comparable to the one proposed for the .MLS gTLD. These reports provide evidence of Verisign’s ability to meet registry operation service level agreements (SLAs) comparable to those detailed in Specification 10. The reports are accessible at the following URL: http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄. 

In accordance with EPP Registry Performance Specifications detailed in Specification 10, Verisignʹs SRS meets the following performance attributes:

* EPP service availability: 〈 or = 864 minutes of downtime (approx. 98%)

* EPP session-command round trip time (RTT): 〈 or = 4000 milliseconds (ms), for at least 90 percent of the commands

* EPP query-command RTT: 〈 or = 2000 ms, for at least 90 percent of the commands

* EPP transform-command RTT: 〈 or = 4000 ms, for at least 90 percent of the commands

1 COMPLETE KNOWLEDGE AND UNDERSTANDING OF THIS ASPECT OF REGISTRY TECHNICAL REQUIREMENTS

Verisign, The Canadian Real Estate Association’s (“CREA”) selected backend registry services provider, has used Extensible Provisioning Protocol (EPP) since its inception and possesses complete knowledge and understanding of EPP registry systems. Its first EPP implementation— for a thick registry for the .name generic top-level domain (gTLD)—was in 2002. Since then Verisign has continued its RFC-compliant use of EPP in multiple TLDs, as detailed in Figure 25-1. 

Figure 25-1: See Canadian Real Estate Assoc_Q25_extensible provisioning protocol_F25-1

Verisign’s understanding of EPP and its ability to implement code that complies with the applicable RFCs is unparalleled. Mr. Scott Hollenbeck, Verisign’s director of software development, authored the Extensible Provisioning Protocol and continues to be fully engaged in its refinement and enhancement (U.S. Patent Number 7299299 – Shared registration system for registering domain names). Verisign has also developed numerous new object mappings and object extensions following the guidelines in RFC 3735 (Guidelines for Extending the Extensible Provisioning Protocol). Mr. James Gould, a principal engineer at Verisign, led and co-authored the most recent EPP Domain Name System Security Extensions (DNSSEC) RFC effort (RFC 5910).

All registry systems for which Verisign is the registry operator or provides backend registry services use EPP. Upon approval of this application, Verisign will use EPP to provide the backend registry services for this gTLD. The .com, .net, and .name registries for which Verisign is the registry operator use an SRS design and approach comparable to the one proposed for this gTLD. Approximately 915 registrars use the Verisign EPP service, and the registry system performs more than 140 million EPP transactions daily without performance issues or restrictive maintenance windows. The processing time service level agreement (SLA) requirements for the Verisign-operated .net gTLD are the strictest of the current Verisign managed gTLDs. All processing times for Verisign-operated gTLDs can be found in ICANN’s Registry Operator’s Monthly Reports at http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄. 

Verisign has also been active on the Internet Engineering Task Force (IETF) Provisioning Registry Protocol (provreg) working group and mailing list since work started on the EPP protocol in 2000. This working group provided a forum for members of the Internet community to comment on Mr. Scott Hollenbeck’s initial EPP drafts, which Mr. Hollenbeck refined based on input and discussions with representatives from registries, registrars, and other interested parties. The working group has since concluded, but the mailing list is still active to enable discussion of different aspects of EPP.

1.1 EPP Interface with Registrars

Verisign, CREA’s selected backend registry services provider, fully supports the features defined in the EPP specifications and provides a set of software development kits (SDK) and tools to help registrars build secure and stable interfaces. Verisign’s SDKs give registrars the option of either fully writing their own EPP client software to integrate with the Shared Registration System (SRS), or using the Verisign-provided SDKs to aid them in the integration effort. Registrars can download the Verisign EPP SDKs and tools from the registrar website (http:⁄⁄www.Verisign.com⁄domain-name-services⁄current-registrars⁄epp-sdk⁄index.html). 

The EPP SDKs provide a host of features including connection pooling, Secure Sockets Layer (SSL), and a test server (stub server) to run EPP tests against. One tool—the EPP tool—provides a web interface for creating EPP Extensible Markup Language (XML) commands and sending them to a configurable set of target servers. This helps registrars in creating the template XML and testing a variety of test cases against the EPP servers. An Operational Test and Evaluation (OT&E) environment, which runs the same software as the production system so approved registrars can integrate and test their software before moving into a live production environment, is also available. 

2 TECHNICAL PLAN SCOPE⁄SCALE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY

Verisign, CREA’s selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies. 

Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the .MLS gTLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to CREA fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.

3 TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION

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

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

Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support the provisioning of EPP services:

* Application Engineers: 19 
* Database Engineers: 3 
* Quality Assurance Engineers: 11 

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

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

4 ABILITY TO COMPLY WITH RELEVANT RFCS 

Verisign, CREA’s selected backend registry services provider, incorporates design reviews, code reviews, and peer reviews into its software development lifecycle (SDLC) to ensure compliance with the relevant RFCs. Verisign’s dedicated QA team creates extensive test plans and issues internal certifications when it has confirmed the accuracy of the code in relation to the RFC requirements. Verisign’s QA organization is independent from the development team within engineering. This separation helps Verisign ensure adopted processes and procedures are followed, further ensuring that all software releases fully consider the security and stability of the TLD. 

For the .MLS gTLD, the Shared Registration System (SRS) complies with the following IETF EPP specifications, where the XML templates and XML schemas are defined in the following specifications:

* EPP RGP 3915 (http:⁄⁄www.apps.ietf.org⁄rfc⁄rfc3915.html): EPP Redemption Grace Period (RGP) Mapping specification for support of RGP statuses and support of Restore Request and Restore Report (authored by Verisign’s Scott Hollenbeck)

* EPP 5730 (http:⁄⁄tools.ietf.org⁄html⁄rfc5730): Base EPP specification (authored by Verisign’s Scott Hollenbeck)

* EPP Domain 5731 (http:⁄⁄tools.ietf.org⁄html⁄rfc5731): EPP Domain Name Mapping specification (authored by Verisign’s Scott Hollenbeck)

* EPP Host 5732 (http:⁄⁄tools.ietf.org⁄html⁄rfc5732): EPP Host Mapping specification (authored by Verisign’s Scott Hollenbeck)

* EPP Contact 5733 (http:⁄⁄tools.ietf.org⁄html⁄rfc5733): EPP Contact Mapping specification (authored by Verisign’s Scott Hollenbeck)

* EPP TCP 5734 (http:⁄⁄tools.ietf.org⁄html⁄rfc5734): EPP Transport over Transmission Control Protocol (TCP) specification (authored by Verisign’s Scott Hollenbeck)

* EPP DNSSEC 5910 (http:⁄⁄tools.ietf.org⁄html⁄rfc5910): EPP Domain Name System Security Extensions (DNSSEC) Mapping specification (authored by Verisign’s James Gould and Scott Hollenbeck)

5 PROPRIETARY EPP EXTENSIONS

Verisign, CREA’s selected backend registry services provider, uses its SRS to provide registry services. The SRS supports the following EPP specifications, which Verisign developed following the guidelines in RFC 3735, where the XML templates and XML schemas are defined in the specifications:

* IDN Language Tag (http:⁄⁄www.verisigninc.com⁄assets⁄idn-language-tag.pdf): EPP internationalized domain names (IDN) language tag extension used for IDN domain name registrations

* RGP Poll Mapping (http:⁄⁄www.verisigninc.com⁄assets⁄whois-info-extension.pdf): EPP mapping for an EPP poll message in support of Restore Request and Restore Report

* Whois Info Extension (http:⁄⁄www.verisigninc.com⁄assets⁄whois-info-extension.pdf): EPP extension for returning additional information needed for transfers

* EPP ConsoliDate Mapping (http:⁄⁄www.verisigninc.com⁄assets⁄consolidate-mapping.txt): EPP mapping to support a Domain Sync operation for synchronizing domain name expiration dates

* NameStore Extension (http:⁄⁄www.verisigninc.com⁄assets⁄namestore-extension.pdf): EPP extension for routing with an EPP intelligent gateway to a pluggable set of backend products and services

* Low Balance Mapping (http:⁄⁄www.verisigninc.com⁄assets⁄low-balance-mapping.pdf): EPP mapping to support low balance poll messages that proactively notify registrars of a low balance (available credit) condition

As part of the 2006 implementation report to bring the EPP RFC documents from Proposed Standard status to Draft Standard status, an implementation test matrix was completed. Two independently developed EPP client implementations based on the RFCs were tested against the Verisign EPP server for the domain, host, and contact transactions. No compliance-related issues were identified during this test, providing evidence that these extensions comply with RFC 3735 guidelines and further demonstrating Verisign’s ability to design, test, and deploy an RFC-compliant EPP implementation.

5.1 EPP Templates and Schemas

The EPP XML schemas are formal descriptions of the EPP XML templates. They are used to express the set of rules to which the EPP templates must conform in order to be considered valid by the schema. The EPP schemas define the building blocks of the EPP templates, describing the format of the data and the different EPP commands’ request and response formats. The current EPP implementations managed by Verisign, CREA’s selected backend registry services provider, use these EPP templates and schemas, as will the proposed TLD. For each proprietary XML template⁄schema Verisign provides a reference to the applicable template and includes the schema.

XML templates⁄schema for idnLang-1.0: See Canadian Real Estate Assoc_Q25_extensible provisioning protocol_xml

XML templates⁄schema for rgp-poll-1.0: See Canadian Real Estate Assoc_Q25_extensible provisioning protocol_xml

XML templates⁄schema for whoisInf-1.0: See Canadian Real Estate Assoc_Q25_extensible provisioning protocol_xml

XML templates⁄schema for sync-1.0 (consoliDate): See Canadian Real Estate Assoc_Q25_extensible provisioning protocol_xml

XML templates⁄schema for namestoreExt-1.1: See Canadian Real Estate Assoc_Q25_extensible provisioning protocol_xml

XML templates⁄schema for lowbalance-poll-1.0: See Canadian Real Estate Assoc_Q25_extensible provisioning protocol_xml

6 PROPRIETARY EPP EXTENSION CONSISTENCY WITH REGISTRATION LIFECYCLE 

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

1 COMPLETE KNOWLEDGE AND UNDERSTANDING OF THIS ASPECT OF REGISTRY TECHNICAL REQUIREMENTS

Verisign, The Canadian Real Estate Association’s (“CREA”) selected backend registry services provider, has operated the Whois lookup service for the gTLDs and ccTLDs it manages since 1991, and will provide these proven services for the .MLS gTLD registry. In addition, it continues to work with the Internet community to improve the utility of Whois data, while thwarting its application for abusive uses.

1.1 High-Level Whois System Description

Like all other components of CREA’s selected backend registry services provider’s (Verisign’s) registry service, Verisign’s Whois system is designed and built for both reliability and performance in full compliance with applicable RFCs. Verisign’s current Whois implementation has answered more than five billion Whois queries per month for the TLDs it manages, and has experienced more than 250,000 queries per minute in peak conditions. The proposed gTLD uses a Whois system design and approach that is comparable to the current implementation. Independent quality control testing ensures Verisign’s Whois service is RFC-compliant through all phases of its lifecycle. 

Verisignʹs redundant Whois databases further contribute to overall system availability and reliability. The hardware and software for its Whois service is architected to scale both horizontally (by adding more servers) and vertically (by adding more CPUs and memory to existing servers) to meet future need.

Verisign can fine-tune access to its Whois database on an individual Internet Protocol (IP) address basis, and it works with registrars to help ensure their services are not limited by any restriction placed on Whois. Verisign provides near real-time updates for Whois services for the TLDs under its management. As information is updated in the registration database, it is propagated to the Whois servers for quick publication. These updates align with the near real-time publication of Domain Name System (DNS) information as it is updated in the registration database. This capability is important for the .MLS gTLD registry as it is Verisign’s experience that when DNS data is updated in near real time, so should Whois data be updated to reflect the registration specifics of those domain names.

Verisign’s Whois response time has been less than 500 milliseconds for 95 percent of all Whois queries in .com, .net, .tv, and .cc. The response time in these TLDs, combined with Verisign’s capacity, enables the Whois system to respond to up to 30,000 searches (or queries) per second for a total capacity of 2.6 billion queries per day.

The Whois software written by Verisign complies with RFC 3912. Verisign uses an advanced in-memory database technology to provide exceptional overall system performance and security. In accordance with RFC 3912, Verisign provides a website at whois.nic.〈TLD〉 that provides free public query-based access to the registration data. 

Verisign currently operates both thin and thick Whois systems. 

Verisign commits to implementing a RESTful Whois service upon finalization of agreements with the IETF (Internet Engineering Task Force).

Provided Functionalities for User Interface

To use the Whois service via port 43, the user enters the applicable parameter on the command line as illustrated here:

* For domain name: whois EXAMPLE.TLD
* For registrar: whois ʺregistrar Example Registrar, Inc.ʺ
* For name server: whois ʺNS1.EXAMPLE.TLDʺ or whois ʺname server (IP address)ʺ

To use the Whois service via the web-based directory service search interface:

* Go to http:⁄⁄whois.nic.〈TLD〉
* Click on the appropriate button (Domain, Registrar, or Name Server)
* Enter the applicable parameter:
o Domain name, including the TLD (e.g., EXAMPLE.TLD)
o Full name of the registrar, including punctuation (e.g., Example Registrar, Inc.)
o Full host name or the IP address (e.g., NS1.EXAMPLE.TLD or 198.41.3.39)
* Click on the Submit button.

Provisions to Ensure That Access Is Limited to Legitimate Authorized Users and Is in Compliance with Applicable Privacy Laws or Policies

To further promote reliable and secure Whois operations, Verisign, CREA’s selected backend registry services provider, has implemented rate-limiting characteristics within the Whois service software. For example, to prevent data mining or other abusive behavior, the service can throttle a specific requestor if the query rate exceeds a configurable threshold. In addition, QoS technology enables rate limiting of queries before they reach the servers, which helps protect against denial of service (DoS) and distributed denial of service (DDoS) attacks.

Verisign’s software also permits restrictions on search capabilities. For example, wild card searches can be disabled. If needed, it is possible to temporarily restrict and⁄or block requests coming from specific IP addresses for a configurable amount of time. Additional features that are configurable in the Whois software include help files, headers and footers for Whois query responses, statistics, and methods to memory map the database. Furthermore, Verisign is European Union (EU) Safe Harbor certified and has worked with European data protection authorities to address applicable privacy laws by developing a tiered Whois access structure that requires users who require access to more extensive data to (i) identify themselves, (ii) confirm that their use is for a specified purpose and (iii) enter into an agreement governing their use of the more extensive Whois data. 

1.2 Relevant Network Diagrams

Figure 26-1 provides a summary network diagram of the Whois service provided by Verisign, CREA’s selected backend registry services provider. The figure details the configuration with one resolution⁄Whois site. For the .MLS gTLD Verisign provides Whois service from 6 of its 17 primary sites based on the proposed gTLD’s traffic volume and patterns. A functionally equivalent resolution architecture configuration exists at each Whois site. 

Figure 26-1: See Canadian Real Estate Assoc_Q26_whois

1.3 IT and Infrastructure Resources

Figure 26-2 summarizes the IT and infrastructure resources that Verisign, CREA’s selected backend registry services provider, uses to provision Whois services from Verisign primary resolution sites. As needed, virtual machines are created based on actual and projected demand.

Figure 26-2: See attached

1.4 Description of Interconnectivity with Other Registry Systems

Figure 26-3 provides a technical overview of the registry system provided by Verisign, CREA’s selected backend registry services provider, and shows how the Whois service component fits into this larger system and interconnects with other system components. 

Figure 26-3: See attached

1.5 Frequency of Synchronization Between Servers

Synchronization between the SRS and the geographically distributed Whois resolution sites occurs approximately every three minutes. Verisign, CREA’s selected backend registry services provider, uses a two-part Whois update process to ensure Whois data is accurate and available. Every 12 hours an initial file is distributed to each resolution site. This file is a complete copy of all Whois data fields associated with each domain name under management. As interactions with the SRS cause the Whois data to be changed, these incremental changes are distributed to the resolution sites as an incremental file update. This incremental update occurs approximately every three minutes. When the new 12-hour full update is distributed, this file includes all past incremental updates. Verisign’s approach to frequency of synchronization between servers meets the Performance Specifications defined in Specification 10 of the Registry Agreement for new gTLDs. 

2 TECHNICAL PLAN SCOPE⁄SCALE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY

Verisign, CREA’s selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies. 

Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the .MLS gTLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to CREA fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.

3 TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION

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

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

Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support Whois services:

* Application Engineers: 19
* Database Engineers: 3
* Quality Assurance Engineers: 11

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

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

4 COMPLIANCE WITH RELEVANT RFC

CREA’s selected backend registry services provider’s (Verisign’s) Whois service complies with the data formats defined in Specification 4 of the Registry Agreement. Verisign will provision Whois services for registered domain names and associated data in the top-level domain (TLD). Verisign’s Whois services are accessible over Internet Protocol version 4 (IPv4) and Internet Protocol version 6 (IPv6), via both Transmission Control Protocol (TCP) port 43 and a web-based directory service at whois.nic.〈TLD〉, which in accordance with RFC 3912, provides free public query-based access to domain name, registrar, and name server lookups. Verisign’s proposed Whois system meets all requirements as defined by ICANN for each registry under Verisign management. Evidence of this successful implementation, and thus compliance with the applicable RFCs, can be verified by a review of the .com and .net Registry Operator’s Monthly Reports that Verisign files with ICANN. These reports provide evidence of Verisign’s ability to meet registry operation service level agreements (SLAs) comparable to those detailed in Specification 10. The reports are accessible at the following URL: http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄. 
5 COMPLIANCE WITH SPECIFICATIONS 4 AND 10 OF REGISTRY AGREEMENT

In accordance with Specification 4, Verisign, CREA’s selected backend registry services provider, provides a Whois service that is available via both port 43 in accordance with RFC 3912, and a web-based directory service at whois.nic.〈TLD〉 also in accordance with RFC 3912, thereby providing free public query-based access. Verisign acknowledges that ICANN reserves the right to specify alternative formats and protocols, and upon such specification, Verisign will implement such alternative specification as soon as reasonably practicable.

The format of the following data fields conforms to the mappings specified in Extensible Provisioning Protocol (EPP) RFCs 5730 – 5734 so the display of this information (or values returned in Whois responses) can be uniformly processed and understood: domain name status, individual and organizational names, address, street, city, state⁄province, postal code, country, telephone and fax numbers, email addresses, date, and times.

Specifications for data objects, bulk access, and lookups comply with Specification 4 and are detailed in the following subsections, provided in both bulk access and lookup modes. 

Bulk Access Mode. This data is provided on a daily schedule to a party designated from time to time in writing by ICANN. The specification of the content and format of this data, and the procedures for providing access, shall be as stated below, until revised in the ICANN Registry Agreement. 

The data is provided in three files:

* Domain Name File: For each domain name, the file provides the domain name, server name for each name server, registrar ID, and updated date.

* Name Server File: For each registered name server, the file provides the server name, each IP address, registrar ID, and updated date.

* Registrar File: For each registrar, the following data elements are provided: registrar ID, registrar address, registrar telephone number, registrar email address, Whois server, referral URL, updated date, and the name, telephone number, and email address of all the registrarʹs administrative, billing, and technical contacts.

Lookup Mode. Figures 26-4 through Figure 26-6 provide the query and response format for domain name, registrar, and name server data objects.

Figure 26-4: See attached

Figure 26-5: See attached

Figure 26-6: See attached

5.1 Specification 10, RDDS Registry Performance Specifications

The Whois service meets all registration data directory services (RDDS) registry performance specifications detailed in Specification 10, Section 2. Evidence of this performance can be verified by a review of the .com and .net Registry Operator’s Monthly Reports that Verisign files monthly with ICANN. These reports are accessible from the ICANN website at the following URL: http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄. 

In accordance with RDDS registry performance specifications detailed in Specification 10, Verisignʹs Whois service meets the following proven performance attributes:

* RDDS availability: 〈 or = 864 min of downtime (approx. 98%)
* RDDS query RTT: 〈 or = 2000 ms, for at least 95% of the queries
* RDDS update time: 〈 or = 60 min, for at least 95% of the probes

6 SEARCHABLE WHOIS

Verisign, CREA’s selected backend registry services provider, provides a searchable Whois service for the .MLS gTLD. Verisign has experience in providing tiered access to Whois for the .name registry, and uses these methods and control structures to help reduce potential malicious use of the function. The searchable Whois system currently uses Apache’s Lucene full text search engine to index relevant Whois content with near-real time incremental updates from the provisioning system.

Features of the Verisign searchable Whois function include:

* Provision of a web-based searchable directory service

* Ability to perform partial match, at least, for the following data fields: domain name, contacts and registrant’s name, and contact and registrant’s postal address, including all the sub-fields described in EPP (e.g., street, city, state, or province)

* Ability to perform exact match, at least, on the following fields: registrar ID, name server name, and name server’s IP address (only applies to IP addresses stored by the registry, i.e., glue records)

* Ability to perform Boolean search supporting, at least, the following logical operators to join a set of search criteria: AND, OR, NOT 

* Search results that include domain names that match the selected search criteria

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

* All unauthenticated searches are returned as thin results.

* Registry system authentication is used to grant access to appropriate users for thick Whois data search results.

* Account access is granted by CREA’s defined .MLS gTLD admin user.

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

Figure 26-7: See attached 

1 COMPLETE KNOWLEDGE AND UNDERSTANDING OF REGISTRATION LIFECYCLES AND STATES

Starting with domain name registration and continuing through domain name delete operations, The Canadian Real Estate Association’s (“CREA”) selected backend registry services provider’s (Verisign’s) registry implements the full registration lifecycle for domain names supporting the operations in the Extensible Provisioning Protocol (EPP) specification. The registration lifecycle of the domain name starts with registration and traverses various states as specified in the following sections. The registry system provides options to update domain names with different server and client status codes that block operations based on the EPP specification. The system also provides different grace periods for different billable operations, where the price of the billable operation is credited back to the registrar if the billable operation is removed within the grace period. Together Figure 27-1 and Figure 27-2 define the registration states comprising the registration lifecycle and explain the trigger points that cause state-to-state transitions. States are represented as green rectangles within Figure 27-1.

Figure 27-1: See Medistry LLC_Q27_registration lifecycle

Figure 27-2: See attached

1.1 Registration Lifecycle of Create⁄Update⁄Delete

The following section details the create⁄update⁄delete processes and the related renewal process that Verisign, CREA’s selected backend registry services provider, follows. For each process, this response defines the process function and its characterization, and as appropriate provides a process flow chart. 

Create Process. The domain name lifecycle begins with a registration or what is referred to as a Domain Name Create operation in EPP. The system fully supports the EPP Domain Name Mapping as defined by RFC 5731, where the associated objects (e.g., hosts and contacts) are created independent of the domain name.

Process Characterization. The Domain Name Create command is received, validated, run through a set of business rules, persisted to the database, and committed in the database if all business rules pass. The domain name is included with the data flow to the DNS and Whois resolution services. If no name servers are supplied, the domain name is not included with the data flow to the DNS. A successfully created domain name has the created date and expiration date set in the database. Creates are subject to grace periods as described in Section 1.3 of this response, Add Grace Period, Redemption Grace Period, and Notice Periods for Renewals or Transfers. 

The Domain Name Create operation is detailed in Figure 27-3 and requires the following attributes:

* A domain name that meets the string restrictions.

* A domain name that does not already exist.

* The registrar is authorized to create a domain name in .MLS.

* The registrar has available credit.

* A valid Authorization Information (Auth-Info) value.

* Required contacts (e.g., registrant, administrative contact, technical contact, and billing contact) are specified and exist.

* The specified name servers (hosts) exist, and there is a maximum of 13 name servers.

* A period in units of years with a maximum value of 10 (default period is one year).

Figure 27-3: See attached

Renewal Process. The domain name can be renewed unless it has any form of Pending Delete, Pending Transfer, or Renew Prohibited.

A request for renewal that sets the expiry date to more than ten years in the future is denied. The registrar must pass the current expiration date (without the timestamp) to support the idempotent features of EPP, where sending the same command a second time does not cause unexpected side effects.

Automatic renewal occurs when a domain name expires. On the expiration date, the registry extends the registration period one year and debits the registrar account balance. In the case of an auto-renewal of the domain name, a separate Auto-Renew grace period applies. Renewals are subject to grace periods as described in Section 1.3 of this response, Add Grace Period, Redemption Grace Period, and Notice Periods for Renewals or Transfers.

Process Characterization. The Domain Name Renew command is received, validated, authorized, and run through a set of business rules. The data is updated and committed in the database if it passes all business rules. The updated domain name’s expiration date is included in the flow to the Whois resolution service. 

The Domain Name Renew operation is detailed in Figure 27-4 and requires the following attributes:

* A domain name that exists and is sponsored by the requesting registrar.
* The registrar is authorized to renew a domain name in .MLS.
* The registrar has available credit.
* The passed current expiration date matches the domain name’s expiration date.
* A period in units of years with a maximum value of 10 (default period is one year). A domain name expiry past ten years is not allowed.

Figure 27-4: See attached

Registrar Transfer Procedures. A registrant may transfer his⁄her domain name from his⁄her current registrar to another registrar. The database system allows a transfer as long as the transfer is not within the initial 60 days, per industry standard, of the original registration date. 

The registrar transfer process goes through many process states, which are described in detail below, unless it has any form of Pending Delete, Pending Transfer, or Transfer Prohibited.

A transfer can only be initiated when the appropriate Auth-Info is supplied. The Auth-Info for transfer is only available to the current registrar. Any other registrar requesting to initiate a transfer on behalf of a registrant must obtain the Auth-Info from the registrant.

The Auth-Info is made available to the registrant upon request. The registrant is the only party other than the current registrar that has access to the Auth-Info. Registrar transfer entails a specified extension of the expiry date for the object. The registrar transfer is a billable operation and is charged identically to a renewal for the same extension of the period. This period can be from one to ten years, in one-year increments.

Because registrar transfer involves an extension of the registration period, the rules and policies applying to how the resulting expiry date is set after transfer are based on the renewal policies on extension.

Per industry standard, a domain name cannot be transferred to another registrar within the first 60 days after registration. This restriction continues to apply if the domain name is renewed during the first 60 days. Transfer of the domain name changes the sponsoring registrar of the domain name, and also changes the child hosts (ns1.sample.xyz) of the domain name (sample .xyz). 

The domain name transfer consists of five separate operations:

* Transfer Request (Figure 27-5): Executed by a non-sponsoring registrar with the valid Auth-Info provided by the registrant. The Transfer Request holds funds of the requesting registrar but does not bill the registrar until the transfer is completed. The sponsoring registrar receives a Transfer Request poll message.

* Transfer Cancel (Figure 27-6): Executed by the requesting registrar to cancel the pending transfer. The held funds of the requesting registrar are reversed. The sponsoring registrar receives a Transfer Cancel poll message.

* Transfer Approve (Figure 27-7): Executed by the sponsoring registrar to approve the Transfer Request. The requesting registrar is billed for the Transfer Request and the sponsoring registrar is credited for an applicable Auto-Renew grace period. The requesting registrar receives a Transfer Approve poll message.

* Transfer Reject (Figure 27-8): Executed by the sponsoring registrar to reject the pending transfer. The held funds of the requesting registrar are reversed. The requesting registrar receives a Transfer Reject poll message.

* Transfer Query (Figure 27-9): Executed by either the requesting registrar or the sponsoring registrar of the last transfer.

The registry auto-approves a transfer if the sponsoring registrar takes no action. The requesting registrar is billed for the Transfer Request and the sponsoring registrar is credited for an applicable Auto-Renew grace period. The requesting registrar and the sponsoring registrar receive a Transfer Auto-Approve poll message. 

Figure 27-5: See attached

Figure 27-6: See attached

Figure 27-7: See attached

Figure 27-8: See attached

Figure 27-9: See attached

Delete Process. A registrar may choose to delete the domain name at any time. 

Process Characterization. The domain name can be deleted, unless it has any form of Pending Delete, Pending Transfer, or Delete Prohibited.

A domain name is also prohibited from deletion if it has any in-zone child hosts that are name servers for domain names. For example, the domain name “sample.xyz” cannot be deleted if an in-zone host “ns.sample.xyz” exists and is a name server for “sample2.xyz.”

If the Domain Name Delete occurs within the Add grace period, the domain name is immediately deleted and the sponsoring registrar is credited for the Domain Name Create. If the Domain Name Delete occurs outside the Add grace period, it follows the Redemption grace period (RGP) lifecycle.

Update Process. The sponsoring registrar can update the following attributes of a domain name:

* Auth-Info
* Name servers
* Contacts (i.e., registrant, administrative contact, technical contact, and billing contact)
* Statuses (e.g., Client Delete Prohibited, Client Hold, Client Renew Prohibited, Client Transfer Prohibited, Client Update Prohibited)

Process Characterization. Updates are allowed provided that the update includes the removal of any Update Prohibited status. The Domain Name Update operation is detailed in Figure 27-10. 

A domain name can be updated unless it has any form of Pending Delete, Pending Transfer, or Update Prohibited.

Figure 27-10: See attached

1.2 Pending, Locked, Expired, and Transferred 

Verisign, CREA’s selected backend registry services provider, handles pending, locked, expired, and transferred domain names as described here. When the domain name is deleted after the five-day Add grace period, it enters into the Pending Delete state. The registrant can return its domain name to active any time within the five-day Pending Delete grace period. After the five-day Pending Delete grace period expires, the domain name enters the Redemption Pending state and then is deleted by the system. The registrant can restore the domain name at any time during the Redemption Pending state.

When a non-sponsoring registrar initiates the domain name transfer request, the domain name enters Pending Transfer state and a notification is mailed to the sponsoring registrar for approvals. If the sponsoring registrar doesn’t respond within five days, the Pending Transfer expires and the transfer request is automatically approved.

EPP specifies both client (registrar) and server (registry) status codes that can be used to prevent registry changes that are not intended by the registrant. Currently, many registrars use the client status codes to protect against inadvertent modifications that would affect their customers’ high-profile or valuable domain names. 

Verisign’s registry service supports the following client (registrar) and server (registry) status codes:

* clientHold
* clientRenewProhibited
* clientTransferProhibited
* clientUpdateProhibited
* clientDeleteProhibited
* serverHold
* serverRenewProhibited
* serverTransferProhibited
* serverUpdateProhibited
* serverDeleteProhibited 

1.3 Add Grace Period, Redemption Grace Period, and Notice Periods for Renewals or Transfers

Verisign, CREA’s selected backend registry services provider, handles Add grace periods, Redemption grace periods, and notice periods for renewals or transfers as described here.

* Add Grace Period: The Add grace period is a specified number of days following the initial registration of the domain name. The current value of the Add grace period for all registrars is five days. 

* Redemption Grace Period: If the domain name is deleted after the five-day grace period expires, it enters the Redemption grace period and then is deleted by the system. The registrant has an option to use the Restore Request command to restore the domain name within the Redemption grace period. In this scenario, the domain name goes to Pending Restore state if there is a Restore Request command within 30 days of the Redemption grace period. From the Pending Restore state, it goes either to the OK state, if there is a Restore Report Submission command within seven days of the Restore Request grace period, or a Redemption Period state if there is no Restore Report Submission command within seven days of the Restore Request grace period. 

* Renew Grace Period: The Renew⁄Extend grace period is a specified number of days following the renewal⁄extension of the domain name’s registration period. The current value of the Renew⁄Extend grace period is five days. 

* Auto-Renew Grace Period: All auto-renewed domain names have a grace period of 45 days. 

* Transfer Grace Period: Domain names have a five-day Transfer grace period. 

1.4 Aspects of the Registration Lifecycle Not Covered by Standard EPP RFCs

CREA’s selected backend registry services provider’s (Verisign’s) registration lifecycle processes and code implementations adhere to the standard EPP RFCs related to the registration lifecycle. By adhering to the RFCs, Verisign’s registration lifecycle is complete and addresses each registration-related task comprising the lifecycle. No aspect of Verisign’s registration lifecycle is not covered by one of the standard EPP RFCs and thus no additional definitions are provided in this response.

2 CONSISTENCY WITH ANY SPECIFIC COMMITMENTS MADE TO REGISTRANTS AS ADAPTED TO THE OVERALL BUSINESS APPROACH FOR THE PROPOSED gTLD

The registration lifecycle described above applies to the .MLS gTLD as well as other TLDs managed by Verisign, CREA’s selected backend registry services provider; thus Verisign remains consistent with commitments made to its registrants. No unique or specific registration lifecycle modifications or adaptations are required to support the overall business approach for the .MLS gTLD. 

To accommodate a range of registries, Verisign’s registry implementation is capable of offering both a thin and thick Whois implementation, which is also built upon Verisign’s award-winning ATLAS infrastructure.

3 COMPLIANCE WITH RELEVANT RFCs

CREA’s selected backend registry services provider’s (Verisign’s) registration lifecycle complies with applicable RFCs, specifically RFCs 5730 – 5734 and 3915. The system fully supports the EPP Domain Name Mapping as defined by RFC 5731, where the associated objects (e.g., hosts and contacts) are created independent of the domain name.

In addition, in accordance with RFCs 5732 and 5733, the Verisign registration system enforces the following domain name registration constraints:

* Uniqueness⁄Multiplicity: A second-level domain name is unique in the .MLS database. Two identical second-level domain names cannot simultaneously exist in .MLS. Further, a second-level domain name cannot be created if it conflicts with a reserved domain name.

* Point of Contact Associations: The domain name is associated with the following points of contact. Contacts are created and managed independently according to RFC 5733. 

* Registrant
* Administrative contact
* Technical contact
* Billing contact

* Domain Name Associations: Each domain name is associated with:

* A maximum of 13 hosts, which are created and managed independently according to RFC 5732
* An Auth-Info, which is used to authorize certain operations on the object
* Status(es), which are used to describe the domain name’s status in the registry
* A created date, updated date, and expiry date

4 DEMONSTRATES THAT TECHNICAL RESOURCES REQUIRED TO CARRY THROUGH THE PLANS FOR THIS ELEMENT ARE ALREADY ON HAND OR READILY AVAILABLE

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

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

Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support the registration lifecycle:

* Application Engineers: 19 
* Customer Support Personnel: 36 
* Database Administrators: 8 
* Database Engineers: 3 
* Quality Assurance Engineers: 11 
* SRS System Administrators: 13 

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

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

1. Comprehensive abuse policies, which include clear definitions of what constitutes abuse in the TLD, and procedures that will effectively minimize potential for abuse in the TLD

The .MLS gTLD will have a comprehensive abuse policy, which includes a clear definition of what constitutes abuse in .MLS, and procedures in place to effectively minimize potential for abuse in .MLS. It is a core goal of .MLS to provide a trusted namespace that minimizes harm to Internet users (such as identity theft, harm to children and a general erosion of trust), while not negatively impacting Internet stability or security. The Canadian Real Estate Association (CREA) takes abuse prevention and mitigation seriously, and the following core elements of the plan (what constitutes abuse, what we will do if we find abuse, how we can be made aware of abuse, and the processes and procedures we will invoke) shows CREA’ commitment to abuse prevention and mitigation in .MLS.

1.1 .MLS Abuse Prevention and Mitigation Implementation Plan 

CREA takes abuse prevention and mitigation seriously. The attached .MLS Abuse Prevention and Mitigation plan (the “Plan”) will be published on .MLS’s registry website and details many of .MLS’s policies and procedures regarding abuse prevention and mitigation. The goal of the Plan is to address significant potential harm to Internet users, including identity theft, harm to children and erosion of trust by Internet users, and to address those who abuse the DNS and otherwise engage in illegal or fraudulent activity via the .MLS gTLD. 

The Plan includes a single abuse point of contact responsible for addressing matters requiring expedited attention and providing a timely response to abuse complaints concerning all .MLS names registered through all registrars of record, including those involving a reseller. The Plan identifies an Abuse Prevention Manager who will be tasked with being the primary point of contact for receiving all abuse complaints. 

The Plan also includes a clear definition of what constitutes “abuse.” Particularly, “abuse” or “abusive use” of a .MLS domain name is the wrongful or excessive use of power, position or ability with regard to a .MLS domain, and includes, without limitation, the following:
* Illegal or fraudulent actions;
* Spam: The use of electronic messaging systems to send unsolicited bulk messages. The term applies to e-mail spam and similar abuses such as instant messaging spam, mobile messaging spam, and the spamming of Web sites and Internet forums. An example, for purposes of illustration, would be the use of email in denial-of-service attacks;
* Phishing: The use of counterfeit Web pages that are designed to trick recipients into divulging sensitive data such as usernames, passwords, or financial data;
* Pharming: The redirecting of unknowing users to fraudulent sites or services, typically through DNS hijacking or poisoning;
* Willful distribution of malware: The dissemination of software designed to infiltrate or damage a computer system without the ownerʹs informed consent.
Examples include, without limitation, computer viruses, worms, keyloggers, and trojan horses;
* Botnet command and control: Services run on a domain name that are used to control a collection of compromised computers or ʺzombies,ʺ or to direct denial-of-service attacks (DDoS attacks);
* Distribution of child pornography; and
* Illegal Access to Other Computers or Networks: Illegally accessing computers, accounts, or networks belonging to another party, or attempting to penetrate security measures of another individualʹs system (often known as ʺhackingʺ). Also, any activity that might be used as a precursor to an attempted system penetration (e.g., port scan, stealth scan, or other information gathering activity).

“Abuse” or “abusive use” of a .MLS domain name by any entity under contract or license to CREA regarding use of the mark “MLS” also includes material violation or material breach of a material provision of such contract or license pertaining to licensed use of the “MLS” mark. This allows CREA, as owner of the MLS® trademarks, to adopt, address, evolve and enforce current and additional policies in place to prevent or mitigate any abusive use of the MLS® brand, including within the .MLS gTLD. CREA provides all licensees of the MLS® trademark with clearly defined policies regarding use of the MLS® mark, and any use of a .MLS domain by such party in violation of such policies may be considered an abuse under the Plan and addressed appropriately.

The Plan also includes reservation of the right on CREA’s part to deny, cancel or transfer any registration or transaction, or place any domain name(s) on registry lock, hold or similar status, that CREA deems necessary: (1) to protect the integrity and stability of .MLS; (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 CREA’s part, as well as affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement or (5) to correct mistakes made by CREA or any registrar in connection with a domain name registration. CREA also reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a complaint.

CREA acknowledges that it is not capable of making final determinations of matters which are appropriately determined in other fora, such as determination of guilt on a criminal matter, determination of child pornography, or determination of other illegality. As such, with regard to any abuse claim made under color or rule of law, statute or code of any jurisdiction, CREA will most likely defer final determination on any such claim to an appropriate tribunal in an appropriate jurisdiction. However, as set forth above, CREA also reserves the right to lock, suspend, place on hold (or similar status), any domain which is the subject of an abuse claim while the substance of the claim is pending adjudication or otherwise final determination by the appropriate tribunal in the appropriate jurisdiction.

The Plan also includes procedures that will effectively minimize potential for abuse in the .MLS gTLD, as set forth more completely below. 

The Plan is aimed at illegal and abusive use of domains, and is not intended as a substitute, replacement, circumvention or alternative venue for complaints, matters and issues more appropriately addressed by trademark rights protection mechanisms set forth in response to Question 29, such as, for example, the UDRP, URS, Sunrise Period and the Trademark Clearinghouse, or the PDDRP as set forth in Question 29.

1.2 Policies for Handling Complaints Regarding Abuse

Abuse complaints may be submitted to the Abuse Prevention Manager by email (likely to be “abuse” (at) RegistryOperatorWebsite.MLS or similar) or by written mail to: Attention: Abuse Prevention Manager ⁄ The Canadian Real Estate Association, 200 Catherine Street, 6th floor, Ottawa ON, K2P 2K9 or other address as identified on .MLS’s registry website. This will allow the complaint to be formally recognized and processed.

A complaint should include: the .MLS domain name at issue; the nature of the alleged abuse; the date(s) the abuse allegedly occurred; any materials the claimant may have illustrating the abuse (for example, spam email, screen shots, etc.); any authority the complainant may have with regard to the claim (for example, if the complainant is with law enforcement or a member of CREA, etc.); and the claimant’s contact information, including a preferred method of contact (such as email).

Complaints must be submitted in English or French. In the event a complainant is not capable of submitting a complaint in English or French, or is otherwise incapable of communicating in English or French, CREA will take commercially reasonable efforts to accommodate the complainant and determine an effective means of communication, but makes no guarantee that any complaint will be processed in any language outside of English or French.

Commercially reasonable attempts will be made to respond to the complainant via the method of communication identified in the complaint (e.g., by email or written mail; by phone if requested and reasonable). If the complaint contains no contact information, or incomplete contact information that does not allow a response, the complaint will be dismissed.

Once received, a complaint will be assigned a unique identifier, which will be maintained during the life cycle of the complaint and communicated to the complainant upon CREA’s first response to the complainant.

Every complaint will be initially screened to determine if it is to be substantively processed or otherwise identified as incomplete, frivolous, incomprehensible, stating a claim for which no relief can be granted, non-topical or otherwise not subject to substantive processing. CREA will endeavor to make this threshold determination within ten business days of receiving a complaint, or three business days if the complainant is a member of law enforcement.

If the complaint is deemed to be incomplete or incomprehensible, CREA will respond to the complainant asking for a complete and comprehensible complaint, and will cease processing the complaint until a complete and comprehensible complaint is received. If the complaint is deemed frivolous, CREA will reply that the complaint is frivolous and invite the complainant to justify why the complaint is not frivolous; if the complainant cannot overcome this burden, the complaint will be dismissed. If the complaint is non-topical or makes claim for which no relief can be granted under .MLS’s Abuse Prevention and Mitigation Plan, CREA will respond accordingly and invite the claimant to respond or direct the claimant to a more appropriate forum or mechanism for addressing the claimant’s complaint, such as the UDRP, other rights protection mechanisms as set forth in the answer to Question 29, civil litigation in an appropriate forum, or referral to law enforcement. In either even, CREA will cease processing such a complaint until a response is received from the complainant. If a review of the complaint determines that the complaint cannot be substantively processed for any other reason, CREA will respond to the complainant accordingly and processing of the complaint will cease until a response is received from complainant.

In the event CREA’s initial screening determines that the complaint is complete, non-frivolous, comprehensible, states a claim for which relief can be granted, topical and otherwise capable of substantive processing by CREA, CREA will substantively process the complaint. CREA will establish and follow a variety of methods for tracking claimed abuse and for addressing the nature of the alleged abuse. These methods may include, but not be limited to, law enforcement, engaging security vendors, internal investigations, engaging our back-end provider (Verisign) and employing Verisign’s resources regarding abuse detection⁄prevention, engaging the registrar of record, and any other industry-standard mechanisms for addressing domain abuse. Complaint processing, analysis and resource allocation will be on a case-by-case basis as needed for each complaint.

In the event CREA initiates substantive processing of a complaint, CREA will inform the registrant of record, the registrar of record and the complainant of such initiation, and will submit requests for information, comment or feedback as required on a case-by-case basis for each complaint. The registrant of record will be contacted via the WHOIS information associated with the registration. CREA will work with the registrar of record to determine the nature of the alleged abuse, and the necessary and appropriate steps to address same. CREA will contact the registrar of record by phone, email or other method as identified in the agreement between CREA and the registrar.

CREA acknowledges that the registrar of record may initiate its own abuse investigation, at which point CREA will process the complaint in parallel with the registrar. Again, CREA will work with the registrar of record with regard to contacting the registrant (if the registrar wishes to be the point of contact with the registrant) and processing the complaint.

During CREA’s processing of a complaint, CREA may elect to suspend, lock, or otherwise place the domain at issue on hold pending resolution of the complaint. The registrant of record will be sent notice via contact information in the WHOIS that the domain will be suspended, locked or otherwise placed on hold pending resolution of the complaint. If the registrant of record chooses to respond, CREA will consider their response and may release the suspension, lock or hold if appropriate. CREA is committed to a fair and impartial process for addressing abuse complaints, and will endeavor to ensure that mistakes in processing or suspending⁄locking⁄holding do not occur, but CREA recognizes that rarely false-positive suspension may occur. In this event, CREA notes that the domain at issue will not be deleted (until potentially completion of complaint processing), which will allow for quick correction of the suspension⁄lock⁄hold in the rare case of a false-positive. In any event, CREA will comply with any appropriate court or tribunal order directed to CREA to release a suspended⁄locked⁄on-hold domain if complainant provides such to CREA.

After processing of a complaint, CREA may approve or deny the claim, make comments on the claim, conditionally approve the claim, suspend the claim pending further action, and may take any action set forth herein (such as, for example, cancelling or transferring the domain at issue). In matters in which the ultimate determination as to whether the substance of a claim is illegal or otherwise more appropriately determined by a court or tribunal in other fora, CREA may delay final processing of a claim, pending resolution and⁄or direction in the matter from such court or tribunal.

CREA will notify the claimant, the registrant of record and the registrar of record of CREA’ final determination regarding the complaint and any actions CREA may take⁄have taken in regard to the matter. The registrant (or entity claimed to have abusively acted) or the claimant may, within ten business days of CREA sending out such notice, inform CREA that such entity wishes CREA to reconsider its decision. Such reconsideration request should be submitted to the Abuse Prevention Manager in the same manner as the complaint was submitted, or otherwise as provided in the notice of CREA’ decision. Any reconsideration request must address why reconsideration should be considered, and should identify any new information which was not considered by CREA in CREA’ final decision, and which would be considered material enough to justify a reversal of CREA’ determination. If the reconsideration request contains such material new information, CREA may decide to reopen processing of the complaint, and would then notify the complainant, the registrant, the registrar and any other interested parties of such reopening. If the reconsideration request fails to contain any material new information, or if CREA determines that the material new information provided is not sufficient for CREA to change its position, CREA will deny the reconsideration request. At that point CREA will cease processing the claim, but will still respond to appropriate court or tribunal orders directed to CREA regarding the matter.

In the event a complainant identifies themselves as a member of law enforcement investigating a potential illegal activity, CREA will endeavor to initially respond to such a complaint within twenty four hours, but in no event less than seventy-two hours, and may respond sooner if the complaint requests a quicker turnaround and provides an adequate reason for needing a quicker turnaround. CREA is committed to working with law enforcement relating to abusive actions in the .MLS gTLD, and will put forth commercially reasonable efforts to communicate with law enforcement, accommodate law enforcement requests and generally work with law enforcement towards expedited processing of a complaint.

CREA is a trade association with a principle place of business at 200 Catherine Street, 6th Floor, Ottawa ON, K2P 2K9, and is subject to federal Canadian law. In the event we receive a court or tribunal order for any reason, we will review the order to determine its reasonableness and the extent to which the issuing court or tribunal has authority over CREA or any party implicated in a complaint. CREA may consult with outside legal counsel in such a review. If CREA elects to respond or take action pursuant to the order, CREA will endeavor to do so within any time frame set forth in the order, so long as practicable. 

Special note should be made of complaints arising from matters relating to abuse or misuse of CREA’s policies and usage guidelines relating to use of the MLS brand and CREA’s policies governing use of the .MLS gTLD (collectively, “CREA Policies”). In complaints relating to CREA Policies, CREA may choose to invoke any of its own policies or procedures developed to address abuses or violations of CREA Policies. As previously stated, CREA is committed to the fair and impartial implementation of the Plan.

CREA is committed to preventing and mitigating abuse in the .MLS gTLD, and will comply with all terms regarding such in the final version of the Registry Agreement and all consensus policies relating to such. Working with its registrars, CREA will remain flexible on the Plan and its implementation policies⁄procedures to address future and unconventional abuses which are not currently known, and looks forward to working with other gTLD registry operators and ICANN in determining industry standard abuse prevention and mitigation plans, policies and procedures.

1.3 Proposed Measures for Removal of Orphan Glue Records

Although orphan glue records often support correct and ordinary operation of the Domain Name System (DNS), registry operators will be required to remove orphan glue records (as defined at http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf) when provided with evidence in written form that such records are present in connection with malicious conduct. CREA’s selected backend registry services provider’s (Verisign’s) registration system is specifically designed to not allow orphan glue records. Registrars are required to delete⁄move all dependent DNS records before they are allowed to delete the parent domain.

To prevent orphan glue records, Verisign performs the following checks before removing a domain or name server: 

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

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

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

1.4 Resourcing Plans

Details related to resourcing plans for the initial implementation and ongoing maintenance of CREA’s abuse plan are provided in Section 2 of this response. 

1.5 Measures to Promote Whois Accuracy

1.5.1 Authentication of Registrant Information 

The .MLS gTLD will initially be made available to CREA’s member Boards and Foreign Affiliate members. After undertaking any required assessments, CREA may enter into a second phase where the gTLD would be made available to broker and salespeople members of CREA.

Each application will be manually reviewed to determine if the applicant is a member of CREA. CREA maintains membership requirements that members must adhere to in order to be eligible to use the .MLS gTLD. In addition, the applied for second level domain will also be reviewed to determine if it would make clear to Internet users what geographical region the MLS® services or listing information on the website represents. Whois registrant information must match the information submitted for CREA’s manual review.

CREA will work with accredited registrars to ensure that required back-end functionality for facilitating CREA’s hand review is available.

1.5.2 Regular Monitoring of Registration Data for Accuracy and Completeness

CREA will periodically spot check .MLS registration data with regard to CREA members. CREA recognizes that monitoring of registration data for accuracy and completeness is an important matter to ICANN and many ICANN stakeholders. CREA will comply with all monitoring provisions in the final version of the Registry Agreement and all consensus policies relating to monitoring. CREA will work with all accredited registrars towards this goal.

Verisign, CREA’s selected backend registry services provider, has established policies and procedures to encourage registrar compliance with ICANN’s Whois accuracy requirements. Verisign provides the following services to CREA for incorporation into its full-service registry operations.

Registrar self-certification 

The self-certification program consists, in part, of evaluations applied equally to all operational ICANN accredited registrars and conducted from time to time throughout the year. Process steps are as follows:
* Verisign sends an email notification to the ICANN primary registrar contact, requesting that the contact go to a designated URL, log in with his⁄her Web ID and password, and complete and submit the online form. The contact must submit the form within 15 business days of receipt of the notification. 
* When the form is submitted, Verisign sends the registrar an automated email confirming that the form was successfully submitted.
* Verisign reviews the submitted form to ensure the certifications are compliant.
* Verisign sends the registrar an email notification if the registrar is found to be compliant in all areas. 
* If a review of the response indicates that the registrar is out of compliance or if Verisign has follow-up questions, the registrar has 10 days to respond to the inquiry.
* If the registrar does not respond within 15 business days of receiving the original notification, or if it does not respond to the request for additional information, Verisign sends the registrar a Breach Notice and gives the registrar 30 days to cure the breach.
* If the registrar does not cure the breach, Verisign terminates the Registry-Registrar Agreement (RRA). 

Whois data reminder process. Verisign regularly reminds registrars of their obligation to comply with ICANN’s Whois Data Reminder Policy, which was adopted by ICANN as a consensus policy on 27 March 2003 (http:⁄⁄www.icann.org⁄en⁄registrars⁄wdrp.htm). Verisign sends a notice to all registrars once a year reminding them of their obligation to be diligent in validating the Whois information provided during the registration process, to investigate claims of fraudulent Whois information, and to cancel domain name registrations for which Whois information is determined to be invalid. 

1.5.3 Use of Registrars

As of the submission date of this application, ICANN has not provided final guidance as to the nature and the details of the procedures which will be implemented by registrars to ensure accuracy and completeness of WHOIS data. CREA has followed and will continue to follow closely the progress of the negotiations between ICANN and the Registrar Negotiations Team (NT) regarding the revised Registrar Accreditation Agreement (RAA). CREA acknowledges the interests of law enforcement agencies (LEA), who generally are seeking greater openness, accuracy and accountability in WHOIS data. CREA also acknowledges the countervailing position of those who wish to maintain WHOIS privacy, and those (such as registrars) who wish to keep WHOIS costs down.

In the 1 March 2012 Progress Report on Negotiations on the Registrar Accreditation Agreement, ICANN notes that ICANN and the NT are currently undertaking a “comprehensive review” of the RAA and addressing twelve enumerated requests from LEA relating to WHOIS accuracy, accountability and completeness. ICANN and the NT appear to have an agreement in principle on eleven of the twelve principals, agreeing in principle on (1) guidelines for Privacy⁄Proxy Accreditation Services; (2) a gross negligence standard for knowledge in permitting criminal activity regarding WHOIS information; (3) registrar contact information; (4) public display of registrar officer information; (5) registrar ownership; (6) notice of change to registrar; (7) registrar certification; (8) registrar accountability and disclosure obligations; (10) validation of WHOIS data; (11) abuse point of contact; and (12) SLA for port 43 servers – while not having an agreement in principle on (9) registrar collection and maintenance of data on the persons initiating requests for registrations, as well as source IP addresses and financial transaction information. ICANN and the NT are also addressing approximately twenty-two other issues relating to the RAA, of which approximately half have an agreement in principle.

CREA is committed to support WHOIS accuracy and completeness procedures and policies which support the WHOIS policies and procedures which result from eventual agreement between ICANN and the NT regarding matters of WHOIS accuracy, accountability and openness as set forth in the final version of the RAA.

1.6 Controls to Ensure Proper Access to Domain Functions

To ensure proper access to domain functions, CREA incorporates Verisign’s Registry-Registrar Two-Factor Authentication Service into its full-service registry operations. The service is designed to improve domain name security and assist registrars in protecting the accounts they manage by providing another level of assurance that only authorized personnel can communicate with the registry. As part of the service, dynamic one-time passwords (OTPs) augment the user names and passwords currently used to process update, transfer, and⁄or deletion requests. These one-time passwords enable transaction processing to be based on requests that are validated both by “what users know” (i.e., their user name and password) and “what users have” (i.e., a two-factor authentication credential with a one-time-password).

Registrars can use the one-time-password when communicating directly with Verisign’s Customer Service department as well as when using the registrar portal to make manual updates, transfers, and⁄or deletion transactions. The Two-Factor Authentication Service is an optional service offered to registrars that execute the Registry-Registrar Two-Factor Authentication Service Agreement. As shown in Figure 28-1, the registrars’ authorized contacts use the OTP to enable strong authentication when they contact the registry. There is no charge for the Registry-Registrar Two-Factor Authentication Service. It is enabled only for registrars that wish to take advantage of the added security provided by the service. 

See Figure 28-1: Verisign Registry-Registrar Two-Factor Authentication Service

2. Technical plan that is adequately resourced in the planned costs detailed in the financial section

Resource Planning

During initial operation of .MLS, the Abuse Prevention Manager will be the General Counsel or a designate of the General Counsel. In processing a complaint, the Abuse Prevention Manager may seek the assistance of any of the Executive Management Personnel. The Abuse Prevention Manager may also seek the assistance of either or both Customer Support personnel and Technical Labor personnel, depending upon the nature of the complaint and the volume of complaints. The Abuse Prevention Manager may also engage the services of outside legal counsel for advice or representation if the nature of a complaint or processing the complaint requires.

Operations of the Abuse Prevention Manager will scale as needed to accommodate the volume and nature of complaints received, including shifting allocations of time from Customer Support personnel and Technical Labor personnel. In the event registration volume and related income allow, and complaint volume dictates, additional personnel may be added to accommodate the complaints, up to and including addition of a dedicated Abuse Prevention Manager with a staff commensurate to need.

Costs for CREA’s operations as detailed above are addressed in the response to Question 47. Specifically, $5,000 has been attributed to legal as part of general administrative expenses per year (see table 3 provided in response to Question 46). In addition, per the Financial Projections Template submitted in response to Question 46, $10,000 per year is budgeted under Other Operating Costs in case of unexpected contingencies, such as outside legal counsel.

Resource Planning Specific to Backend Registry Activities

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

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

Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support abuse prevention and mitigation:

* Application Engineers: 19
* Business Continuity Personnel: 3
* Customer Affairs Organization: 9
* Customer Support Personnel: 36
* Information Security Engineers: 11
* Network Administrators: 11
* Network Architects: 4
* Network Operations Center (NOC) Engineers: 33
* Project Managers: 25
* Quality Assurance Engineers: 11
* Systems Architects: 9

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

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

3. Policies and procedures identify and address the abusive use of registered names at startup and on an ongoing basis

The anti-abuse policies and procedures set forth in the answers to this Question 28 address, and are applicable, to abusive use of registered names in .MLS at both startup and on an ongoing basis.

3.1 Start-Up Anti-Abuse Policies and Procedures

CREA’s anti-abuse policies and procedures set forth above will be available as of start-up of .MLS. Further, the requirement set forth in section 1.5 above regarding submission of a unique identifier for applicants for domains will be in place for start-up.

Verisign, CREA’s selected backend registry services provider, provides the following domain name abuse prevention services, which CREA incorporates into its full-service registry operations. These services are available at the time of domain name registration.

Registry Lock. The Registry Lock Service allows registrars to offer server-level protection for their registrants’ domain names. A registry lock can be applied during the initial standup of the domain name or at any time that the registry is operational. 

Specific Extensible Provisioning Protocol (EPP) status codes are set on the domain name to prevent malicious or inadvertent modifications, deletions, and transfers. Typically, these ‘server’ level status codes can only be updated by the registry. The registrar only has ‘client’ level codes and cannot alter ‘server’ level status codes. The registrant must provide a pass phrase to the registry before any updates are made to the domain name. However, with Registry Lock, provided via Verisign, CREA’s subcontractor, registrars can also take advantage of server status codes.

The following EPP server status codes are applicable for domain names: (i) serverUpdateProhibited, (ii) serverDeleteProhibited, and (iii) serverTransferProhibited. These statuses may be applied individually or in combination.

The EPP also enables setting host (i.e., name server) status codes to prevent deleting or renaming a host or modifying its IP addresses. Setting host status codes at the registry reduces the risk of inadvertent disruption of DNS resolution for domain names.

The Registry Lock Service is used in conjunction with a registrar’s proprietary security measures to bring a greater level of security to registrants’ domain names and help mitigate potential for unintended deletions, transfers, and⁄or updates.

Two components comprise the Registry Lock Service:
* CREA and⁄or its registrars provides Verisign, CREA’s selected provider of backend registry services, with a list of the domain names to be placed on the server status codes. During the term of the service agreement, the registrar can add domain names to be placed on the server status codes and⁄or remove domain names currently placed on the server status codes. Verisign then manually authenticates that the registrar submitting the list of domain names is the registrar-of-record for such domain names.
* If CREA and⁄or its registrars requires changes (including updates, deletes, and transfers) to a domain name placed on a server status code, Verisign follows a secure, authenticated process to perform the change. This process includes a request from a CREA-authorized representative for Verisign to remove the specific registry status code, validation of the authorized individual by Verisign, removal of the specified server status code, registrar completion of the desired change, and a request from the CREA-authorized individual to reinstate the server status code on the domain name. This process is designed to complement automated transaction processing through the Shared Registration System (SRS) by using independent authentication by trusted registry experts. 

CREA intends to charge registrars based on the market value of the Registry Lock Service. A tiered pricing model is expected, with each tier having an annual fee based on per domain name⁄host and the number of domain names and hosts to be placed on Registry Lock server status code(s). 

3.2 Ongoing Anti-Abuse Policies and Procedures

CREA’ anti-abuse policies and procedures set forth in the answers to this Question 28 will be available on an on-going basis for .MLS. Further, the requirement set forth in section 1.5 above regarding submission of a unique identifier also will apply on an ongoing basis.

3.2.1 Policies and Procedures That Identify Malicious or Abusive Behavior

Verisign, CREA’s selected backend registry services provider, provides the following service to CREA for incorporation into its full-service registry operations.

Malware scanning service. Registrants are often unknowing victims of malware exploits. Verisign has developed proprietary code to help identify malware in the zones it manages, which in turn helps registrars by identifying malicious code hidden in their domain names. 

Verisign’s malware scanning service helps prevent websites from infecting other websites by scanning web pages for embedded malicious content that will infect visitors’ websites. Verisign’s malware scanning technology uses a combination of in-depth malware behavioral analysis, anti-virus results, detailed malware patterns, and network analysis to discover known exploits for the particular scanned zone. If malware is detected, the service sends the registrar a report that contains the number of malicious domains found and details about malicious content within its TLD zones. Reports with remediation instructions are provided to help registrars and registrants eliminate the identified malware from the registrant’s website. 

3.2.2 Policies and Procedures That Address the Abusive Use of Registered Names

Suspension processes conducted by backend registry services provider. In the case of domain name abuse, CREA will determine whether to take down the subject domain name as set forth in Section 1 of the answer to this Question 28. Verisign, CREA’s selected backend registry services provider, will follow the following auditable processes to comply with the suspension request.

See Figure 28-2: Suspension Procedure.

Verisign Suspension Notification. CREA submits the suspension request to Verisign for processing, documented by:
* Threat domain name
* Registry incident number 
* Incident CREArative, threat analytics, screen shots to depict abuse, and⁄or other evidence
* Threat classification 
* Threat urgency description
* Recommended timeframe for suspension⁄takedown 
* Technical details (e.g., Whois records, IP addresses, hash values, anti-virus detection results⁄nomenclature, name servers, domain name statuses that are relevant to the suspension) 
* Incident response, including surge capacity 

Verisign Notification Verification. When Verisign receives a suspension request from CREA, it performs the following verification procedures:
* Validate that all the required data appears in the notification.
* Validate that the request for suspension is for a registered domain name.
* Return a case number for tracking purposes.

Suspension Rejection. If required data is missing from the suspension request, or the domain name is not registered, the request will be rejected and returned to CREA with the following information:

* Threat domain name
* Registry incident number 
* Verisign case number
* Error reason

Registrar Notification. Once Verisign has performed the domain name suspension, and upon CREA request, Verisign notifies the registrar of the suspension. If CREA does not request that Verisign notify the registrar, CREA will notify the registrar. Registrar notification includes the following information:

* Threat domain name
* Registry incident number 
* Verisign case number 
* Classification of type of domain name abuse
* Evidence of abuse
* Anti-abuse contact name and number
* Suspension status
* Date⁄time of domain name suspension

Registrant Notification. Once Verisign has performed the domain name suspension, and upon CREA request, Verisign notifies the registrant of the suspension. If CREA does not request that Verisign notify the registrant, CREA will notify the registrant. Registrant notification includes the following information:

* Threat domain name
* Registry incident number 
* Verisign case number 
* Classification of type of domain name abuse
* Evidence of abuse
* Registrar anti-abuse contact name and number

Domain Suspension. Verisign places the domain to be suspended on the following statuses:

* serverUpdateProhibited 
* serverDeleteProhibited
* serverTransferProhibited
* serverHold 

Suspension Acknowledgement. Verisign notifies CREA that the suspension has been completed. Acknowledgement of the suspension includes the following information:

* Threat domain name
* Registry incident number 
* Verisign case number 
* Case number
* Domain name
* CREA abuse contact name and number, or registrar abuse contact name and number
* Suspension status

4. When executed in accordance with the Registry Agreement, plans will result in compliance with contractual requirements

It is CREA’s good faith belief that the plans and procedures set forth herein, when executed, will place .MLS in compliance with the contractual requirements set forth in the Registry Agreement. As a final version of the Registry Agreement has not been provided, CREA is committed to being in compliance with all abuse-prevention terms and obligations set forth in the final version of the Registry Agreement, and will amend and augment any and all anti-abuse plans and procedures set forth herein to be in compliance with the terms and obligations regarding anti-abuse plans and procedures set forth in the final version of the Registry Agreement and any Consensus Policies relating to abuse prevention and mitigation.

5. Technical plan scope⁄scale that is consistent with the overall business approach and planned size of the registry

Scope⁄Scale Consistency

CREA’ anti-abuse plans and procedures set forth herein are consistent with the technical, operational and financial approach and details set forth in other parts of this application, and other answers to the Questions therein. As detailed in answers to Question 47, CREA has allocated more than adequate levels of resources on hand and committed to enable full functionality of the plan and procedures, and CREA’ experienced management team and new hires, along with the resources of CREA and Verisign, are more than capable of successfully carrying out the functions set forth herein.

Scope⁄Scale Consistency Specific to Backend Registry Activities

Verisign, CREA’s selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies. 

Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the .MLS gTLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely sceCREAio (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to CREA fully accounts for cost related to this infrastructure, which is provided as “Other Operating Cost” (Template 1, Line I.L) within the Question 46 financial projections response.

1. Mechanisms Designed to Prevent abusive registrations

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

As described in this response, CREA will implement a Sunrise period and Trademark Claims service with respect to the registration of domain names within the .MLS gTLD. Certain aspects of the Sunrise period and⁄or Trademark Claims service may be administered on behalf of CREA by CREA-approved registrars or by subcontractors of CREA, such as its selected backend registry services provider, Verisign. CREA will also use, as detailed in the answer to Question 18, eligibility requirements which will also provide rights protection. Most rights protection aspects of the eligibility requirements will be performed internally by CREA, with enactment (for example, suspension or transfer) by CREA.

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

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

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

During the Sunrise period, CREA and⁄or CREA-approved registrars, as applicable, are responsible for determining whether each domain name is eligible to be registered (including in accordance with the SERs).

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

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

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

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

Eligibility Restrictions. As set forth in the answer to Question 18, the .MLS gTLD will initially be made available to CREA’s member Boards and Foreign Affiliate members. After undertaking any required assessments, CREA may enter into a second phase where the gTLD would be made available to broker and salespeople members of CREA.

As also set forth in the answer to Question 18, each application will be manually reviewed to determine if the applicant is a member of CREA. CREA maintains membership requirements that members must adhere to in order to be eligible to use the .MLS gTLD. In addition, the applied for second level domain will also be reviewed to determine if it would make clear to Internet users what geographical region the MLS® services or listing information on the website represents. As set forth in the answer to Question 28, Whois registrant information must match the information submitted for CREA’s manual review, and CREA will work with accredited registrars to ensure that required back-end functionality for facilitating CREA’s hand review is available.

CREA promulgates policies regarding use of its MLS® trademark with which all members need comply. Trademark infringement uses are not allowed. CREA has internal policies, procedures, guidelines and personnel to address claims of abuse or violation of these guidelines.

2. Mechanisms Designed to Identify and address the abusive use of registered CREA names on an ongoing basis

In addition to the Sunrise and Trademark Claims services described in Section 1 of this response, CREA implements and adheres to RPMs post-launch as mandated by ICANN, and confirms that registrars accredited for the .MLS gTLD are in compliance with these mechanisms. Certain aspects of these post-launch RPMs may be administered on behalf of CREA by CREA-approved registrars or by subcontractors of CREA, such as its selected backend registry services provider, Verisign. 

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

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

The following descriptions provide implementation details of each post-launch RPM for the .MLS gTLD: 

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

Additional Measures Specific to Rights Protection. CREA provides additional measures against potentially abusive registrations. These measures help mitigate phishing, pharming, and other Internet security threats. The measures exceed the minimum requirements for RPMs defined by Specification 7 of the Registry Agreement and are available at the time of registration. These measures include:

* Rapid Takedown or Suspension Based on Court Orders: CREA complies promptly with any order from a court of competent jurisdiction that directs it to take any action on a domain name that is within its technical capabilities as a TLD registry. These orders may be issued when abusive content, such as child pornography, counterfeit goods, or illegal pharmaceuticals, is associated with the domain name.
* Anti-Abuse Process: CREA implements an anti-abuse process that is executed on domain name takedown requests. The scope of the anti-abuse process includes malicious exploitation of the DNS infrastructure, such as phishing, botnets, and malware. 
* Authentication Procedures: Verisign, CREA’s selected backend registry services provider, uses two-factor authentication to augment security protocols for telephone, email, and chat communications.
* Registry Lock: This Verisign service allows registrants to lock a domain name at the registry level to protect against both unintended and malicious changes, deletions, and transfers. Only Verisign, as CREA’s backend registry services provider, can release the lock; thus all other entities that normally are permitted to update Shared Registration System (SRS) records are prevented from doing so. This lock is released only after the registrar makes the request to unlock.
* Malware Code Identification: This safeguard reduces opportunities for abusive behaviors that use registered domain names in the gTLD. Registrants are often unknowing victims of malware exploits. As CREA’s backend registry services provider, Verisign has developed proprietary code to help identify malware in the zones it manages, which in turn helps registrars by identifying malicious code hidden in their domain names.
* DNSSEC Signing Service: Domain Name System Security Extensions (DNSSEC) helps mitigate pharming attacks that use cache poisoning to redirect unsuspecting users to fraudulent websites or addresses. It uses public key cryptography to digitally sign DNS data when it comes into the system and then validate it at its destination. The .MLS gTLD is DNSSEC-enabled as part of Verisign’s core backend registry services. 

3. Resourcing Plans

Resource Planning

Resourcing plans for the initial implementation of, and ongoing maintenance for, the rights protection mechanisms in Part 1 of the answer to this Question 29, except for those relating to eligibility requirements, are set forth in the answer to Question 49(a) – contingency planning (detailed further below). As ICANN has not issued final guidance with regard to the Trademark Clearinghouse, and particularly the costs associated with the Clearinghouse, subcontractors and backend providers, such as Verisign, have not been able to quote costs and resource allocations for implementation of the Clearinghouse and other RPMs which incorporate the Clearinghouse. CREA will determine which entity(ies) will provide which services, and allocate costs and resources accordingly, once ICANN has determined a Clearinghouse cost and CREA can determine subcontractor⁄Verisign pricing and availability. In any event, CREA has a firm commitment from Verisign that, at minimum, Verisign will work with CREA to provide all the necessary resources and services to implement and maintain the RPMs contemplated in this answer, and as set forth in Question 49(a), CREA has allocated sufficient committed resources to ensure sufficient resources to cover Verisign’s (or other subcontractor’s) costs.

CREA internal operations for all RPMs will scale as needed to accommodate the volume and nature of all matters not handled by Verisign or subcontractors, including shifting allocations of time from the management team, General Counsel, Customer Support personnel and Technical Labor personnel. In the event registration volume and related income allow, and RPM matter volume dictates, additional personnel may be added to accommodate the matters, up to and including addition of a dedicated RPM Manager with a staff commensurate to need.

Costs for CREA’s operations as detailed above are addressed in the response to Question 47. Specifically, $5,000 has been attributed to legal as part of general administrative expenses per year (see table 3 provided in response to Question 46). In addition, per the Financial Projections Template submitted in response to Question 46, $10,000 per year is budgeted under Other Operating Costs in case of unexpected contingencies, such as the use of outside legal counsel.

With regard to operation of RPMs relating to eligibility requirements, CREA has an experienced management team, compliance team and legal team for overseeing use of their MLS mark and the activities of Boards and members with regard to the MLS mark. With regard to eligibility requirement complaints or other complaints which relate to rights protection which may violate any CREA policy, CREA has established internal procedures for addressing such claims. The procedures involve input from management, compliance and legal, and legal regularly consults with outside legal counsel. CREA has sufficient resources and personnel to provide the compliance services attributed to CREA herein.

Resource Planning Specific to Backend Registry Activities

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

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

Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support the implementation of RPMs:

* Customer Affairs Organization: 9
* Customer Support Personnel: 36
* Information Security Engineers: 11 

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

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

1 DETAILED DESCRIPTION OF PROCESSES AND SOLUTIONS DEPLOYED TO MANAGE LOGICAL SECURITY ACROSS INFRASTRUCTURE AND SYSTEMS, MONITORING AND DETECTING THREATS AND SECURITY VULNERABILITIES AND TAKING APPROPRIATE STEPS TO RESOLVE THEM

The Canadian Real Estate Association’s (CREA) selected backend registry services provider’s (Verisign’s) comprehensive security policy has evolved over the years as part of managing some of the world’s most critical TLDs. Verisign’s Information Security Policy is the primary guideline that sets the baseline for all other policies, procedures, and standards that Verisign follows. This security policy addresses all of the critical components for the management of backend registry services, including architecture, engineering, and operations. 

Verisign’s general security policies and standards with respect to these areas are provided as follows:

* Architecture

Information Security Architecture Standard: This standard establishes the Verisign standard for application and network architecture. The document explains the methods for segmenting application tiers, using authentication mechanisms, and implementing application functions.

Information Security Secure Linux Standard: This standard establishes the information security requirements for all systems that run Linux throughout the Verisign organization.

Information Security Secure Oracle Standard: This standard establishes the information security requirements for all systems that run Oracle throughout the Verisign organization.

Information Security Remote Access Standard: This standard establishes the information security requirements for remote access to terminal services throughout the Verisign organization.

Information Security SSH Standard: This standard establishes the information security requirements for the application of Secure Shell (SSH) on all systems throughout the Verisign organization.

* Engineering

Secure SSL⁄TLS Configuration Standard: This standard establishes the information security requirements for the configuration of Secure Sockets Layer⁄Transport Layer Security (SSL⁄TLS) for all systems throughout the Verisign organization.

Information Security C++ Standards: These standards explain how to use and implement the functions and application programming interfaces (APIs) within C++. The document also describes how to perform logging, authentication, and database connectivity.

Information Security Java Standards: These standards explain how to use and implement the functions and APIs within Java. The document also describes how to perform logging, authentication, and database connectivity.

* Operations

Information Security DNS Standard: This standard establishes the information security requirements for all systems that run DNS systems throughout the Verisign organization.

Information Security Cryptographic Key Management Standard: This standard provides detailed information on both technology and processes for the use of encryption on Verisign information security systems.

Secure Apache Standard: Verisign has a multitude of Apache web servers, which are used in both production and development environments on the Verisign intranet and on the Internet. They provide a centralized, dynamic, and extensible interface to various other systems that deliver information to the end user. Because of their exposure and the confidential nature of the data that these systems host, adequate security measures must be in place. The Secure Apache Standard establishes the information security requirements for all systems that run Apache web servers throughout the Verisign organization.

Secure Sendmail Standard: Verisign uses sendmail servers in both the production and development environments on the Verisign intranet and on the Internet. Sendmail allows users to communicate with one another via email. The Secure Sendmail Standard establishes the information security requirements for all systems that run sendmail servers throughout the Verisign organization.

Secure Logging Standard: This standard establishes the information security logging requirements for all systems and applications throughout the Verisign organization. Where specific standards documents have been created for operating systems or applications, the logging standards have been detailed. This document covers all technologies.

Patch Management Standard: This standard establishes the information security patch and upgrade management requirements for all systems and applications throughout Verisign.

* General

Secure Password Standard: Because passwords are the most popular and, in many cases, the sole mechanism for authenticating a user to a system, great care must be taken to help ensure that passwords are “strong” and secure. The Secure Password Standard details requirements for the use and implementation of passwords.

Secure Anti-Virus Standard: Verisign must be protected continuously from computer viruses and other forms of malicious code. These threats can cause significant damage to the overall operation and security of the Verisign network. The Secure Anti-Virus Standard describes the requirements for minimizing the occurrence and impact of these incidents.

Security processes and solutions for the .MLS TLD are based on the standards defined above, each of which is derived from Verisign’s experience and industry best practice. These standards comprise the framework for the overall security solution and applicable processes implemented across all products under Verisign’s management. The security solution and applicable processes include, but are not limited to:

* System and network access control (e.g., monitoring, logging, and backup) 
* Independent assessment and periodic independent assessment reports
* Denial of service (DoS) and distributed denial of service (DDoS) attack mitigation
* Computer and network incident response policies, plans, and processes
* Minimization of risk of unauthorized access to systems or tampering with registry data
* Intrusion detection mechanisms, threat analysis, defenses, and updates 
* Auditing of network access
* Physical security

Further details of these processes and solutions are provided in Part B of this response.

1.1 Security Policy and Procedures for the Proposed Registry

Specific security policy related details, requested as the bulleted items of Question 30 – Part A, are provided here. 

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

Figure 30A-1: See attached

Augmented Security Levels or Capabilities. See Section 5 of this response. 

Commitments Made to Registrants Concerning Security Levels. See Section 4 of this response.

2 SECURITY CAPABILITIES ARE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY

Verisign, CREA’s selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies. 

Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the .MLS gTLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to CREA fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.

3 TECHNICAL PLAN ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION

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

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

Verisign projects it will use the following personnel role, which is described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support its security policy:

* Information Security Engineers: 11

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

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

4 SECURITY MEASURES ARE CONSISTENT WITH ANY COMMITMENTS MADE TO REGISTRANTS REGARDING SECURITY LEVELS

Verisign is CREA’s selected backend registry services provider. For the .MLS gTLD, no unique security measures or commitments must be made by Verisign or CREA to any registrant.

5 SECURITY MEASURES ARE APPROPRIATE FOR THE APPLIED-FOR gTLD STRING (FOR EXAMPLE, APPLICATIONS FOR STRINGS WITH UNIQUE TRUST IMPLICATIONS, SUCH AS FINANCIAL SERVICES-ORIENTED STRINGS, WOULD BE EXPECTED TO PROVIDE A COMMENSURATE LEVEL OF SECURITY)

No unique security measures are necessary to implement the .MLS gTLD. As defined in Section 1 of this response, Verisign, CREA’s selected backend registry services provider, commits to providing backend registry services in accordance with the following international and relevant security standards:

* American Institute of Certified Public Accountants (AICPA) and Canadian Institute of Chartered Accountants (CICA) SAS 70 
* WebTrust⁄SysTrust for Certification Authorities (CA)