Application number: 1-1950-81778 for INFIBEAM INCORPORATION LIMITED

INFIBEAM INCORPORATION LIMITED

9th Floor, A-Wing
Gopal Palace, NehruNagar
Ahmedabad Gujarat 380015
IN

+91 79 402 602 60

+91 79 264 403 59

http:⁄⁄www.infibeam.com

Mr. Vishal A. Mehta

CEO

+91 96 012 809 02

+91 79 264 403 59

vishal@infibeam.net

Mr. Vijayakumar Subramanian

CIO

+91 9620912244

+91 79 264 403 59

vijaysub@infibeam.net

Limited Company

Infibeam Incorporation Limited is incorporated under the Companies Act, 1956, India.

Not Available

Ajit C. Mehta
Chairman
Jayshree A. Mehta
Member
Malav A. Mehta
Member
Vishal A. Mehta
Member

Ajay Chandra
CTO
Manu Midha
VP (Planning & Strategy)
Sachin Oswal
COO
Vijayakumar Subramanian
CIO
Vishal A. Mehta
CEO

ooo

Not Available

We conducted extensive research on specialized websites and on generic search tools first. Our experts (computer engineers) have evaluated the string to conclude that there was no operational or rendering problem. We contacted outside experts who reached the same conclusion. Hence there are no known operational or rendering problems concerning the applied-for gTLD string.

Our goal is nothing less than providing a billion stores for a billion people. With the .ooo gTLD we intend to expand, on a global scale, the valued service we already provide to brick-and-mortar retailers, specifically delivering a dedicated online platform to market their goods and services. Our offering won’t only extend to those currently running physical retail spaces, however, as the .ooo gTLD easily could be used for any entity launching or expanding an e-commerce venture.

 Our current platform, BuildaBazaar.com, facilitates online platforms for thousands of Indian retailers large and small, lowering the barriers to entry which had prevented small businessmen from transitioning their companies online. It is not uncommon, however, for some retailers to resist operating under a generic builabazaar.com domain name. Doing so can create a perception among consumers that the retailer is not an autonomous entity. This new gTLD would permit each retailer to have their own personalized website at the address of their choice. This would increase their brand recognition while making the independence of their operation transparent.

While the current system is limited to retailers in India, the adoption of a gTLD would permit retailers across the globe to operate from a trusted and secure online platform.
By providing new outlets for brick-and-mortar retailers to sell their goods and services online, those retailers would gain new business and more readily remain in operation, but the real winners would be Internet users. The adoption of the gTLD by global retailers will dramatically increase consumer choice across a limitless range of goods and services, in a safe and trusted environment. Our policies will ensure that the gTLD will be synonymous in an online consumerʹs mind with choice and trust. You can learn more about the steps we will take regarding choice and trust below.
Infibeam is well suited to manage this gTLD, because it is a leader in e-commerce - a rapidly growing company based in Ahmedabad, India, serving one of the most populous nations on the globe. Since 2007, Infibeam.com has been a one-stop online outlet for apparel; beauty supplies; books; health goods; jewelry; technology; toys; and many other goods. In 2011 it empowered brick-and-mortar retailers by offering them access to Internet users via the BuildaBazaar.com platform. Retailers operating BuildaBazaar.com websites include apparel stores, bookstores, electronics outlets, jewelry retailers, and other consumer and business needs. The company is well-loved by its customers, with over 900,000 fans on Facebook. Infibeam was named a Top 5 Digital Brand in September 2010 in a survey conducted by the Economic Times.

As we have seen with the success of BuildaBazaar.com, brick-and-mortar retailers benefit when they can expand their sales to millions of online customers. The Internet is a magnificent medium for e-commerce, as the success of infibeam.com attests. This new gTLD will expand this impact, as with it, registrants can compete for online sales with any e-commerce outlet while ensuring their continued physical presence in their communities.

As the gTLD is adopted by more retailers, Internet users benefit directly through an increase in choice, and a concurrent increase in competition for their business. The Internet as a whole will expand due to an increase in the number of trusted sites providing privacy and security for consumers.

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

Any conceivable product or service available in e-commerce form would be suitable for this proposed gTLD. We anticipate that initial adoption patterns would follow what we have seen with the growth of BuildaBazaar.com sites. Popular items such as books, beauty supplies, apparel, jewelry and other common consumer goods would be among the first to be offered by gTLD registrants. 

Given that the gTLD permits a smooth and easy extension of brick-and-mortar retail operations to the Internet, it is perhaps easiest to imagine your favorite physical area of commerce, and mentally project those retail options online. Infibeam takes pride in its superlative customer service to its infibeam.com customers, as well as its service to BuildaBazaar.com retailers. Those retailers, meanwhile, uphold the highest standards of customer service for their own customers. The same approach would apply for gTLD registrants and their customers.

Due to the standards that will be applied in permitting gTLD registration, the gTLD will become synonymous with trust and consumer choice, ensuring a solid reputation among Internet consumers, as well as retailers. 

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

The positive impact this new gTLD will bring to the Internet cannot be understated:

Competition:

As stated above, the proposed gTLD will increase competition in the e-commerce space by virtualizing brick-and-mortar stores. It will increase the reach of all specialty stores to an always growing customer base, while allowing small stores to generate extra profit from online sales. Local goods will be made readily available to an unlimited number of Internet users. 

True competition will also emerge, however, among TLDs. As stated above, BuildaBazaar.com retailers currently have to market themselves online with a .COM domain, with build a bazaar as part of their second-level designation. The launch of e-commerce options under this new gTLD will provide direct competition to .COM. In fact, the new gTLD will increase competition to any TLD that includes e-commerce providers among its registrants.

Differentiation:

As with increased competition, the new gTLD will permit retailers to differentiate themselves and their offerings from other retailers. Unique product offerings reflecting differing cultures, geographic regions, and local traditions will be readily available in the virtual marketplace, side by side with more traditional offerings currently found online. The gTLD will act as an enabler, handing over unique web identities to many retailers. We will facilitate the entire process, as we are doing now with great success. Differentiation in the e-commerce market will increase due to the simplicity with which individuals can set up their own stores. Individuals will be able to compete with the major players, as they design their own websites. Their ideas will act as catalyst for the web as a whole and e-commerce specifically.

Along those lines, increased differentiation in the e-commerce space--facilitated by the domains issued under the new gTLD--will lead to increased differentiation across the TLD landscape.
Innovation:

Infibeam.com is a leader in innovation, from online retailing to the development of electronic devices such as the Pi ebook reader. That innovation is reflected in BuildaBazaar.com, a user-friendly way to marry brick-and-mortar stores to the Internet. As the operator of this new gTLD, Infibeam.com will continue to innovate to serve its registrants.

It must be noted, however, that innovation is not limited to large technology companies such as Infibeam.com. As we have seen with our BuildaBazaar.com retailers, innovative thinking abounds among retailers of all shapes and sizes, from a rapidly growing brick-and-mortar franchise to the individual with a great idea and a passion to promote it. The new gTLD will provide an entry-point to the Internet for these innovative individuals and businesses, enriching the e-commerce marketplace.

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

Infibeam.com’ focus in its operation of the gTLD will be on superlative user experiences for our registrants and for Internet end-users. The first established goal is to give a clear web identity for each retailerʹs brand, minimizing the chance of confusion on the side of the user. Online consumers will be aware that stores under our gTLD will primarily be local retailers with a physical address. In the event of a conflict, we will make sure users are able to understand which firm they are dealing with. Each and every store will be bound to a unique physical address, displayed on the main screen. Hence, the identity of the store a consumer is dealing with will be readily available.

By the same token, we will rely on our expertise to assist registrants in offering consumers a comfortable shopping experience with secure payments. Our built-in websites with SKUs, readily available from Infibeam.com, ensure an optimal user experience, while our pre-set payment gateways are a pledge for safe shopping. In addition, a Cash-on-Delivery option will reassure wary customers. 

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

As the operator of the proposed gTLD, Infibeam.com takes its responsibilities to its registrants and the greater Internet as a whole extremely seriously. As a longtime leader in ecommerce, Infibeam.com understands the critical role trust and security play in online transactions. The new gTLD will succeed due to its reputation as a safe place for Internet users to shop.

Infibeam.com offers tools and processes to ensure safe transactions for its BuildaBazaar.com retailers. Those offerings would be available to new gTLD users. But we would also ensure compliance with the highest standards of consumer trust from our registrants. 

Applicants who pass these eligibility tests will then be able to register their applied-for name. Applicants who do not pass the eligibility test will have the opportunity to appeal to the registry, but determination of eligibility rests solely with Infibeam.com.

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.

All transactions involving the private or confidential information of existing Infibeam customers are governed by our corporate privacy policy. For the .ooo gTLD, the only requirements we would have for public display of information would be a physical address, a brand⁄store name, and a phone number. Otherwise the privacy offered will be total.

The .ooo gTLD will be governed by strict guidelines and policies to ensure the privacy of information for registrants as well as users. The policies will be transparent and rigorous; modeled after successful policies implemented by other operators of TLDs; and accompanied by vigilant technological steps to prevent unauthorized access to information. This is a manifestation of the larger goal of the new gTLD, that of a trusted source of safe online transactions, as stipulated in 18(a).

Privacy and security will be key elements of our Acceptable Use Policy (AUP). The AUP will govern how a registrant may use its registered name, with a specific focus on protecting Internet users. AUP language would specifically address privacy by prohibiting a registrant from using a domain for any activity that violates the privacy or publicity rights of another person or entity, or breaches any duty of confidentiality owed to any other person or entity. The AUP also would prohibit spam or other unsolicited bulk email, or computer or network hacking or cracking, as well as the installation of any viruses, worms, bugs, Trojan horses or other code, files or programs designed to, or capable of, disrupting, damaging or limiting the functionality of any software or hardware. We would maintain complete enforcement rights over the use of the domain name. Should a registrant find itself in breach of the AUP, we would reserve the right to revoke, suspend, terminate, cancel or otherwise modify their rights to the domain name.

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

The momentum around the new gTLD will build upon our own success with BuildaBazaar.com. Already highly successful, that serviceʹs online reach will be even greater by the time the new extension becomes widely available. We are currently planning a campaign for our platform that will be launched at the time of the release of the gTLDs. We will unveil a specific marketing campaign around that time, based on our existing customers and Infibeam.com’s very own network. 

Our biggest customers are already using a .com and⁄or .in domain, and we would include the new gTLD in their portfolio. As for small retailers, we will stoke their interest through a targeted campaign aimed at convincing them to invest in the premium package, which would open the new gTLD to them. Most are already aware of the benefits of having their own internet space, and are in fact expecting us to provide such a service. Were a new gTLD to be included in the package, many more will be likely to launch their own e-commerce sites.

Infibeam, as detailed in our answers to Questions 28 and 29 will be taking steps to minimize and mitigate abuses. There will not be burdensome social costs to registrants of a second-level domains under this gTLD. The approval process will prevent immediate registration, but we will bring experience to the gTLD, having already provided similar services under our BuildaBazaar.com offering. There are no negative consequences or costs that will be imposed upon consumers. Quite the contrary, robust adoption of the new gTLD will ensure that consumers have an enhanced online experience. For more on this see 18(b)(ii) and 18(b)(iii) above.

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

Any Infibeam customer would be able to register his own e-store. Though priority will be given to registered brands, people will be able to register under whatever name they want. If there is a conflict, the first parameter is the first-come first-serve basis. 

As the portal goes global, multiple domain name applications will come, with many stores using the same name but being grounded in different regions. We expect to deliver the applied-for name as long as the brand is legally registered as such, on a first-come⁄first-serve basis: we do not intend to give the edge to the biggest firms, though counterfeit prevention will be taken into account.

On the other hand, we will display a physical address for each and every store, often the “flagship” outlet of our user, to differentiate it from stores with similar names. Part of the location may be included in the domain name in order to differentiate the store from the first ones with the idea. In the case of a pure internet player, we will need the official address of the brand as the mandatory registration for firms requires, as stated in 18(b)(iv) above.

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

The domain name will be complimentary within Infibeam’s the premium package. As long as potential registrants fulfill the requirements in 18(b)(iv) above, customers will be able to apply for their own domain. Tailored approaches may be implemented for rural areas, which see much more desultory, and lower-income, stores. 

The registration will be open to other customers at a low price, with minimal complementary services. They would have to register through other registrars or through our own apparatus in order to benefit from an enhanced customer experience. We do not plan any bulk registration discounts as per se one site must be unique to one retailer.

iii. Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.

Infibeam will comply with all ICANN mandated price increase notices. At this time, we do not intend to make any contractual commitments regarding the magnitude of price escalation. 

No

Not Available

No

In order to comply with ICANN requirements and GAC recommendations regarding the protection of geographic names, Infibeam has developed and will implement the following measures to protect geographical names at the second and all other levels in the .ooo gTLD: 

1.Rules for Reserving Geographical Names

Infibeam will comply with Specification 5 ʺSchedule of Reserved Names at the Second Level in gTLD Registriesʺ Section 5 titled ʺCountry and Territory Names.ʺ The country and territory names contained in the following internationally recognized lists shall be initially reserved at the second level and at all other levels within the .ooo gTLD at which the Infibeam provides for registrations:

A. 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 

B. 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

C. 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.

2. Incorporation of GAC recommendations regarding second level geographic domains:

Infibeam will review and seriously consider suggestions from global government entities, public authorities and the IGOʹs regarding additional names with national or geographic significant at the second level. 

Infibeam will consider any claims of abuse, including abuse of names with national or geographic significance as serious offenses. The Abuse Prevention and Mitigation Procedures for the .ooo gTLD will ensure that governments, public authorities or IGOʹs have the ability to raise cases of concern.

3. Rules for registration and employment of geographical names:

If a decision is made by Infibeam to release names reserved in Section 1 above, Infibeam will follow the policy and procedures outlined in Specification 5 of the Registry agreement and will work effectively to reach agreement with the applicable government(s), provided, further, that Infibeam may also propose release of these reservations, subject to review by ICANN’s Governmental Advisory Committee and approval by ICANN.

1. CUSTOMARY REGISTRY SERVICES

Please note; all figures, tables and diagrams referenced in the following response can be found in attachment titled “Attachment dot ooo Q23”.

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

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

Figure 23 1 summarizes the technical and business components of those registry services, customarily offered by a registry operator (i.e., Verisign), that support this application. These services are currently operational and support both large and small Verisign-managed registries. Customary registry services are provided in the same manner as Verisign provides these services for its existing gTLDs.
Through these established registry services, Verisign has proven its ability to operate a reliable and low-risk registry that supports millions of transactions per day. Verisign is unaware of any potential security or stability concern related to any of these services.

Registry services defined by this application are not intended to be offered in a manner unique to the new generic top-level domain (gTLD) nor are any proposed services unique to this application’s registry. 
As further evidence of Verisign’s compliance with ICANN mandated security and stability requirements, Verisign allocates the applicable RFCs to each of the five customary registry services (items A – E above). For each registry service, Verisign also provides evidence in Figure 23 2 of Verisign’s RFC compliance and includes relevant ICANN prior-service approval actions. 

1.1. Critical Operations of the Registry 
i. Receipt of Data from Registrars Concerning Registration of Domain Names and Name Servers 

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

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

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

iii. Dissemination of TLD Zone Files

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

iv. Operation of the Registry Zone Servers

Verisign is Infibeam’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 Infibeam’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, Infibeam’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 .ooo 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, Infibeam’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. Infibeam’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 Infibeam in a consulting capacity as needed. 
Unique to the TLD: This service is not provided in a manner unique to the .ooo gTLD.

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 Infibeam to assess registration fees upon registrars that have exceeded the AGP thresholds stipulated in the AGP Limits Policy. Further, Infibeam accepts and evaluates all exemption requests received from registrars and determines whether the exemption request meets the exemption criteria. Infibeam maintains all AGP Limits Policy exemption request activity so that this material may be included within Infibeam’s Monthly Registry Operator Report to ICANN.
Registrars that exceed the limits established by the policy may submit exemption requests to Infibeam for consideration. Infibeam’s compliance office reviews these exemption requests in accordance with the AGP Limits Policy and renders a decision. Upon request, Infibeam 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, Infibeam 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, Infibeam’s backend registry services provider, has had experience with this policy since its implementation in April 2009 and is available to support Infibeam in a consulting capacity as needed. 

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

2.3. Registry Services Evaluation Policy (RSEP)

Technical Component: Verisign, Infibeam’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, Infibeam’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 .ooo gTLD.

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

Infibeam may implement a Premium Name Program as part of launch plans for the .ooo gTLD. Depending on the estimated demand before launch, we might engage outside experts in developing a program that ensures success. The contingencies being highly tied to the outcome of the first gTLD released, we decided to stay conservative in our estimate itself being based on recent TLD launches. We will leverage past similar experiences to determine what has been most effective and ensure that all efforts are in compliance with ICANN guidelines.

Verisign, Infibeam’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. 
Infibeam 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 .ooo gTLD.

ROBUST PLAN FOR OPERATING A RELIABLE SRS

Please note; all figures, tables and diagrams referenced in the following response can be found in attachment titled “Attachment dot ooo Q24”.

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

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

The SRS components include:

•Web Interface: Allows customers to access the authoritative database for accounts, contacts, users, authorization groups, product catalog, product subscriptions, and customer notification messages.
•EPP Interface: Provides an interface to the SRS that enables registrars to use EPP to register and manage domains, hosts, and contacts.
•Authentication Provider: A Verisign developed application, specific to the SRS, that authenticates a user based on a login name, password, and the SSL certificate common name and client IP address. 

The SRS is designed to be scalable and fault tolerant by incorporating clustering in multiple tiers of the platform. New nodes can be added to a cluster within a single tier to scale a specific tier, and if one node fails within a single tier, the services will still be available. The SRS allows registrars to manage the .ooo 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 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 .ooo gTLD. The application servers store Infibeam’s data in the registry database, which comprises the third and final tier. This simple, industry-standard design has been highly effective with other customers for whom Verisign provides backend registry services.

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

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

Besides improving scalability and reliability, local SRS redundancy enables Verisign to take down individual system components for maintenance and upgrades, with little to no performance impact. With Verisign’s redundant design, Verisign can perform routine maintenance while the remainder of the system remains online and unaffected. For the .ooo 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 Infibeam’s selected backend registry services provider’s (Verisign’s) SRS. This configuration at both the primary and alternate-primary Verisign data centers provides a highly reliable backup capability. Data is continuously replicated between both sites to ensure failover to the alternate-primary site can be implemented expeditiously to support both planned and unplanned outages. 

1.3. Number of Servers
As Infibeam’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 .ooo 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 Infibeam’s selected backend registry services provider’s (Verisign’s) SRS, showing how the SRS component fits into this larger system and interconnects with other system components. 

1.5. Frequency of Synchronization between Servers

As Infibeam’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 .ooo 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 Infibeam 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 Infibeam’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 Infibeam 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 .ooo gTLD as described in this application, Verisign, Infibeam’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, Infibeam’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, Infibeam 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 .ooo 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: ≤ 864 minutes of downtime (≈98%)
•EPP session-command round trip time (RTT): ≤4000 milliseconds (ms), for at least 90 percent of the commands
•EPP query-command RTT: ≤2000 ms, for at least 90 percent of the commands
•EPP transform-command RTT: ≤4000 ms, for at least 90 percent of the commands

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

Please note; all figures, tables and diagrams referenced in the following response can be found in the attachment titled “Attachment dot ooo Q25”. All EPP schemas can be found in the attachment titled “Attachment dot ooo Q25 EPP schemas”.

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

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

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

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

1.1. EPP Interface with Registrars

Verisign, Infibeam’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, Infibeam’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 .ooo 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 Infibeam 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, Infibeam’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 Infibeam 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 .ooo gTLD as described in this application, Verisign, Infibeam’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, Infibeam’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 .ooo 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, Infibeam’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, Infibeam’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.

6. PROPRIETARY EPP EXTENSION CONSISTENCY WITH REGISTRATION LIFECYCLE 

Infibeam’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

Please note; all figures, tables and diagrams referenced in the following response can be found in attachment titled “Attachment dot ooo Q26”.

Verisign, Infibeam’s selected backend registry services provider, has operated the Whois lookup service for the gTLDs and ccTLDs it manages since 1991, and will provide these proven services for the .ooo 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 Infibeam’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 .ooo 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:
 oDomain name, including the TLD (e.g., EXAMPLE.TLD)
 oFull name of the registrar, including punctuation (e.g., Example Registrar, Inc.)
 oFull 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, Infibeam’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, Infibeam’s selected backend registry services provider. The figure details the configuration with one resolution⁄Whois site. For the .ooo 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. 

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

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

1.5. Frequency of Synchronization between Servers
Synchronization between the SRS and the geographically distributed Whois resolution sites occurs approximately every three minutes. Verisign, Infibeam’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, Infibeam’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 .ooo 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 Infibeam 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, Infibeam’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 Infibeam 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 .ooo gTLD as described in this application, Verisign, Infibeam’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
Infibeam’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, Infibeam’s selected backend registry services provider, provides a Whois service that is available via both port 43 in accordance with RFC 3912, and a web-based directory service at whois.nic.〈TLD〉 also in accordance with RFC 3912, thereby providing free public query-based access. Verisign acknowledges that ICANN reserves the right to specify alternative formats and protocols, and upon such specification, Verisign will implement such alternative specification as soon as reasonably practicable.
The format of the following data fields conforms to the mappings specified in Extensible Provisioning Protocol (EPP) RFCs 5730 – 5734 so the display of this information (or values returned in Whois responses) can be uniformly processed and understood: domain name status, individual and organizational names, address, street, city, state⁄province, postal code, country, telephone and fax numbers, email addresses, date, and times.
Specifications for data objects, bulk access, and lookups comply with Specification 4 and are detailed in the following subsections, provided in both bulk access and lookup modes. 

Bulk Access Mode. This data is provided on a daily schedule to a party designated from time to time in writing by ICANN. The specification of the content and format of this data, and the procedures for providing access, shall be as stated below, until revised in the ICANN Registry Agreement. 
The data is provided in three files:
•Domain Name File: For each domain name, the file provides the domain name, server name for each name server, registrar ID, and updated date.
•Name Server File: For each registered name server, the file provides the server name, each IP address, registrar ID, and updated date.
•Registrar File: For each registrar, the following data elements are provided: registrar ID, registrar address, registrar telephone number, registrar email address, Whois server, referral URL, updated date, and the name, telephone number, and email address of all the registrarʹs administrative, billing, and technical contacts.
Lookup Mode. Figures ‎26 4 through Figure ‎26 6 provide the query and response format for domain name, registrar, and name server data objects.

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

In accordance with RDDS registry performance specifications detailed in Specification 10, Verisignʹs Whois service meets the following proven performance attributes:
•RDDS availability: 864 min of downtime (98%)
•RDDS query RTT: 2000 ms, for at least 95% of the queries
•RDDS update time: 60 min, for at least 95% of the probes

6. SEARCHABLE WHOIS
Verisign, Infibeam’s selected backend registry services provider, provides a searchable Whois service for the .ooo 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 the Infibeam’s defined .ooo 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, Infibeam’s selected backend registry services provider, is knowledgeable of the likely data mining forms of abuse associated with a searchable Whois service. Figure ‎26 7 summarizes these potential forms of abuse and Verisign’s approach to mitigate the identified risk. 

1. COMPLETE KNOWLEDGE AND UNDERSTANDING OF REGISTRATION LIFECYCLES AND STATES
Please note; all figures, tables and diagrams referenced in the following response can be found in the attachment titled “Attachment dot ooo Q27”.

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

1.1 Registration Lifecycle of Create⁄Update⁄Delete
The following section details the create⁄update⁄delete processes and the related renewal process that Verisign, Infibeam’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 .ooo.
•The registrar has available credit.
•A valid Authorization Information (Auth-Info) value.
•Required contacts (e.g., registrant, administrative contact, technical contact, and billing contact) are specified and exist.
•The specified name servers (hosts) exist, and there is a maximum of 13 name servers.
•A period in units of years with a maximum value of 10 (default period is one year).

Renewal Process. The domain name can be renewed unless it has any form of Pending Delete, Pending Transfer, or Renew Prohibited.
A request for renewal that sets the expiry date to more than ten years in the future is denied. The registrar must pass the current expiration date (without the timestamp) to support the idempotent features of EPP, where sending the same command a second time does not cause unexpected side effects.
Automatic renewal occurs when a domain name expires. On the expiration date, the registry extends the registration period one year and debits the registrar account balance. In the case of an auto-renewal of the domain name, a separate Auto-Renew grace period applies. Renewals are subject to grace periods as described in Section 1.3 of this response, “Add Grace Period, Redemption Grace Period, and Notice Periods for Renewals or Transfers”.

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

The Domain Name Renew operation is detailed in Figure 27 4 and requires the following attributes:
•A domain name that exists and is sponsored by the requesting registrar.
•The registrar is authorized to renew a domain name in .ooo.
•The registrar has available credit.
•The passed current expiration date matches the domain name’s expiration date.
•A period in units of years with a maximum value of 10 (default period is one year). A domain name expiry past ten years is not allowed.

Registrar Transfer Procedures. A registrant may transfer his⁄her domain name from his⁄her current registrar to another registrar. The database system allows a transfer as long as the transfer is not within the initial 60 days, per industry standard, of the original registration date. 
The registrar transfer process goes through many process states, which are described in detail below, unless it has any form of Pending Delete, Pending Transfer, or Transfer Prohibited.
A transfer can only be initiated when the appropriate Auth-Info is supplied. The Auth-Info for transfer is only available to the current registrar. Any other registrar requesting to initiate a transfer on behalf of a registrant must obtain the Auth-Info from the registrant.
The Auth-Info is made available to the registrant upon request. The registrant is the only party other than the current registrar that has access to the Auth-Info. Registrar transfer entails a specified extension of the expiry date for the object. The registrar transfer is a billable operation and is charged identically to a renewal for the same extension of the period. This period can be from one to ten years, in one-year increments.
Because registrar transfer involves an extension of the registration period, the rules and policies applying to how the resulting expiry date is set after transfer are based on the renewal policies on extension.
Per industry standard, a domain name cannot be transferred to another registrar within the first 60 days after registration. This restriction continues to apply if the domain name is renewed during the first 60 days. Transfer of the domain name changes the sponsoring registrar of the domain name, and also changes the child hosts (ns1.sample.xyz) of the domain name (sample .xyz). 

The domain name transfer consists of five separate operations:
•Transfer Request (Figure 27 5): Executed by a non-sponsoring registrar with the valid Auth-Info provided by the registrant. The Transfer Request holds funds of the requesting registrar but does not bill the registrar until the transfer is completed. The sponsoring registrar receives a Transfer Request poll message.
•Transfer Cancel (Figure 27 6): Executed by the requesting registrar to cancel the pending transfer. The held funds of the requesting registrar are reversed. The sponsoring registrar receives a Transfer Cancel poll message.
•Transfer Approve (Figure 27 7): Executed by the sponsoring registrar to approve the Transfer Request. The requesting registrar is billed for the Transfer Request and the sponsoring registrar is credited for an applicable Auto-Renew grace period. The requesting registrar receives a Transfer Approve poll message.
•Transfer Reject (Figure 27 8): Executed by the sponsoring registrar to reject the pending transfer. The held funds of the requesting registrar are reversed. The requesting registrar receives a Transfer Reject poll message.
•Transfer Query (Figure 27 9): Executed by either the requesting registrar or the sponsoring registrar of the last transfer.
The registry auto-approves a transfer if the sponsoring registrar takes no action. The requesting registrar is billed for the Transfer Request and the sponsoring registrar is credited for an applicable Auto-Renew grace period. The requesting registrar and the sponsoring registrar receive a Transfer Auto-Approve poll message.

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

Process Characterization. The domain name can be deleted, unless it has any form of Pending Delete, Pending Transfer, or Delete Prohibited.
A domain name is also prohibited from deletion if it has any in-zone child hosts that are name servers for domain names. For example, the domain name “sample.xyz” cannot be deleted if an in-zone host “ns.sample.xyz” exists and is a name server for “sample2.xyz.”
If the Domain Name Delete occurs within the Add grace period, the domain name is immediately deleted and the sponsoring registrar is credited for the Domain Name Create. If the Domain Name Delete occurs outside the Add grace period, it follows the Redemption grace period (RGP) lifecycle.

Update Process. The sponsoring registrar can update the following attributes of a domain name:
•Auth-Info
•Name servers
•Contacts (i.e., registrant, administrative contact, technical contact, and billing contact)
•Statuses (e.g., Client Delete Prohibited, Client Hold, Client Renew Prohibited, Client Transfer Prohibited, Client Update Prohibited)

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

1.2 Pending, Locked, Expired, and Transferred 
Verisign, Infibeam’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, Infibeam’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
Infibeam’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 .ooo gTLD as well as other TLDs managed by Verisign, Infibeam’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 .ooo 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
Infibeam’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 .ooo database. Two identical second-level domain names cannot simultaneously exist in .ooo. 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, Infibeam’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 Infibeam 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 .ooo gTLD as described in this application, Verisign, Infibeam’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

Please note; all figures, tables and diagrams referenced in the following response can be found in attachment titled “Attachment dot ooo Q28”.

By registering the .ooo gTLD, Infibeam hopes to provide a myriad of retailers their own, customized, online retail space. With the use of the .ooo gTLD, Infibeam will be able to offer personalized domain names, thus allowing strong brand association, and differentiation. By providing new outlets for brick-and-mortar retailers to sell their goods and services online, those retailers would gain new business and more readily remain in operation, but the real winners would be Internet users. The adoption of the gTLD by global retailers will dramatically increase consumer choice across a limitless range of goods and services, in a safe and trusted environment. Our policies will ensure that the gTLD will be synonymous in an online consumerʹs mind with choice and trust. In order to ensure this trust, it is of paramount importance that Infibeam maintain stringent rules, so as to avoid abuse of the .ooo gTLD.

1.1 .ooo Abuse Prevention and Mitigation Implementation Plan 
Unfortunately, some gTLDs are not operated in a manner that instils confidence in the internet consumer and the online shopper. As explained above, Infibeam hopes to make the .ooo gTLD different. In launching the .ooo gTLD we have put together a collection of efforts that seek to prevent and successfully mitigate domain name abuse, making the web a more accessible and friendly place for small and medium sized businesses as well as individuals. These efforts include:
•An acceptable use policy; 
•An abuse mitigation team already situated to handle complaints of abuse; 
•Technological Measures for Removal of Orphan Glue Records;
•Efforts and measures to promote accurate and complete Whois;
•Requirements for .ooo accredited registrars to enact measures in support of these efforts.

Preventing domain name abuse in the .ooo gTLD is of critical importance to registrants, consumers and Infibeam. To demonstrate our commitment to make the .ooo gTLD more resistant to abusive behavior than most other gTLDs, Infibeam has explored various mechanisms to help prevent abusive registrations. Following on from this, Infibeam has developed and will look to deploy a customized approach that seeks to minimize the potential for abusive registrations and mitigate them as soon as possible should they occur. Registrants, Registrars and the Registry will all play a role in this endeavor. Having all three levels of the .ooo gTLD ecosystem participate in these measures will help ensure a comprehensive approach to these critical objectives. Infibeam has designed the following procedure to prevent and mitigate abusive registrations:

Acceptable Use Policy - Infibeam has developed a draft Acceptable Use Policy (AUP) found in attachment to Question 28 under the name ‘dot ooo Q28 AUP’. This AUP clearly defines what is considered abuse and what type of behavior is expressly prohibited in conjunction with the use of a .ooo domain name. Infibeam will require, through the Registry Registrar Agreement (RRA), that this AUP be included in the registration agreement used by all .ooo gTLD accredited registrars. This registration agreement must be accepted by a registrant prior to them being able to register a name in the .ooo gTLD. 
Infibeam will ensure all domain names meet the technical requirements as set forth in applicable RFCs as well as domain name reservations as set forth in Specification 5 of the template Registry Agreement. In addition, the registry will develop a list of reserved names that are intended to be released in the future and the procedures governing their release will be developed in an open and transparent manner. 

Annual Certification of Registrar compliance with Registry-Registrar Agreement. The self-certification program consists, in part, of evaluations applied equally to all operational .ooo gTLD accredited registrars and conducted from time to time throughout the year. Process steps are as follows:
•Infibeam 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 14 business days of receipt of the notification. 
•When the form is submitted, Infibeam sends the registrar an automated email confirming that the form was successfully submitted.
•Infibeam reviews the submitted form to ensure the certifications are compliant.
•Infibeam 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 Infibeam 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, Infibeam sends the registrar a Breach Notice and gives the registrar 30 days to cure the breach.
•If the registrar does not cure the breach, Infibeam terminates the Registry-Registrar Agreement (RRA). 

1.2 Policies for Handling Complaints Regarding Abuse

We will display the contact information for the Abuse Mitigation Team, which serves as the primary point of contact for reporting abuse within the .ooo gTLD, on the .ooo gTLD website.
Each .ooo gTLD accredited registrar will also provide and maintain valid a primary point of contact for abuse complaints. The registrar must provide and maintain valid primary contact information for reporting abuse in the .ooo gTLD on their website. This will be required as part of the .ooo gTLD RRA.
Infibeam will explicitly define for Registrars what constitutes abusive behavior including but not limited to, malicious, negligent, and reckless behavior. The definition of abusive behavior will be contained in the AUP that Registrars will be required to include as part of the Registration Agreement. This will be required as part of the .ooo gTLD RRA.
Registrar must notify Registry Operator immediately regarding any investigation or compliance action including the nature of the investigation or compliance action by ICANN or any outside party (e.g., law enforcement, etc.), along with the TLD impacted. This will be required as part of the .ooo gTLD RRA.

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. Infibeam’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 Infibeam’s abuse plan are provided in Section 2 of this response. 

1.5 Measures to Promote Whois Accuracy
Ensuring the accuracy of Whois information is of paramount importance to Infibeam in the operation of the .ooo gTLD. Infibeam will maintain valid primary contact information (e.g., name, email address, and phone number) on its website. All .ooo accredited registrars will be contractually required to do the same. 
Infibeam will employ the following mechanism to promote Whois accuracy:
There will be a strict prohibition against the use of proxy registration services;
The Registrant Whois must be affirmatively revalidated biannually. Unlike current industry practices which just involve sending an email to a registrant asking them to confirm the accuracy of the Whois data, this semi-annual re-validation will require positive affirmation from the Registrant; and, 
Infibeam will maintain a web-based form for third parties to submit claims regarding false and or inaccurate Whois data and Infibeam will forward credible claims to the Registrar for investigation⁄resolution. Infibeam will follow up after 7 days to verify that the claim has been satisfactorily resolved. Failure of the Registrar or Registrant to resolve the problem will result in Infibeam placing the domain name on hold, absent extraordinary circumstances. This proactive approach is much more robust than the current process which ICANN has implemented. 

1.5.1 Regular Monitoring of Registration Data for Accuracy and Completeness
As part of their Registry-Registrar Agreement, all .ooo Registrars will be required to revalidate Whois data for each record they have registered on a bi-annual basis. This revalidation will require the Registrant to affirmatively respond to a confirmation email sent out within a set period of time. While Infibeam reserves the right to suspend domain names that are not verified in a timely manner, Infibeam will engage in other outreach to the Registrant prior to suspending any domain name. As part of the .ooo gTLD Abuse reporting system, users can report missing or incomplete Whois data via the registry website. Infibeam will also perform randomized audits of verified Whois information to ensure compliance and accuracy. 
Additionally, Verisign, Infibeam’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 Infibeam 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. 

1.6 Malicious or Abusive Behavior Definitions, Metrics, and Service Level Requirements for Resolution
Infibeam defines Malicious and Abusive behavior based on but not limited to the following definitions;
•Phishing is a criminal activity employing tactics to defraud and defame Internet users via sensitive information with the intent to steal or expose credentials, money or identities. A phishing attack begins with a spoofed email posing as a trustworthy electronic correspondence that contains hijacked brand names i.e. (financial institutions, credit card companies, e-commerce sites). The language of a phishing email is misleading and persuasive by generating either fear and⁄or excitement to ultimately lure the recipient to a fraudulent Web site. It is paramount for both the phishing email and Web site to appear credible in order for the attack to influence the recipient. As with the spoofed email, phishers aim to make the associated phishing Web site appear credible. The legitimate target Web site is mirrored to make the fraudulent site look professionally designed. Fake third-party security endorsements, spoofed address bars, and spoofed padlock icons falsely lend credibility to fraudulent sites as well. The persuasive inflammatory language of the email combined with a legitimate looking Web site is used to convince recipients to disclose sensitive information such as passwords, usernames, credit card numbers, social security numbers, account numbers, and mother’s maiden name. 
•Malware is malicious software that was intentionally developed to infiltrate or damage a computer, mobile device, software and⁄or operating infrastructure or website without the consent of the owner or authorized party. This includes, amongst others, Viruses, Trojan horses, and worms. 
•Domain Name or Domain Theft is the act of changing the registration of a domain name without the permission of its original registrant.
•Botnet Command and Control: Services run on a domain name that is used to control a collection of compromised computers or “zombies,” or to direct Distributed Denial of Service attacks (DDoS attacks)
•Distribution of Malware: The intentional creation and intentional or unintentional distribution of “malicious” software designed to infiltrate a computer system without the owner’s consent, including, without limitation, computer viruses, worms, keyloggers, and Trojans. 
•Fast Flux Attacks⁄Hosting: A technique used to shelter Phishing, Pharming, and Malware sites and networks from detection and to frustrate methods employed to defend against such practices, whereby the IP address associated with fraudulent sites are changed rapidly so as to make the true location of the sites difficult to find.
•Hacking: Unauthorized access to a computer network;
•Pharming: The redirecting of unknown users to fraudulent sites or services, typically through, but not limited to, DNS hijacking or poisoning;
•Spam: The use of electronic messaging systems to send unsolicited bulk messages. The term applies to email spam and similar abuses such as instant messaging spam, mobile messaging spam, and spamming of websites and Internet forums.
Further abusive behaviours include, but are not limited to; Cybersquatting，Front-Running，Gripe Sites， Deceptive and⁄or Offensive Domain Names，Fake Renewal Notices，Cross-TLD Registration Scam，Name Spinning，Pay-per-Click，Traffic Diversion，False Affiliation，Domain Kiting ⁄ Tasting， fast‐flux, botnet command and‐control and 419 scams.

Infibeam’s Policies and Procedures for Handling Complaints Regarding Abuse as defined in this section.

Infibeam will staff a Single Point of Contact Abuse Team to address abuse and malicious use complaints. The role of the abuse team is to monitor registry services and review complaints lodged online by end users, customers, or from Law Enforcement. The complaints are managed in accordance with the Acceptable Use Policies (AUP) and Terms of Service which allows the Abuse Team discretion to suspend a domain instantly or send the complaint thru the appropriate escalation channel for complaint resolution. 

Complaints are received via email as noted on the registry website. Registrars will have a dedicated hotline, email address, and personnel for filing direct requests. Complaints may be submitted 24x7. We will acknowledge the complaint within one business day and will provide the requestor acceptance and⁄or resolution within three business days depending on severity and complexity of the complaint. 

Infibeamʹs Abuse Policies recognize many forms of abuse related to the registrations and use of domain names. Abuses and their respective mitigation strategy listed here is not an exhaustive list, but is meant to highlight general process and procedure by which we will manage the most common forms of abuse. 

For less severe complaint such as incidents of spam and malware, our plan is to investigate the complaint, determine validity, contact the registrant and resolve the issue within 3 days. Many times this will happen sooner. 

For more serious offenses such as Phishing, Illegal Access to other Computers or Networks, etc, we have the right to and many times will suspend the domain, conduct an investigation, contact the registrant and mitigate the offense. Depending on severity, goal is to rectify the situation within 24 hours. If necessary, proper law enforcement authorities will be contacted to relay the results of the incident. You can find more information about the draft process in the attached document ‘dot ooo Q28 Process’.

1.7 Controls to Ensure Proper Access to Domain Functions
There will be a contractual requirement between Infibeam and all .ooo accredited registrars for the mandatory sharing of information regarding instances of abuse, where legally applicable. This qualification is necessary as there may be instances where registration authorities are prohibited by law from sharing information with third parties.

1.7.1 Multi-Factor Authentication
To ensure proper access to domain functions, Infibeam 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. 


2. TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION
Resource Planning
Infibeam is a leader in e-commerce, a rapidly growing company based in Ahmedabad, India, serving one of the most populous nations on the globe. Since 2007, Infibeam.com has been a one-stop online outlet for apparel; beauty supplies; books; health goods; jewelry; technology; toys; and many other goods. In 2011 it empowered brick-and-mortar retailers by offering them access to Internet users via the BuildaBazaar.com platform. Retailers operating BuildaBazaar.com retailers include apparel stores, bookstores, electronics outlets, jewelry retailers, and other consumer and business needs. The company is well-loved by its customers, with more than 900,000 fans on Facebook. Infibeam was named a Top 5 Digital Brand in September 2010 in a survey conducted by the Economic Times.

The .ooo gTLD will be fully supported by a cross function team of Infibeam professionals. Numbers and types of employees will vary for each function but Infibeam projects it will use the following personnel to support the resource planning requirements:
•Marketing manager 1 
•Marketing director 1 
•Customer support 4 
•Technical support 1 
•Legal 1 
•Accounting 1 


Resource Planning Specific to Backend Registry Activities
Verisign, Infibeam’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 gTLD. 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 Infibeam 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 .ooo gTLD as described in this application, Verisign, Infibeam’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
3.1 Start-Up Anti-Abuse Policies and Procedures
As stated earlier, Infibeam has included as an attachment its draft AUP. Prior to finalizing this policy, Infibeam will undertake a review of other Abuse and Acceptable Policies from similar gTLD registry operators to develop a best-in-class policy that will provide it with the appropriate legal authority to take prompt and decisive action when necessary. While Infibeam is currently envisioning a separate standalone Abuse Policy, it reserves the right to incorporate this Abuse Policy into a broader Acceptable Use Policy.

3.2 Ongoing Anti-Abuse Policies and Procedures
3.1 Policies and Procedures That Identify Malicious or Abusive Behavior
VeriSign, Infibeam’s selected backend registry services provider, provides the following service to Infibeam 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 gTLD zones. Reports with remediation instructions are provided to help registrars and registrants eliminate the identified malware from the registrant’s website. 

3.2 Policies and Procedures That Address the Abusive Use of Registered Names
Suspension processes. In the case of domain name abuse, Infibeam will determine whether to take down the subject domain name. Verisign, Infibeam’s selected backend registry services provider, will adhere to the following auditable processes to comply with the suspension request.

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

Verisign Notification Verification. When Verisign receives a suspension request from Infibeam 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 Infibeam 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 Infibeam’s request, Verisign notifies the registrar of the suspension. 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 Infibeam’s request, Verisign notifies the registrant of the suspension. 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

Upon Infibeam’s request, Verisign can provide a process for registrants to protest the suspension. 
Domain Suspension. Verisign places the domain to be suspended on the following statuses:
•serverUpdateProhibited 
•serverDeleteProhibited
•serverTransferProhibited
•serverHold 

Suspension Acknowledgement. Verisign notifies Infibeam 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
•Infibeam 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
Infibeam believes that the proposed tapestry of protections that involve both proactive and reactive mechanism will provide an unmatched level of security and anti-abuse activity within the .ooo gTLD. These mechanisms will be hard coded into both the Registry-Registrar Agreement as well as the Registrant Registration Agreement. 
Infibeam is fully committed to improving the completeness and accuracy of Whois data and to preventing and mitigating domain name abuse in the .ooo gTLD. We strongly believe the efforts that we have lain out will go a long way in this critical area and most certainly meet the requirements as outlined by ICANN.
The fight against domain name abuse is not a static fight. The tactics used by malicious parties are constantly evolving and Infibeam is committed to evolving our systems to address these ongoing threats, not simple because ICANN requires it, but also because it is in our client’s interests.

5. TECHNICAL PLAN SCOPE⁄SCALE THAT IS CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY
Scope⁄Scale Consistency
Infibeam is confident that the distribution of validation⁄verification services between itself and .ooo accredited Registrars will provide the level of protection needed to minimize potential abuse activity within the .ooo gTLD.

Scope⁄Scale Consistency Specific to Backend Registry Activities
Verisign, Infibeam’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 .ooo 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 Infibeam 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

The mission of the .ooo gTLD is to provide retailers their own, customized, online retail space. With the use of the .ooo gTLD, Infibeam will be able to offer personalized domain names, thus allowing strong brand association, and differentiation. By providing new outlets for brick-and-mortar retailers to sell their goods and services online, those retailers will gain new business and more readily remain in operation, but the real winners are Internet users. The adoption of the gTLD by global retailers will dramatically increase consumer choice across a limitless range of goods and services, in a safe and trusted environment. In order to create this safe and trusted environment, it is in Infibeam’s interest to prevent abusive registrations – beyond simply adhering to regulations.

Infibeam 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 .ooo gTLD. Infibeam understands the importance of Trademark holders to manage and protect their brands. In order to demonstrate our commitment to ensure the .ooo gTLD will accommodate the Intellectual Property community, Infibeam has explored various additional mechanisms to help prevent abusive registrations.
 
Since the launch of the new gTLD program, some organizations have stepped forward offering proposals with enhanced security standards from various types of TLDs. Infibeam completed a thorough review to determine which standards may enhance the .ooo gTLD experience. While not all of the proposed standards are applicable to the .ooo gTLD, we will strive to implement several of them to ensure trademark owners will be able to take advantage of additional protection beyond the minimums outlined by ICANN. 

Infibeam has also developed and will deploy a customized approach that seeks to minimize the potential for abusive registrations and incorporate a proactive mitigation process if such a situation were to arise. Measures will be deployed at the registry, registrar, and registrant levels to ensure a comprehensive approach to these critical objectives. Policies and processes designed to prevent and mitigate abusive registrations include:

•Sunrise Period
•Trademark Claims Service
•Extended Trademark Claims Service 
•UDRP, URS, PDDRP
•Rapid Takedown or Suspension
•Anti-Abuse Process
•Malware Code Identification
•DNSSEC Signing Service
•Biannual WHOIS Verification 
•Name Selection Policy
•Registrant Eligibility Criteria
•Acceptable Use Policy


1.2 Startup Rights Protection Mechanisms
Further to these policies, rights protection is one of Infibeam’s core objectives. Infibeam 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. As mentioned above, Infibeam 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 .ooo 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, Infibeam cannot fully detail the specific implementation of the Trademark Clearinghouse within this application. Infibeam will adhere to all processes and procedures to comply with ICANN guidance once this guidance is finalized. 

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

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 Infibeam 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 Infibeam either directly or through Infibeam-approved registrars. 

Infibeam requires all registrants, either directly or through Infibeam-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 Infibeam 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, Infibeam and⁄or Infibeam-approved registrars, as applicable, are responsible for determining whether each domain name is eligible to be registered (including in accordance with the SERs).
While Infibeam is exploring engaging outside expertise to assist with the implementation of a sunrise service, we drafted our current business plan based on the staffing of two member of our legal team full time for the duration of the Sunrise period.

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, Infibeam or the Infibeam-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, Infibeam or the Infibeam-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, Infibeam or the Infibeam-approved registrar will not process the domain name registration.
Following the registration of a domain name, the Infibeam-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 Infibeam will recognize and honor all word marks validated by the Trademark Clearinghouse.

Extended Trademark Claims Service
To further enhance the rights protections for trademark holders, Infibeam will be offering an extended 30 day period of the Trademark Claims service for a total of 90 days. In exceptional cases, Infibeam may acknowledge legitimate trademark claims after this period, if obvious abuse of the brand name can be proved.
 
2. MECHANISMS DESIGNED TO IDENTIFY AND ADDRESS THE ABUSIVE USE OF REGISTERED NAMES ON AN ONGOING BASIS
In addition to the Sunrise and Trademark Claims services described in Section 1 of this response, Infibeam will implement and adhere to RPMs post-launch as mandated by ICANN, and confirms that registrars accredited for the .ooo gTLD will be in compliance with these mechanisms. Certain aspects of these post-launch RPMs may be administered on behalf of Infibeam by Infibeam-approved registrars or by subcontractors of Infibeam, such as its selected backend registry services provider, Verisign. 

2.1 Ongoing Rights Protection Mechanisms
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, Infibeam 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 .ooo gTLD: 

Uniform Dispute Resolution Policy
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. Infibeam and entities operating on its behalf adhere to all decisions rendered by UDRP providers.

Uniform Rapid Suspension
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, Infibeam and entities operating on its behalf adhere to decisions rendered by the URS providers.

Post Delegation Dispute Resolution Procedure
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. Infibeam participates in the PDDRP process as specified in the Applicant Guidebook.

2.2 Additional Measures Specific to Rights Protection
Infibeam 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
Infibeam 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 gTLD 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
Infibeam implements an anti-abuse process that is executed based on the type of domain name takedown requested. The anti-abuse process is for malicious exploitation of the DNS infrastructure, such as phishing, botnets, and malware. 

Authentication Procedures
Verisign, Infibeam’s selected backend registry services provider, uses two-factor authentication to augment security protocols for telephone, email, and chat communications.

Malware Code Identification
This safeguard reduces opportunities for abusive behaviors that use registered domain names in the gTLD. Registrants are often unknowing victims of malware exploits. As Infibeam’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 .ooo gTLD is DNSSEC-enabled as part of Verisign’s core backend registry services. 
Where applicable, these measures will be incorporated into the RRA which governs the legal relationship between Infibeam and its accredited registrars.

2.3 Whois Verification
As part of their RRA, all Infibeam registrars will be required to revalidate Whois data for each record they have registered in the gTLD. The registry will leave the ultimate determination of how to implement this procedure to each registrar but it must include one of the following approved methods. 
1)Email with a verification link that must be acted upon within a set time frame.
2)If the email verification is not acted upon in the proscribed timeframe, an outbound telemarketing effort to the individual listed as the administrative contact for the domain must be initiated to manually confirm the information contained in the Whois record. 
 
Each method will require the use of two factor authentication to ensure the respondent is the original registrant.

Verification process for each registered domain name must take place twice a year within the following schedule:

1)Mid registration Verification: No sooner than 150 days after initial registration or subsequent renewal and no later than 210 days after initial registration or subsequent renewal
2)Renewal Verification: No later than 7 days prior to expiration and no sooner than 45 days prior to expiration. 

Infibeam, as operator of the registry, will perform audits of verified Whois information to ensure compliance and accuracy. In addition, the registry will allow interested parties to report cases of inaccurate Whois information via an inbound reporting mechanism on the .ooo gTLD webpage.

2.4 Adoption of Certain Elevated Security Standards
As referenced earlier in this question, Infibeam will work to implement the following elevated security standards in the .ooo gTLD:

Name Selection Policy
The .ooo gTLD will enforce a name selection policy that ensures that all names registered in the gTLD will be in compliance with ICANN mandated technical standards. These include restrictions on 2 character names, tagged names, reserved names for Registry Operations. All names must also be in compliance with all applicable RFCs governing the composition of domain names. In addition, registrations of Country, Geographical and Territory Names will only be allowed in compliance with the restrictions as outlined in the answer to Question 22.

Registrant Eligibility Criteria
The Registrant Eligibility Criteria evaluation process serves several purposes which will reduce the incidents of abusive registrations that impact the rights of others as well as impact the security of the gTLD. This will include ensuring that all registrant information is complete, true and accurate, thereby contributing to accurate Whois information for all domains in the gTLD.

Applicants who pass these eligibility tests will then be permitted to register their domain name. Applicants who do not pass the eligibility test will have the opportunity to appeal to the registry, but determination of eligibility rests solely with Infibeam. In the case of a dispute, an adjunct ombudsman will be used.

Acceptable Use Policy
Infibeam has developed a draft of the Registry Operator Acceptable Use Policy (AUP) which is further detailed in the response to Question 28. This AUP clearly defines what type of behavior is expressly prohibited in conjunction with the use of a .ooo domain name. Infibeam will require, through the Registry Registrar Agreement (RRA), that this AUP be included in the registration agreement used by all .ooo gTLD accredited registrars. This registration agreement must be agreed upon by a registrant prior to them being able to register a name in the .ooo gTLD.

3. RESOURCING PLANS
3.1 Resource Planning
Infibeam is a leader in e-commerce, a rapidly growing company based in Ahmedabad, India, serving one of the most populous nations on the globe. Since 2007, Infibeam.com has been a one-stop online outlet for apparel; beauty supplies; books; health goods; jewelry; technology; toys; and many other goods. In 2011 it empowered brick-and-mortar retailers by offering them access to Internet users via the BuildaBazaar.com platform. Retailers operating BuildaBazaar.com retailers include apparel stores, bookstores, electronics outlets, jewelry retailers, and other consumer and business needs. The company is well-loved by its customers, with more than 900,000 fans on Facebook. Infibeam was named a Top 5 Digital Brand in September 2010 in a survey conducted by the Economic Times.

The .ooo gTLD will be fully supported by a cross function team of Infibeam professionals. Numbers and types of employees will vary for each function but Infibeam projects it will use the following personnel to support the resource planning requirements:

•Marketing manager 1 
•Marketing director 1 
•Customer support 4 
•Technical support 1 
•Legal 1 
•Legal (for Sunrise Period) 1
•Accounting 1

Please note that during the Sunrise period one more legal will be working on trademark claims to cope with the volume. This extra budget could also be used to engage outside expertise.

3.2 Resource Planning Specific to Backend Registry Activities
Verisign, Infibeam’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 gTLD. 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 Infibeam 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 .ooo gTLD as described in this application, Verisign, Infibeam’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
Please note; all figures, tables and diagrams referenced in the following response can be found in attachment titled “Attachment dot ooo Q30A”.

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

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

Augmented Security Levels or Capabilities. See Section 5 of this response. 
Commitments Made to Registrants Concerning Security Levels. See Section 4 of this response.

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

Verisign, Infibeam’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 .ooo 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 Infibeam 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
Resource Planning
Infibeam is a leader in e-commerce, a rapidly growing company based in Ahmedabad, India, serving one of the most populous nations on the globe. Since 2007, Infibeam.com has been a one-stop online outlet for apparel; beauty supplies; books; health goods; jewelry; technology; toys; and many other goods. In 2011 it empowered brick-and-mortar retailers by offering them access to Internet users via the BuildaBazaar.com platform. Retailers operating BuildaBazaar.com retailers include apparel stores, bookstores, electronics outlets, jewelry retailers, and other consumer and business needs. The company is well-loved by its customers, with more than 900,000 fans on Facebook. Infibeam was named a Top 5 Digital Brand in September 2010 in a survey conducted by the Economic Times.

The .ooo gTLD will be fully supported by a cross function team of Infibeam professionals. Numbers and types of employees will vary for each function but Infibeam projects it will use the following personnel to support the resource planning requirements:

•Marketing manager 1 
•Marketing director 1 
•Customer support 4 
•Technical support 1 
•Legal 1 
•Accounting 1 

Resource Planning Specific to Backend Registry Activities
Verisign, Infibeam’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 Infibeam 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 .ooo gTLD as described in this application, Verisign, Infibeam’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 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 .ooo gTLD. As defined in Section 1 of this response, Verisign, Infibeam’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)