Application number: 1-1975-66983 for Dot Food, LLC

Dot Food, LLC

9138973100

8169947333

Tess Pattison-Wade

Executive Director

9136084088

tess@dotregistry.org

Shaul Jolles

CEO

8162007080

sjolles@dotregistry.org

Limited Liability Company

Kansas

Not Available

Ecyber Solutions Group, INc

Chris Parrott
Director of Finance
Paul Spurgeon
COO
Scott Samuels
Director of Business Development
Scott Schahtman
Director of Legal & Policy
Shaul Jolles
CEO

Ecyber Solutions Group, INC
Not Applicable

Ecyber Solutions Group, INC
Not Applicable

food

Not Available

There are no known operational or rendering issues associated with our applied for string. We are relying on the proven capabilities of Neustar to troubleshoot and quickly eliminate these should they arise.

To provide a consistent, identifiable online industry marker for food related businesses, in order to better serve the ever growing Food Industry and consumer needs worldwide. 

The purpose of “.FOOD” is to provide a commerce environment and information exchange platform for the food industry allowing businesses to create user friendly access to products and services instantaneously through accurate search engine classifications. 

“.FOOD” will serve to unite all aspects of life and business associated with ʹfoodʹ and create a marketing catapult to propel food related industries into the next wave of internet expansion. It is our mission that businesses bearing the “.FOOD” gTLD string would become leaders in their market and be instantly differentiated online as food producers, providers, or service professionals. 

While food is a necessary commodity, it has also become synonymous with community, family, and recreation. Meals bring people together, play major roles in travel planning, and create community through recipe sharing, picnics, and education. Food is not a regional industry, but a global one, and the creation of the “.FOOD” gTLD would mark the first ever common identifier of this internationally essential and diverse consumer market.

When we consider the rate at which domain registration has increased in the last ten years, resulting in overcrowding and a general lack of naming availability, we begin to see the need for industry classifications online such as “.FOOD”. “.FOOD” will not only open the door for increased online naming abilities, it will also allow consumers to easily locate specific products and services through increased search engine classifications. Further, by developing specific industry classifications such as “.FOOD” , advertisers will have increased confidence that they are reaching their target markets, thus increasing advertising revenue across the board for online businesses. 

With these thoughts in mind, we at DOT Food believe that it is essential for the food industry to become a leader in this transition. On average, there are over 100 million searches a month for the words “food” online, which result in a monthly volume of page views totaling well over 700 billion clicks. The opportunity to enhance the consumer experience while driving competition in our market is paramount and we are excited to be apart of this evolution.

Processed food sales worldwide are approximately $3.2 trillion. According to Plunkett Research, LTD: US consumers spend approximately $1 trillion annually on food. This represents nearly 10 percent of the Gross Domestic Product (GDP). The US Food Industry consists of nearly 100,000 grocery stores and supermarkets; generating nearly $500 million in food sales annually, 960,000 US restaurants & dining establishments; generating $604 billion, and employs over 16.5 million people, with approximately 960,000 of those working within restaurants. 

From farming and food production, packaging, distribution, retail and catering: the food industry touches everyone’s life in numerous ways. “.FOOD” will provide an innovative way to bond the many facets of the food industry together, while offering consumers an identifiable online resource to meet all their food related needs. 

Our areas of specialty will be extremely widespread, including, but not limited to food manufacturers, food suppliers, food producers, retail food service operators, culinary institutes, restaurant operators, catering providers, food publications and food television networks. Consumers can be confident that domains bearing the “.FOOD “ gTLD will provide them with industry specific information, up to date restaurant listings, recipes, and access to leaders in this market. 

“.FOOD” will have a positive impact on the current Internet name space by helping to advance the unique and growing concept of industry differentiation through classification. Further “.FOOD” will reap positive benefits on both registrants and consumers by creating an easy and efficient way to market and grow food related brands, while simplifying locating “food” businesses in a cyber-setting. 

In order to achieve our goals and build name recognition DOT Food, LLC will be implementing an extensive and far reaching marketing plan, focused on enhancing the value of the “.FOOD” brand name, while positioning “.FOOD” to become an industry “must –have” in assisting businesses to gain market share and exposure. 

Within six- years of the “.FOOD” launch it is our goal to register 70%+ of all food-related companies with a minimum of one “.FOOD” gtld. This achievement would solidify our mission statement and serve to differentiate the Internet in a much needed and effective way.

To do so the following marketing strategies will be put in place:

1) Build strong relationships with Registrar services in order to capture new domain registrations.
2) Create a prominent and consistent image, representative of our mission and expressed clearly through branding, advertisements, and corporate relationships.
3) Build a wide-reaching presence for “.FOOD” in the industry by creating a strong international presence through attendance at conferences appropriate to our visibility in the market. Industry tradeshow participation may include the following:
a. International Foodservice Manufacturer Conference (Las Vegas)
b. International Restaurant and Food Service Show (New York)
c. Canadian Restaurant & Food Service Show (Toronto)
d. The International Food & Drink Trade Show (London)
e. Annual Restaurant Industry Conference (Los Angeles)
f. National Restaurant Association Show (Chicago)
g. Institute of Food Technologists (Las Vegas)
h. International Fancy Food Show (Washington DC)
i. Multi-Unit Foodservice Operators Conference (Dallas)

4) Create a consistent presence in all food-related trade publications and sponsorship of well attended food-related events.

5) Secure “key” Registrants through our Founders program (described further in question 29 of this application) that will act as innovative leaders to assist us in appropriately exposing our target audience to the existence of “.FOOD”.

6) Additionally, establish corporate partnerships with the world’s largest food companies and providers, such as: 

Dole (the world’s largest producer of fruit and vegetables);

PepsiCo (PepsiCo reaches far beyond the world of soft drinks and exceeds $44 billion in annual revenue. PepsiCo owns Frito-Lay, which produces an enormous variety of snack foods, including Ruffles, Lay’s, Tostitos and Fritos brands); 

General Mills (General Mills owns Betty Crocker, Pillsbury, Yoplait and Green Giant with revenues of $14 billion annually); 

Nestle (Nestlé’s brands are wide-ranging, from the candy - Gobstoppers, Pixy Stix and Laffy Taffy, to coffee - Nescafé and Taster’s Choice. The company also owns Digiorno, California Pizza Kitchen, Hot Pockets, Lean Pockets and Tombstone. Nestlé reigns king of the international food scene); and 

Kraft (the largest food company headquartered in the United States with $40 billion in revenues. Kraft is best known for its crackers: Wheat Thins, Triscuits, Ritz, Nabisco and Cheese Nips. Most recently, Kraft has made significant inroads in the health, diet and upscale food industries).

7) Creating strong partnerships with states, cities, towns and villages in order to better promote the foods of that region or area.

For example, within six years we anticipate that Chicago.food will become the “go to” secondary domain for consumers to tap into the restaurant scene in Chicago. This model would similarly spread to the many destination cities, towns and provinces across the world. This process would create a food based tourist information center in relation to dining, proportionately enhancing tourism and entertainment in any given territory by centralizing the availability of resources for visitors.

This concept would further be enhanced by building strong relationships with the local chamber of commerce or applicable agencies in order to capture newly forming food industry businesses.

8) Build strong and lasting partnerships with farmers and agricultural organizations which are committed to the promotion of sustainable food production. Through these relationships the “.FOOD” gTLD will assist in helping to achieve market visibility for local producers and increased awareness about the importance of local agriculture.
9) Cultivate relationships with both domestic and global food related organizations. Partnerships with these organizations would increase DOT Food’s knowledge base in regards to efficiently meeting the needs of food industry consumers and business owners.

10) Increase exposure for “.FOOD” by creating a strong international presence through attendance at conferences appropriate to our visibility in the market

6) Reach out to businesses in the following food related industries to create a widespread representation of the market and build strong brand representation:

A) Grocery Stores
B) Wholesale food distributers
C) Food Banks
D) Restaurants
E) Caterers
F) Culinary Institutes
G) Food Television shows and networks
H) Trade publications
I) Chefs and other industry professionals
J) Bakeries and specialty food providers
K) Farmers markets
L) Farmers
M) Grain elevators and commodity brokers
N) Equipment suppliers and manufacturers
O) Authors and recipe distributers
P) Online information providers
Q) Clubs, bloggers and social organizations.

We intend to implement a highly focused⁄ targeted marketing blitz to the industry sub-divisions listed above, their advertising agencies, and public relations personnel in order to assist them in implementing and utilizing the “.FOOD” gTLD.

The above marketing practices will help us to provide consumers with globally diverse industry information and assist them in meeting both recreational and business related “.food” needs. 

It is our goal to provide an efficient and secure registration process by minimizing the input required by the Registrant and creating a streamlined application process. In order to do so and uphold the integrity of our mission to provide instant access to members of the food industry, DOT Food, LLC will implement the following registration guidelines and naming conventions:

1) “.FOOD” registrations will be restricted to individuals, businesses, and organizations that are active members of the Food industry. “Active” can be defined in this context as any individual, business or organization wishing to provide Food industry information, services, or products online.

2) Registrants will be asked to submit, at minimum their contact information and agree to a statement indicating that it is their intention to utilize their “.FOOD” domain for the promotion, distribution, or exchange of information, products or services directly connected to the food industry.

3) Content on all awarded “.FOOD” sites are expected to primarily represent the Registrant’s connection to the food industry. Sites will be randomly selected for review to ensure compliance with this guideline. Should Registrant’s be found in violation of this guideline, they will be notified in writing of the violation and given a 30 - day probationary period in order to correct the content deficiencies of their site. If Registrants are unable to comply with this guideline within the 30 - day probationary period, DOT Food, LLC will revoke the Registrant’s domain name and it will be returned to general availability. Should a Registrant’s domain name be revoked due to their content deficiencies, all funds paid by the Registrant to date will be considered non-refundable. DOT Food or it’s designated agent will perform all tasks related to content monitoring in order to not further burden their registrar partners.

4) Should DOT Food, LLC discover at any point that a Registrant has falsely represented themselves as an individual, business, or organization related to the food industry, their awarded domain will be immediately revoked and returned to general availability. Should a Registrant’s domain be revoked due their false representation of their industry relationship, all funds paid by the Registrant to date will be considered non-refundable. 

5) Registrant’s should understand that name availability is not guaranteed and that names will be issued on a first – come, first - served basis. Should a Registrant’s requested name be unavailable, the Registrant will be offered the option of re-wording, changing, or adapting their initial naming request until a suitable solution is found.

6) Registrants will not be allowed to register names that infringe on the legal rights of other individuals or companies, allude to criminal activities, or contain in any part racially offensive language. 

7) DOT Food, LLC reserves the right to deny, cancel, or transfer any registration or transaction (as more fully described in our Abuse Policies in question 28 below), or place any domain name(s) on registry lock, hold, or similar status, that it deems necessary ; (1) to protect the integrity and stability of the registry; (2) to comply with applicable laws, government rules or requirements, or court orders; (3) to avoid any liability, civil or criminal, on the part of DOT Food, LLC, as well as its affiliates, subsidiaries, officers, directors, and employees; (4) to correct mistakes made by the DOT Food, LLC, registry services provider, or any Registrar in connection with a domain name registration; (5) during resolution of any dispute regarding the domain; and (6) if a Registrant’s pre-authorization or payment fails; or (7) to prevent the bad faith use of a domain name that is identical to a registered trademark and being utilized to confuse users.

8) DOT Food’s registry services operator will provide thick WHOIS services that are fully compliant with RFC 3912 and with Specifications 4 and 10 of the Registry Agreement. Additionally, DOT Food will provide a Web-based WHOIS application, which will be located at www.whois.food. The WHOIS Web application will be an intuitive and easy to use application which will allow the general public to easily access registration information for each “.FOOD” site. A complete description of these services can be found in Question 26 below.
9) All Registrants awarded a “.FOOD” domain will agree to a one year minimum contract, which will need to be renewed on an annual basis. Renewal is the sole responsibility of the Registrant. Registrant’s failing to renew their awarded domains by their expiration dates will be given a 60-day renewal grace period prior to their domain being revoked and returned to general availability.

10) DOT Food, LLC is not liable or responsible in any way for any errors, omissions or any other actions by any third party (including any Registrar service) arising out of, or related to a given Registrant’s application for, registration of, renewal of, or failure to register or renew a particular domain name.

11) Through the registration process, all Registrants will be expected to designate an administrative contact for their application, which would possess all the rights granted by DOT Food, LLC or its designated agents to act in respect to the given domain including, but not limited to, managing the domain name or any services associated thereto. 

12) DOT Food, LLC will implement a reserved names policy consisting of both names DOT Food wishes to reserve for our own purposes as the registry operator and names protected by ICANN. DOT Food will respect all ICANN reserved names including, but not limited to, two letter country codes and existing TLD’s. Additionally, DOT Food, LLC will seek ICANN approval on any additional names we plan to reserve in order to appropriately secure them prior to the opening of general availability.


DOT Food, LLC will additionally implement a series of Rights Protection Mechanisms (RPM) included, but not limited to: Support for and interaction with the Trademark Clearinghouse (“Clearinghouse”), use of the Trademark Claims Service, segmented Sunrise Periods allowing for the owners of trademarks listed in the Clearinghouse to register domain names that consist of an identical match of their listed trademarks, subsequent Sunrise Periods to give trademark owners or Registrants that own the rights to a particular name the ability to block the use of such name, stringent take-down services and Uniform Dispute Resolution Policies. 

“.FOOD” was proposed for the sole purpose of unifying the food industry, and simplifying consumer search practices. In order to maintain the integrity of that mission and minimize the negative consequences to consumers and business owners the following policies will be adhered to:

a) No information collected from our registrants will be used for marketing purposes.
b) Data collected will not be traded or sold.
c) All data collected on any registrant will be available to the registrant free of charge. 
d) Registrants will be allowed to address and correct data inaccuracies as needed.
e) All data will be kept secure. 

DOT Food, LLC will strictly uphold the rules set forth in their registration guidelines in order to accurately service our Registrants and mitigate any negative consequences to consumers or Internet users.

DOT Food, LLC does not plan to offer registrations to Registrants directly. Therefore, our pricing commitments will be made within our Registry–Registrar Agreements. It is our intention that these commitments will percolate down to Registrants directly and that the contractual commitments contained within our Registry-Registrar agreements will be reflected in the retail sale process of our gTLD, thus minimizing the negative consequences that might be imposed on Registrants via the retail process.

DOT Food, LLC plans to offer bulk registration benefits to Registrars during the first 6 months of operation. Registrars wishing to purchase bulk registrations of 1,000 names or more would be offered a 5% discount at the time of purchase. Additionally, DOT Food, LLC , through our founders program will provide a 25% discount to founders participants as a participation incentive. It is possible that DOT Food, LLC would offer additional pricing benefits from time to time as relative to the market. All future pricing discounts not detailed in this application will be submitted through the appropriate ICANN channels for approval prior to introduction to the market.

No

Not Available

No

DOT Food, LLC has thoroughly reviewed ISO 3166-1 and ISO 3166-2, relevant UN documents on the standardization of geographic names, GAC correspondence relating to the reservation of geographic names in the .INFO TLD, and understands its obligations under Specification 5 of the draft Registry Agreement. DOT Food, LLC shall implement measures similar to those used to protect geographic names in the .INFO TLD by reserving and registering to itself all the geographic place names found in ISO-3166 and official country names as specified by the UN. DOT Food, LLC has already discussed this proposed measure of protecting geographic names with its registry services provider, Neustar, and has arranged for such reservation to occur as soon after delegation as is technically possible.

As with the .INFO TLD, only if a potential second-level domain registrant makes a proper showing of governmental support for country or territorial names will DOT Food, LLC will then relay this request to ICANN. At this point, DOT Food, LLC would wait for the approval of the GAC and of ICANN before proceeding to delegate the domain at issue.

23.1 Introduction 



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



23.2 Standard Technical and Business Components



Neustar will provide the highest level of service while delivering a secure, stable and comprehensive registry platform. DOT Food, LLC will use Neustarʹs Registry Services platform to deploy the ʺ.FOODʺ registry, by providing the following Registry Services (none of these services are offered in a manner that is unique to ʺ.FOODʺ): 



-Registry-Registrar Shared Registration Service (SRS)

-Extensible Provisioning Protocol (EPP)

-Domain Name System (DNS)

-WHOIS

-DNSSEC

-Data Escrow

-Dissemination of Zone Files using Dynamic Updates

-Access to Bulk Zone Files

-Dynamic WHOIS Updates

-IPv6 Support

-Rights Protection Mechanisms

-Internationalized Domain Names (IDN). [Optional should be deleted if not being offered].



The following is a description of each of the services. 



23.2.1 SRS 



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



23.2.2 EPP



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



23.2.3 DNS



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



23.2.4 WHOIS



Neustarʹs existing standard WHOIS solution will be used for the ʺ.FOODʺ. The service provides supports for near real-time dynamic updates. The design and construction is agnostic with regard to data display policy is flexible enough to accommodate any data model. In addition, a searchable WHOIS service that complies with all ICANN requirements will be provided. The following WHOIS options will be provided:



Standard WHOIS (Port 43)

Standard WHOIS (Web)

Searchable WHOIS (Web)



23.2.5 DNSSEC



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



23.2.6 Data Escrow



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



-Protect against data loss

-Follow industry best practices

-Ensure easy, accurate, and timely retrieval and restore capability in the event of a hardware failure

-Minimizes the impact of software or business failure.



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



23.2.7 Dissemination of Zone Files using Dynamic Updates



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



23.2.8 Access to Bulk Zone Files



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



23.2.9 Dynamic WHOIS Updates



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



23.2.10 IPv6 Support



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



23.2.11 Required Rights Protection Mechanisms



DOT Food, LLC, will provide all ICANN required Rights Mechanisms, including: 



-Trademark Claims Service

-Trademark Post-Delegation Dispute Resolution Procedure (PDDRP)

-Registration Restriction Dispute Resolution Procedure (RRDRP)

-UDRP

-URS

-Sunrise service.

More information is presented in the response to Question 29.



23.2.12 Internationalized Domain Names (IDN)



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



23.3 Unique Services 



DOT Food, LLC will not be offering services that are unique to ʺ.FOODʺ.



23.4 Security or Stability Concerns 



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

24.1 Introduction



DOT Food, LLC has partnered with NeuStar, Inc (ʺNeustarʺ), an experienced TLD registry operator, for the operation of the ʺ.FOODʺ Registry. The applicant is confident that the plan in place for the operation of a robust and reliable Shared Registration System (SRS) as currently provided by Neustar will satisfy the criterion established by ICANN.



Neustar built its SRS from the ground up as an EPP based platform and has been operating it reliably and at scale since 2001. The software currently provides registry services to five TLDs (.BIZ, .US, TEL, .CO and .TRAVEL) and is used to provide gateway services to the .CN and .TW registries. Neustarʹs state of the art registry has a proven track record of being secure, stable, and robust. It manages more than 6 million domains, and has over 300 registrars connected today. 

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



24.2 The Plan for Operation of a Robust and Reliable SRS



24.2.1 High-level SRS System Description



The SRS to be used for ʺ.FOODʺ will leverage a production-proven, standards-based, highly reliable and high-performance domain name registration and management system that fully meets or exceeds the requirements as identified in the new gTLD Application Guidebook. 



The SRS is the central component of any registry implementation and its quality, reliability and capabilities are essential to the overall stability of the TLD. Neustar has a documented history of deploying SRS implementations with proven and verifiable performance, reliability and availability. The SRS adheres to all industry standards and protocols. By leveraging an existing SRS platform, DOT Food, LLC is mitigating the significant risks and costs associated with the development of a new system. Highlights of the SRS include:



-State-of-the-art, production proven multi-layer design

-Ability to rapidly and easily scale from low to high volume as a TLD grows

-Fully redundant architecture at two sites

-Support for IDN registrations in compliance with all standards 

-Use by over 300 Registrars

-EPP connectivity over IPv6

-Performance being measured using 100% of all production transactions (not sampling).



24.2.2 SRS Systems, Software, Hardware, and Interoperability 



The systems and software that the registry operates on are a critical element to providing a high quality of service. If the systems are of poor quality, if they are difficult to maintain and operate, or if the registry personnel are unfamiliar with them, the registry will be prone to outages. Neustar has a decade of experience operating registry infrastructure to extremely high service level requirements. The infrastructure is designed using best of breed systems and software. Much of the application software that performs registry-specific operations was developed by the current engineering team and a result the team is intimately familiar with its operations.



The architecture is highly scalable and provides the same high level of availability and performance as volumes increase. It combines load balancing technology with scalable server technology to provide a cost effective and efficient method for scaling.



The Registry is able to limit the ability of any one registrar from adversely impacting other registrars by consuming too many resources due to excessive EPP transactions. The system uses network layer 2 level packet shaping to limit the number of simultaneous connections registrars can open to the protocol layer.



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



-The IP address of the client

-Timestamp

-Transaction Details

-Processing Time.



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



24.2.3 SRS Design



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



-Protocol Layer

-Business Policy Layer

-Database. 



Each of the layers is described below. 



24.2.4 Protocol Layer



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



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



-The registrarʹs host exchanges keys to initiates a TLS handshake session with the EPP server.

-The registrarʹs host must provide credentials to determine proper access levels.

-The registrarʹs IP address must be preregistered in the network firewalls and traffic-shapers.



24.2.5 Business Policy Layer 



The Business Policy Layer is the brain of the registry system. Within this layer, the policy engine servers perform rules-based processing as defined through configurable attributes. This process takes individual transactions, applies various validation and policy rules, persists data and dispatches notification through the central database in order to publish to various external systems. External systems fed by the Business Policy Layer include backend processes such as dynamic update of DNS, WHOIS and Billing. 



Similar to the EPP protocol farm, the SRS consists of a farm of application servers within this layer. This design ensures that there is sufficient capacity to process every transaction in a manner that meets or exceeds all service level requirements. Some registries couple the business logic layer directly in the protocol layer or within the database. This architecture limits the ability to scale the registry. Using a decoupled architecture enables the load to be distributed among farms of inexpensive servers that can be scaled up or down as demand changes.



The SRS today processes over 30 million EPP transactions daily. 



24.2.6 Database



The database is the third core components of the SRS. The primary function of the SRS database is to provide highly reliable, persistent storage for all registry information required for domain registration services. The database is highly secure, with access limited to transactions from authenticated registrars, trusted application-server processes, and highly restricted access by the registry database administrators. A full description of the database can be found in response to Question 33.



Figure 24-1 attached depicts the overall SRS architecture including network components.



24.2.7 Number of Servers



As depicted in the SRS architecture diagram above Neustar operates a high availability architecture where at each level of the stack there are no single points of failures. Each of the network level devices run with dual pairs as do the databases. For the ʺ.FOODʺ registry, the SRS will operate with 8 protocol servers and 6 policy engine servers. These expand horizontally as volume increases due to additional TLDs, increased load, and through organic growth. In addition to the SRS servers described above, there are multiple backend servers for services such as DNS and WHOIS. These are discussed in detail within those respective response sections. 



24.2.8 Description of Interconnectivity with Other Registry Systems



The core SRS service interfaces with other external systems via Neustarʹs external systems layer. The services that the SRS interfaces with include:



-WHOIS 

-DNS 

-Billing

-Data Warehouse (Reporting and Data Escrow).

 

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



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



24.2.9 WHOIS External Notifier



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



24.2.10 DNS External Notifier



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



24.2.11 Billing External Notifier



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



24.2.12 Data Warehouse



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



24.2.13 Frequency of Synchronization between Servers



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



24.2.14 Synchronization Scheme (e.g., hot standby, cold standby) 



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



24.2.15 Compliance with Specification 6 Section 1.2



The SRS implementation for ʺ.FOODʺ is fully compliant with Specification 6, including section 1.2. EPP Standards are described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. Extensible Provisioning Protocol or EPP is defined by a core set of RFCs that standardize the interface that make up the registry-registrar model. The SRS interface supports EPP 1.0 as defined in the following RFCs shown in Table 24-1 attached. 



Additional information on the EPP implementation and compliance with RFCs can be found in the response to Question 25.



24.2.16 Compliance with Specification 10



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



To properly measure the technical performance and progress of TLDs, Neustar collects data on key essential operating metrics. These measurements are key indicators of the performance and health of the registry. Neustarʹs current .biz SLA commitments are among the most stringent in the industry today, and exceed the requirements for new TLDs. Table 24-2 compares the current SRS performance levels compared to the requirements for new TLDs, and clearly demonstrates the ability of the SRS to exceed those requirements.



Their ability to commit and meet such high performance standards is a direct result of their philosophy towards operational excellence. See response to Question 31 for a full description of their philosophy for building and managing for performance.



24.3 Resourcing Plans 



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



-Development⁄Engineering

-Database Administration

-Systems Administration

-Network Engineering.



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



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



-Development⁄Engineering 19 employees

-Database Administration- 10 employees

-Systems Administration 24 employees

-Network Engineering 5 employees



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

25.1 Introduction



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



25.2 EPP Interface



Registrars are provided with two different interfaces for interacting with the registry. Both are EPP based, and both contain all the functionality necessary to provision and manage domain names. The primary mechanism is an EPP interface to connect directly with the registry. This is the interface registrars will use for most of their interactions with the registry. 



However, an alternative web GUI (Registry Administration Tool) that can also be used to perform EPP transactions will be provided. The primary use of the Registry Administration Tool is for performing administrative or customer support tasks. 

The main features of the EPP implementation are: 



-Standards Compliance: The EPP XML interface is compliant to the EPP RFCs. As future EPP RFCs are published or existing RFCs are updated, Neustar makes changes to the implementation keeping in mind of any backward compatibility issues.



-Scalability: The system is deployed keeping in mind that it may be required to grow and shrink the footprint of the Registry system for a particular TLD. 



-Fault-tolerance: The EPP servers are deployed in two geographically separate data centers to provide for quick failover capability in case of a major outage in a particular data center. The EPP servers adhere to strict availability requirements defined in the SLAs.



-Configurability: The EPP extensions are built in a way that they can be easily configured to turn on or off for a particular TLD.



-Extensibility: The software is built ground up using object oriented design. This allows for easy extensibility of the software without risking the possibility of the change rippling through the whole application. 



-Auditable: The system stores detailed information about EPP transactions from provisioning to DNS and WHOIS publishing. In case of a dispute regarding a name registration, the Registry can provide comprehensive audit information on EPP transactions.



-Security: The system provides IP address based access control, client credential-based authorization test, digital certificate exchange, and connection limiting to the protocol layer. 



25.3 Compliance with RFCs and Specifications



The registry-registrar model is described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. As shown in Table 25-1 attached, EPP is defined by the core set of RFCs that standardize the interface that registrars use to provision domains with the SRS. As a core component of the SRS architecture, the implementation is fully compliant with all EPP RFCs. 



Neustar ensures compliance with all RFCs through a variety of processes and procedures. Members from the engineering and standards teams actively monitor and participate in the development of RFCs that impact the registry services, including those related to EPP. When new RFCs are introduced or existing ones are updated, the team performs a full compliance review of each system impacted by the change. Furthermore, all code releases include a full regression test that includes specific test cases to verify RFC compliance.



Neustar has a long history of providing exceptional service that exceeds all performance specifications. The SRS and EPP interface have been designed to exceed the EPP specifications defined in Specification 10 of the Registry Agreement and profiled in Table 25-2 attached. Evidence of Neustarʹs ability to perform at these levels can be found in the .biz monthly progress reports found on the ICANN website.



25.3.1 EPP Toolkits



Toolkits, under open source licensing, are freely provided to registrars for interfacing with the SRS. Both Java and C++ toolkits will be provided, along with the accompanying documentation. The Registrar Tool Kit (RTK) is a software development kit (SDK) that supports the development of a registrar software system for registering domain names in the registry using EPP. The SDK consists of software and documentation as described below.



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



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



25.4 Proprietary EPP Extensions



 [Default Response]



The ʺ.FOODʺ registry will not include proprietary EPP extensions. Neustar has implemented various EPP extensions for both internal and external use in other TLD registries. These extensions use the standard EPP extension framework described in RFC 5730. Table 25-3 attached provides a list of extensions developed for other TLDs. Should the ʺ.FOODʺ registry require an EPP extension at some point in the future, the extension will be implemented in compliance with all RFC specifications including RFC 3735.



The full EPP schema to be used in the ʺ.FOODʺ registry is attached in the document titled EPP Schema Files.



25.5 Resourcing Plans



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



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



-Development⁄Engineering 19 employees

-Quality Assurance - 7 employees.



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

DOT Food, LLC recognizes the importance of an accurate, reliable, and up-to-date WHOIS database to governments, law enforcement, intellectual property holders, and the public as a whole, and is firmly committed to complying with all of the applicable WHOIS specifications for data objects, bulk access, and lookups as defined in Specifications 4 and 10 to the Registry Agreement and relevant RFCs.

DOT Food, LLC’s back-end registry services provider, Neustar, has extensive experience providing ICANN and RFC-compliant WHOIS services for each of the TLDs that it operates both as a Registry Operator for gTLDs, ccTLDs, and back-end registry services provider. As one of the first “thick” registry operators in the gTLD space, the WHOIS service provided by DOT Food, LLC’s registry services operator has been designed from the ground up to display as much information as required by ICANN and respond to a very stringent availability and performance requirement.

Some of the key features of DOT Food, LLC’s WHOIS services will include: 

• Fully compliant with all relevant RFCs including 3912;
• Production proven, highly flexible, and scalable (DOT Food, LLC’s back-end registry services provider has a track record of 100% availability over the past 10 years);
• Exceeds current and proposed performance specifications;
• Supports dynamic updates with the capability of doing bulk updates;
• Geographically distributed sites to provide greater stability and performance; and
• Search capabilities (e.g., IDN, registrant data) that mitigate potential forms of abuse as discussed below.
DOT Food, LLC’s registry services operator will provide thick WHOIS services that are fully compliant with RFC 3912 and with Specifications 4 and 10 of the Registry Agreement. 

DOT Food, LLC’s WHOIS service will support port 43 queries, and will be optimized for speed using an in-memory database and a master-slave architecture between SRS and WHOIS slaves. RFC 3912 is a simple text based protocol over TCP that describes the interaction between the server and client on port 43. DOT Food, LLC’s registry services operator currently processes millions of WHOIS queries per day.

In addition to the WHOIS Service on port 43, DOT Food, LLC will provide a Web-based WHOIS application, which will be located at www.whois.food. This WHOIS Web application will be an intuitive and easy to use application for the general public to use. The WHOIS Web application provides all of the features available in the port 43 WHOIS. This includes full and partial search on:
• Domain names
• Nameservers
• Registrant, Technical and Administrative Contacts
• Registrars
The WHOIS web application will also provide features not available on the port 43 service. These include:
• Extensive support for international domain names (IDN)
• Ability to perform WHOIS lookups on the actual Unicode IDN
• Display of the actual Unicode IDN in addition to the ACE-encoded name
• A Unicode to Punycode and Punycode to Unicode translator
• An extensive FAQ
• A list of upcoming domain deletions
DOT Food, LLC will also provide a searchable web-based WHOIS service in accordance with Specification 4 Section 1.8 The application will enable users to search the WHOIS directory to find exact or partial matches using any one or more of the following fields: 
• Domain name
• Contacts and registrant’s name
• Contact and registrant’s postal address, including all the sub-fields described in EPP (e.g., street, city, state or province, etc.)
• Registrar ID
• Name server name and IP address
• Internet Protocol addresses
• The system will also allow search using non-Latin character sets which are compliant with IDNA specification
The WHOIS user will be able to choose one or more search criteria, combine them by Boolean operators (AND, OR, NOT) and provide partial or exact match regular expressions for each of the criterion name-value pairs. The domain names matching the search criteria and their WHOIS information will quickly be returned to the user.
In order to reduce abuse for this feature, only authorized users will have access to the Whois search features after providing a username and password. DOT Food, LLC will provide third party access to the bulk zone file in accordance with Specification 4, Section 2 of the Registry Agreement. Credentialing and dissemination of the zone files will be facilitated through the Central Zone Data Access Provider, which will make access to the zone files in bulk via FTP to any person or organization that signs and abides by a Zone File Access (ZFA) Agreement with the registry. Contracted gTLD registries will provide this access daily and at no charge. 
DOT Food, LLC will also provide ICANN and any emergency operators with up-to-date Registration Data on a weekly basis (the day to be designated by ICANN). Data will include data committed as of 00:00:00 UTC on the day previous to the one designated for retrieval by ICANN. The file(s) will be made available for download by SFTP, unless ICANN requests other means in the future.
DOT Food, LLC’s Legal Team consisting of 3 dedicated employees, will regularly monitor the registry service provider to ensure that they are providing the services as described above. This will entail random monthly testing of the WHOIS port 43 and Web-based services to ensure that they meet the ICANN Specifications and RFCs as outlined above, if not, to follow up with the registry services provider to ensure that they do. As the relevant WHOIS will only contain DOT Food, LLC’s information, DOT Food, LLC’s WHOIS services will necessarily be in compliance with any applicable privacy laws or policies.

27.1 Registration Life Cycle



27.1.1 Introduction



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



27.1.2 Domain Lifecycle - Description



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



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



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



-OK Default status applied by the Registry.

-Inactive Default status applied by the Registry if the domain has less than 2 nameservers.

-PendingCreate Status applied by the Registry upon processing a successful Create command, and indicates further action is pending. This status will not be used in the ʺ.FOODʺ registry.

-PendingTransfer Status applied by the Registry upon processing a successful Transfer request command, and indicates further action is pending.

-PendingDelete Status applied by the Registry upon processing a successful Delete command that does not result in the immediate deletion of the domain, and indicates further action is pending.

-PendingRenew Status applied by the Registry upon processing a successful Renew command that does not result in the immediate renewal of the domain, and indicates further action is pending. This status will not be used in the ʺ.FOODʺ registry.

-PendingUpdate Status applied by the Registry if an additional action is expected to complete the update, and indicates further action is pending. This status will not be used in the ʺ.FOODʺ registry.

-Hold Removes the domain from the DNS zone.

-UpdateProhibited Prevents the object from being modified by an Update command.

-TransferProhibited Prevents the object from being transferred to another Registrar by the Transfer command.

-RenewProhibited Prevents a domain from being renewed by a Renew command.

-DeleteProhibited Prevents the object from being deleted by a Delete command. 



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



-Domain may be updated

-Domain may be deleted, either within or after the add-grace period

-Domain may be renewed at anytime during the term

-Domain may be auto-renewed by the Registry

-Domain may be transferred to another registrar. 

 

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



27.2 Registration States



27.2.1 Domain Lifecycle Registration States



As described above the ʺ.FOODʺ registry will implement a standard domain lifecycle found in most gTLD registries today. There are five possible domain states:



-Active 

-Inactive

-Locked

-Pending Transfer

-Pending Delete.



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



27.2.2 Active State



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



27.2.3 Inactive State



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



27.2.4 Locked State



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



27.2.5 Pending Transfer State



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



27.2.6 Pending Delete State



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



27.3 Typical Registration Lifecycle Activities



27.3.1 Domain Creation Process



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



1. Contact objects are created in the SRS database. The same contact object may be used for each contact type, or they may all be different. If the contacts already exist in the database this step may be skipped.



2. Nameservers are created in the SRS database. Nameservers are not required to complete the registration process; however any domain with less than 2 name servers will not be resolvable.



3. The domain is created using the each of the objects created in the previous steps. In addition, the term and any client statuses may be assigned at the time of creation.



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



27.3.2 Update Process



Registry objects may be updated (modified) using the EPP Modify operation. The Update transaction updates the attributes of the object. 



For example, the Update operation on a domain name will only allow the following attributes to be updated:



-Domain statuses

-Registrant ID

-Administrative Contact ID

-Billing Contact ID

-Technical Contact ID

-Nameservers

-AuthInfo

-Additional Registrar provided fields.



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



27.3.4 Renew Process 



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



27.3.5 Transfer Process



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



-Initiate a domain transfer

-Cancel a domain transfer

-Approve a domain transfer

- Reject a domain transfer.



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



1. The gaining (new) Registrar submits a Transfer command, which includes the AuthInfo code of the domain name.



2. If the AuthInfo code is valid and the domain is not in a status that does not allow transfers the domain is placed into pendingTransfer status



3. A poll message notifying the losing Registrar of the pending transfer is sent to the Registrarʹs message queue



4. The domain remains in pendingTransfer status for up to 120 hours, or until the losing (current) Registrar Acks (approves) or Nack (rejects) the transfer request



5. If the losing Registrar has not Acked or Nacked the transfer request within the 120 hour timeframe, the Registry auto-approves the transfer



6. The requesting Registrar may cancel the original request up until the transfer has been completed.



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



27.3.6 Deletion Process



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



27.4 Applicable Time Elements



The following section explains the time elements that are involved. 



27.4.1 Grace Periods



There are six grace periods:



-Add-Delete Grace Period (AGP)

-Renew-Delete Grace Period

-Transfer-Delete Grace Period

-Auto-Renew-Delete Grace Period

-Auto-Renew Grace Period

-Redemption Grace Period (RGP). 



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

The following describes each of these grace periods in detail.



27.4.2 Add-Delete Grace Period 



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



27.4.3 Renew-Delete Grace Period 



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



27.4.4 Transfer-Delete Grace Period 



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



27.4.5 Auto-Renew-Delete Grace Period 



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



27.4.6 Auto-Renew Grace Period 



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



27.4.7 Redemption Grace Period 



The RGP is a special grace period that enables Registrars to restore domains that have been inadvertently deleted but are still in pendingDelete status within the Redemption Grace Period. All domains enter the RGP except those deleted during the AGP. 



The RGP period is 30 days, during which time the domain may be restored using the EPP RenewDomain command as described below. Following the 30day RGP period the domain will remain in pendingDelete status for an additional five days, during which time the domain may NOT be restored. The domain is released from the SRS, at the end of the 5 day non-restore period. A restore fee applies and is detailed in the Billing Section. A renewal fee will be automatically applied for any domain past expiration.



Neustar has created a unique restoration process that uses the EPP Renew transaction to restore the domain and fulfill all the reporting obligations required under ICANN policy. The following describes the restoration process.



27.5 State Diagram



Figure 27-1 attached provides a description of the registration lifecycle. 



The different states of the lifecycle are active, inactive, locked, pending transfer, and pending delete.Please refer to section 27.2 for detailed descriptions of each of these states. The lines between the states represent triggers that transition a domain from one state to another. 



The details of each trigger are described below:



-Create:Registry receives a create domain EPP command.

-WithNS:The domain has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.

-WithOutNS:The domain has not met the minimum number of nameservers required by registry policy. The domain will not be in the DNS zone.

-Remove Nameservers: Domainʹs nameserver(s) is removed as part of an update domain EPP command. The total nameserver is below the minimum number of nameservers required by registry policy in order to be published in the DNS zone.

-Add Nameservers: Nameserver(s) has been added to domain as part of an update domain EPP command.The total number of nameservers has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.

-Delete: Registry receives a delete domain EPP command.

-DeleteAfterGrace: Domain deletion does not fall within the add grace period.

-DeleteWithinAddGrace:Domain deletion falls within add grace period.

-Restore: Domain is restored.Domain goes back to its original state prior to the delete command.

-Transfer: Transfer request EPP command is received.

-Transfer Approve⁄Cancel⁄Reject:Transfer requested is approved or cancel or rejected.

-TransferProhibited: The domain is in clientTransferProhibited and⁄or serverTranferProhibited status. This will cause the transfer request to fail.The domain goes back to its original state.

-DeleteProhibited: The domain is in clientDeleteProhibited and⁄or serverDeleteProhibited status.This will cause the delete command to fail.The domain goes back to its original state.



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



27.5.1 EPP RFC Consistency



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



27.6 Resources



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



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



-Development⁄Engineering 19 employees

-Registry Product Management 4 employees



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

General Statement of Policy

Abuse within the registry will not be tolerated. DOT Food, LLC will implement very strict policies and procedures to minimize abusive registrations and other activities that have a negative impact on Internet users. DOT Food, LLC’s homepages will provide clear contact information for its Abuse Team, and in accordance with ICANN policy DOT Food, LLC shall host NIC.FOOD, providing access to .FOOD’s WhoIs services, the Abuse Policy, and contact information for the Abuse Team.

Anti-Abuse Policy

DOT Food, LLC will implement in its internal policies and its Registry-Registrar Agreements (RRAs) that all registered domain names in the TLD will be subject to a Domain Name Anti-Abuse Policy (“Abuse Policy”).

The Abuse Policy will provide DOT Food, LLC with broad power to suspend, cancel, or transfer domain names that violate the Abuse Policy. DOT Food, LLC will publish the Abuse Policy on its home website at NIC.FOOD and clearly provide DOT Food, LLC’s Point of Contact (“Abuse Contact”) and its contact information. This information shall consist of, at a minimum, a valid e-mail address dedicated solely to the handling of abuse complaints, and a telephone number and mailing address for the primary contact. DOT Food, LLC will ensure that this information will be kept accurate and up to date and will be provided to ICANN if and when changes are made. 

In addition, with respect to inquiries from ICANN-Accredited registrars, the Abuse Contact shall handle requests related to abusive domain name practices.

Inquiries addressed to the Abuse Contact will be routed to DOT Food, LLC’s Legal Team who will review and if applicable remedy any Complaint regarding an alleged violation of the Abuse Policy as described in more detail below. DOT Food, LLC will catalog all abuse communications in its CRM software using a ticketing system that maintains records of all abuse complaints indefinitely. Moreover, DOT Food, LLC shall only provide access to these records to third parties under limited circumstances, such as in response to a subpoena or other such court order or demonstrated official need by law enforcement.

The Abuse Policy will state, at a minimum, that DOT Food, LLC reserves the right to deny, cancel, or transfer any registration or transaction, or place any domain name(s) on registry lock, hold, or similar status, that it deems necessary to ; (1) to protect the integrity and stability of the registry; (2) to comply with applicable laws, government rules or requirements, or court orders; (3) to avoid any liability, civil or criminal, on the part of DOT Food, LLC, as well as its affiliates, subsidiaries, officers, directors, and employees; (4) to correct mistakes made by the DOT Food, LLC, registry services provider, or any registrar in connection with a domain name registration; (5) during resolution of any dispute regarding the domain; and (6) if a Registrant’s pre-authorization or payment fails; or (7) to prevent the bad faith use of a domain name that is identical to a registered trademark and being used to confuse users.

The Abuse Policy will define the abusive use of domain names to include, but not be limited to, the following activities:

• Illegal or fraudulent actions: use of the DOT Food, LLC’s or Registrarʹs services to violate the laws or regulations of any country, state, or infringe upon the laws of any other jurisdiction, or in a manner that adversely affects the legal rights of any other person;
• Spam: use of electronic messaging systems from email addresses from domains in the TLD to send unsolicited bulk messages. The term applies to e-mail spam and similar abuses such as instant messaging spam, mobile messaging spam, and the spamming of Web sites and Internet forums;
• Trademark and Copyright Infringement: DOT Food, LLC will take great care to ensure that trademark and copyright infringement does not occur within the .FOOD TLD. DOT Food, LLC will employ notice and takedown procedures based on the provisions of the Digital Millennium Copyright Act (DMCA) ;
• Phishing: use of counterfeit Web pages within the TLD that are designed to trick recipients into divulging sensitive data such as usernames, passwords, or financial data;
• Pharming: redirecting of unknowing users to fraudulent Web sites or services, typically through DNS hijacking or poisoning;
• Willful distribution of malware: dissemination of software designed to infiltrate or damage a computer system without the ownerʹs informed consent. Examples include, without limitation, computer viruses, worms, keyloggers, and trojan horses.
• Fast flux hosting: use of fast-flux techniques to disguise the location of Web sites or other Internet services, or to avoid detection and mitigation efforts, or to host illegal activities. Fast-flux techniques use DNS to frequently change the location on the Internet to which the domain name of an Internet host or name server resolves. Fast flux hosting may be used only with prior permission of DOT Food, LLC;
• Botnet command and control: services run on a domain name that are used to control a collection of compromised computers or ʺzombies,ʺ or to direct denial-of-service attacks (DDoS attacks);
• Distribution of pornography;
• Illegal Access to Other Computers or Networks: illegally accessing computers, accounts, or networks belonging to another party, or attempting to penetrate security measures of another individualʹs system (often known as ʺhackingʺ). Also, any activity that might be used as a precursor to an attempted system penetration (e.g., port scan, stealth scan, or other information gathering activity);
• Domain Kiting⁄Tasting: registration of domain names to test their commercial viability before returning them during a Grace Period;
• High Volume Registrations⁄Surveying: registration of multiple domain names in order to warehouse them for sale or pay-per-click websites in a way that can impede DOT Food, LLC from offering them to legitimate users or timely services to other subscribers;
• Geographic Name: registering a domain name that is identical to a Geographic Name, as defined by Specification 5 of the Registry Agreement;
• Inadequate Security: registering and using a domain name to host a website that collects third-party information but does not employ adequate security measures to protect third-party information in accordance with that geographic area’s data and financial privacy laws;
• Front Running: registrars mining their own web and WhoIs traffic to obtain insider information with regard to high-value second-level domains, which the registrar will then register to itself or an affiliated third party for sale or to generate advertising revenue;
• WhoIs Accuracy: Intentionally inserting false or misleading Registrant information into the TLD’s WhoIs database in connection with the bad faith registration and use of the domain in question;
• WhoIs Misuse: abusing access to the WhoIs database by using Registrant information for data mining purposes or other malicious purposes;
• Fake Renewal Notices; misusing WhoIs Registrant information to send bogus renewal notices to Registrants on file with the aim of causing the Registrant to spend unnecessary money or steal or redirect the domain at issue.

Domain Anti-Abuse Procedure

DOT Food, LLC will provide a domain name anti-abuse procedure modeled after the DMCA’s notice-and-takedown procedure.

At all times, DOT Food, LLC will publish on its home website at NIC.FOOD the Abuse Policy and the contact information for the Abuse Contact. Inquiries addressed to the Point of Contact will be addressed to and received by DOT Food, LLC’s Legal Time who will review and if applicable remedy any Complaint regarding an alleged violation of the Abuse Policy. DOT Food, LLC will catalog all abuse communications and provide them to third parties only under limited circumstances, such as in response to a subpoena or other such court order or demonstrated official need by law enforcement.

Any correspondence (“Complaint”) from a complaining party (“Complainant”) to the Abuse Contact will be ticketed in DOT Food, LLC’s CRM software and relayed to DOT Food, LLC’s Abuse Team. A member of DOT Food, LLC’s Abuse Team will then send an email to the Complainant within forty-eight (48) hours of receiving the Complaint confirming receipt of the email and that DOT Food, LLC will notify the Complainant of the results of the Complaint within ten (10) days of receiving the Complaint.

DOT Food, LLC’s Abuse Team will review the Complaint and give it a “quick look” to see if the Complaint reasonably falls within an abusive use as defined by the Abuse Policy. If not, the Contact will write an email to the Complainant within thirty-six (36) hours of sending the confirmation email that the subject of the complaint clearly does not fall within one of the delineated abusive uses as defined by the Abuse Policy and that DOT Food, LLC considers the matter closed.

If the quick look does not resolve the matter, DOT Food, LLC’s Abuse Team will give the Complaint a full review. Any Registrant that has been determined to be in violation of DOT Food, LLC policies shall be notified of the violation of such policy and their options to cure the violation. 
Such notification shall state:
1) the nature of the violation;
2) the proposed remedy to the violation;
3) the time frame to cure the violation; and
4) the Registry’s options to take subsequent action if the Registrant does not cure the violation.
If an abusive use is determined DOT Food, LLC’s Abuse Team will alert it’s Registry services team to immediately cancel the resolution of the domain name. DOT Food, LLC’s Abuse Team will immediately notify the Registrant of the suspension of the domain name, the nature of the complaint, and provide the Registrant with the option to respond within ten (10) days or the domain will be canceled.
If the Registrant responds within ten (10) business days, it’[s response will be reviewed by the DOT Food, LLC’s Abuse Team for further review. If DOT Food, LLC’s Abuse Team is satisfied by the Registrant’s response that the use is not abusive, DOT Food, LLC’s Abuse Team will submit a request by the registry services provider to reactivate the domain name. DOT Food, LLC’s Abuse Team will then notify the Complainant that its complaint was ultimately denied and provide the reasons for the denial. If the Registrant does not respond within ten (10) business days, DOT Food, LLC will notify the registry services team to cancel the abusive domain name.

This Anti-Abuse Procedure will not prejudice either party’s election to pursue another dispute mechanism, such as URS or UDRP.

With the resources of DOT Food, LLC’s registry services personnel, DOT Food, LLC can meet its obligations under Section 2.8 of the Registry Agreement where required to take reasonable steps to investigate and respond to reports from law enforcement and governmental and quasi-governmental agencies of illegal conduct in connection with the use of its TLD. The Registry will respond to legitimate law enforcement inquiries within one (1) business day from receiving the request. Such response shall include, at a minimum, an acknowledgement of receipt of the request, questions, or comments concerning the request, and an outline of the next steps to be taken by Application for rapid resolution of the request. 

In the event such request involves any of the activities which can be validated by DOT Food, LLC and involves the type of activity set forth in the Abuse Policy, the sponsoring registrar is then given forty-eight (48) hours to investigate the activity further and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 48-hour period (i.e., is unresponsive to the request or refuses to take action), DOT Food, LLC will place the domain on “serverHold”.

Maintenance of Registration Criteria

If a Registrant previously awarded the “.FOOD” domain ceases to be registered with a Secretary of State or legally applicable jurisdiction, such Registrant will be required to forfeit the assigned “.FOOD” domain at their designated renewal date.
If DOT Food, LLC discovers that a Registrant wrongfully applied for and was awarded a “.FOOD” domain, then such “.FOOD” will be immediately forfeited to DOT Food, LLC. 
If a Registrant previously awarded a “.FOOD” domain is dissolved and⁄or forfeited for any reason, then such “.FOOD” domain will be forfeited to DOT Food, LLC at their designated renewal time; unless such Registrant takes all reasonable steps to become reinstated and such Registrant is reinstated within six months of being dissolved and⁄or forfeited. 
If a Registrant previously awarded the “.FOOD” domain is administratively dissolved by the Secretary of State or legally applicable jurisdiction, then such “.FOOD” will be forfeited to DOT Food, LLC at their designated renewal time, unless such Registrant is reinstated within six months of being administratively dissolved.
A Registrant’s “Active” Status will be verified annually. Any Registrant not considered “Active” by the definition listed above in question 18 will be given a probationary warning, allowing time for the Registrant to restore itself to “Active” Status. If the Registrant is unable to restore itself to “Active” status within the defined probationary period, their previously assigned “.FOOD” will be forfeited. In addition, DOT Food, LLC’s definition of “Active” may change in accordance with the policies of the Secretaries of State.
Orphan Glue Removal

As the Security and Stability Advisory Committee of ICANN (SSAC) rightly acknowledges, although orphaned glue records may be used for abusive or malicious purposes, the “dominant use of orphaned glue supports the correct and ordinary operation of the DNS.” See http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf. 

While orphan glue often supports correct and ordinary operation of the DNS, we understand that such glue records can be used maliciously to point to name servers that host domains used in illegal phishing, bot-nets, malware, and other abusive behaviors. Problems occur when the parent domain of the glue record is deleted but its children glue records still remain in the DNS. Therefore, when DOT Food, LLC has written evidence of actual abuse of orphaned glue, DOT Food, LLC will take action to remove those records from the zone to mitigate such malicious conduct. 

DOT Food, LLC’s registry service operator will run a daily audit of entries in its DNS systems and compare those with its provisioning system. This serves as an umbrella protection to make sure that items in the DNS zone are valid. Any DNS record that shows up in the DNS zone but not in the provisioning system will be flagged for investigation and removed if necessary. This daily DNS audit serves to not only prevent orphaned hosts but also other records that should not be in the zone. 

In addition, if either DOT Food, LLC or its registry services operator becomes aware of actual abuse on orphaned glue after receiving written notification by a third party through its Abuse Contact or through its customer support, such glue records will be removed from the zone.

WhoIs Accuracy

DOT Food, LLC will provide WhoIs accessibility in a reliable, consistent, and predictable fashion in order to promote Whois accuracy. The Registry will adhere to port 43 WhoIs Service Level Agreements (SLAs), which require that port 43 WHOIS service be highly accessible and fast. 

DOT Food, LLC will offer thick WhoIs services, in which all authoritative WhoIs data—including contact data—is maintained at the registry. DOT Food, LLC will maintain timely, unrestricted, and public access to accurate and complete WhoIs information, including all data objects as specified in Specification 4. Moreover, prior to the release of any domain names, DOT Food, LLC’s registrar will provide DOT Food, LLC with an authorization code to verify eligible Registrants provide accurate Registrant contact information. 

In order to further promote WhoIs accuracy, DOT Food, LLC will offer a mechanism whereby third parties can submit complaints directly to the DOT Food, LLC (as opposed to ICANN or the sponsoring Registrar) about inaccurate or incomplete WhoIs data. Such information shall be forwarded to the registrar, who shall be required to address those complaints with their Registrants. Thirty days after forwarding the complaint to the registrar, DOT Food, LLC will examine the current WhoIs data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, DOT Food, LLC reserves the right to cancel or suspend the applicable domain name(s) should DOT Food, LLC determine that the domains are being used in a manner contrary to DOT Food, LLC’s abuse policy. 

 DOT Food shall also require authentication and verification of all Registrant data. DOT Food shall verify, contact information, e-mail address, and, to the best of its abilities, determine whether address information supplied is accurate. Second-level domains in the TLD shall not be operational unless two (2) out of three (3) of the above authentication methods have been satisfied.

DOT Food, LLC will also maintain historical databases of Registrants and associated information which have provided inaccurate WhoIs information. DOT Food, LLC will endeavor to use this database to uncover patterns of suspicious registrations which DOT Food, LLC shall then flag for further authentication or for review of the Registrant’s use of the domain in question to ensure Registrant’s use is consonant with DOT Food, LLC’s abuse policy.

In addition, DOT Food, LLC’s Abuse Team shall on its own initiative, no less than twice per year, perform a manual review of a random sampling of domain names within the applied-for TLD to test the accuracy of the WhoIs information. Although this will not include verifying the actual information in the WHOIS record, DOT Food, LLC will be examining the WHOIS data for prima facie evidence of inaccuracies. In the event that such evidence exists, it shall be forwarded to the registrar, who shall be required to address those complaints with their Registrants. Thirty days after forwarding the complaint to the registrar, the DOT Food, LLC will examine the current WhoIs data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, DOT Food, LLC reserves the right to suspend the applicable domain name(s) should DOT Food, LLC determine that the Registrant is using the domain in question in a manner contrary to DOT Food, LLC’s abuse policy. DOT Food, LLC shall also reserve the right to report such recalcitrant registrar activities directly to ICANN.

Abuse Prevention and Mitigation – Domain Name Access

All domain name Registrants will have adequate controls to ensure proper access to domain functions.

In addition to the above, all domain name Registrants in the applied-for TLD will be required to name at least two (2) unique points of contact who are authorized to request and⁄or approve update, transfer, and deletion requests. The points of contact must establish strong passwords with the registrar that must be authenticated before a point of contact will be allowed to process updates, transfer, and deletion requests. Once a process update, transfer, or deletion request is entered, the points of contact will automatically be notified when a domain has been updated, transferred, or deleted through an automated system run by DOT Food, LLC’s registrar. Authentication of modified Registrant information shall be accomplished 48 Hours.

DOT Food, LLC is committed to implementing strong and integrated Rights Protection Mechanisms (RPM). Use of domain names that infringe upon the legal rights of others in the TLD will not be tolerated. The nature of such uses creates security and stability issues for the registry, registrars, and registrants, as well as for users of the Internet in general. DOT Food, LLC will protect the legal rights of others by implementing RPMs and anti-abuse policies backed by robust responsiveness to complaints and requirements of DOT Food, LLC’s registrars.

Trademark Clearinghouse

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

Utilizing the Clearinghouse, all operators of new gTLDs must offer: (i) a Sunrise registration service for at least 30 days during the pre-launch phase giving eligible trademark owners an early opportunity to register second-level domains in new gTLDs; and (ii) a Trademark Claims Service for at least the first 60 days that second-level registrations are open. The Trademark Claims Service is intended to provide clear notice to a potential registrant of the rights of a trademark owner whose trademark is registered in the Clearinghouse.

Sunrise A Period

DOT Food, LLC will offer segmented Sunrise Periods. The initial Sunrise Period will last [minimum 30 days] for owners of trademarks listed in the Clearinghouse to register domain names that consist of an identical match of their listed trademarks. All domain names registered during the Sunrise Period will be subject to DOT Food, LLC’s domain name registration policy, namely, that all registrants be validly registered corporations and all applied-for domains will only be awarded the .FOOD domain that matches or includes a substantial part of the Registrant’s legal name. DOT Food, LLC will assign its Rights Protection Team; which is lead by our Director of Legal and Policy and further supported by two dedicated employees to receive and authenticate all Sunrise Registrations. 

DOT Food, LLC’s registrar will ensure that all Sunrise Registrants meet sunrise eligibility requirements (SERs), which will be verified by Clearinghouse data. The proposed SERs include: (i) ownership of a mark that is (a) nationally or regionally registered and for which proof of use, such as a declaration and a single specimen of current use – was submitted to, and validated by, the Trademark Clearinghouse; or (b) that have been court-validated; or (c) that are specifically protected by a statute or treaty currently in effect and that was in effect on or before 26 June 2008, (ii) optional registry elected requirements concerning international classes of goods or services covered by registration; (iii) representation that all provided information is true and correct; and (iv) provision of data sufficient to document rights in the trademark. 

Upon receipt of the Sunrise application, DOT Food, LLC will issue a unique tracking number to the Registrar, which will correspond to that particular application. All applications will receive tracking numbers regardless of whether they are complete. Applications received during the Sunrise period will be accepted on a first-come, first-served basis and must be active corporations in good standing before they may be awarded the requested domain, or able to proceed to auction. Upon submission of all of the required information and documentation, registrar will forward the information to DOT Food, LLC’s [RPM Team] for authentication. DOT Food, LLC’s [RPM Team] will review the information and documentation and verify the trademark information, and notify the potential registrant of any deficiencies. If a registrant does not cure any trademark-related deficiencies and⁄or respond by the means listed within one (1) week, DOT Food, LLC will notify its registrar and the domain name will be released for registration. 
DOT Food, LLC will incorporate a Sunrise Dispute Resolution Policy (SDRP). The SRDP will allow challenges to Sunrise Registrations by third parties for a ten-day period after acceptance of the registration based on the following four grounds: (i) at time the challenged domain name was registered, the registrant did not hold a trademark registration of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; (ii) the domain name is not identical to the mark on which the registrant based its Sunrise registration; (iii) the trademark registration on which the registrant based its Sunrise registration is not of national or regional effect or the trademark had not been court-validated or protected by statute or treaty; or (iv) the trademark registration on which the domain name registrant based its Sunrise registration did not issue on or before the effective date of the Registry Agreement and was not applied for on or before ICANN announced the applications received.

After receiving a Sunrise Complaint, DOT Food, LLC’s [RPM Team] will review the Complaint to see if the Complaint reasonably asserts a legitimate challenge as defined by the SDRP. If not, DOT Food, LLC’s [RPM Team] will send an email to the Complainant within thirty-six (36) hours of sending the confirmation email that the subject of the complaint clearly does not fall within one of the delineated grounds as defined by the SDRP and that DOT Food, LLC considers the matter closed.

If the domain name is not found to have adequately met the SERs, DOT Food, LLC’s [RPM Team] will alert the registrar and registry services provider to immediately suspend the resolution of the domain name. Thereafter, DOT Food, LLC’s [RPM Team] will immediately notify the Sunrise Registrant of the suspension of the domain name, the nature of the complaint, and provide the registrant with the option to respond within ten (10) days to cure the SER deficiencies or the domain name will be canceled. 

If the registrant responds within ten (10) business days, its response will be reviewed by DOT Food, LLC’s [RPM Team] to determine if the SERs are met. If DOT Food, LLC’s [RPM Team] is satisfied by the registrant’s response, DOT Food, LLC’s [RPM Team] will submit a request to the registrar and the registry services provider to unsuspend the domain name. DOT Food, LLC’s [RPM Team] will then notify the Complainant that its complaint was ultimately denied and provide the reasons for the denial.

Names secured as described through the Sunrise AT⁄AD processes will result in the registration of resolving domain names at the registry. Names reserved through the Sunrise B process will not result in resolving domain name at DOT Food, LLC. Rather, these names will be reserved and blocked from live use. The applied for string will resolve to an informational page informing visitors that the name is unavailable for registration and reserved from use. 
Applications that fit the following criteria will be considered during the Sunrise A period: Applicant owns and operates an existing domain name in another gTLD or ccTLD, in connection with eligible commerce and satisfies the registration requirements described in Section 1. 
Sunrise B
Applications that fit the following criteria will be considered during the Sunrise B period:
a) Applicant holds valid trademark registrations or owns rights to a particular name and wishes to block the use of such name. 
b) The Applicant must seek to block a name that corresponds to the entire text of its trademark or the complete textual component of a graphical or compound trademark. Certain variances are permitted for trademarks containing spaces or special characters that are not available for domain names.
Any entity, applying for blocks under Sunrise B as a non-member of the sponsored community cannot apply for names in the TLD.

Founder’s Program
Applications for the Founder’s Program will be accepted after the close of the Sunrise Periods. Potential registrants should understand that certain expectations, as described herein will accompany the issuance of a domain name under the Founder’s Program and all registrations resulting from this program will be required to follow the below listed guidelines, which will be further described in their Program Agreement: 
a) Registrants awarded a domain through the Founder’s Program must use their best efforts to launch a .FOOD website within 30 days of signing the Program Agreement.
b) In addition, each registrant will be required to issue a press release announcing the launch of their .FOOD Founder Website, concurrent with the launch of their .FOOD Founder Website, said press release must be approved by DOT Food, LLC; 
c) Founder’s websites should be kept good working order, with unique, meaningful content, user-friendly interfaces, and broad user appeal, for the duration of the License Term, 
d) Founders are expected to proactively market and promote .FOOD gTLD in a manner that is likely to produce widespread awareness of the unique advantages gained through the .FOOD string. 
e) Founders are expected to participate in reasonable joint marketing initiatives with DOT Food, LLC or its Agents, these would be discussed and mutually agreed upon, given the unique circumstances of each marketing venture.
f) Founders will allow DOT Food, LLC to use in good faith Founder’s name, likeness, trademarks, logos, and Application contents (other than Confidential Information,) as well as other Founder information and content as may be mutually agreed, in DOT Food, LLC’s marketing, promotional and communications materials. 
g) Founders through our founders program will provide a 25% discount to founders participants as a participation incentive. It is possible that DOT Food, LLC would offer additional pricing benefits from time to time as relative to the market.
DOT Food, LLC will randomly verify compliance of the above listed expectations and have the right to revoke any Founder’s site, should they be deemed non-compliant. 

Landrush
Landrush is a limited time opportunity for companies that want to secure a high value .FOOD name for a small fee (above the basic registration cost). The landrush period will last 30 days. Applications will be accepted and evaluated to determine if they meet the requirements for registration. At the end of the Landrush period domain names with only one application will be awarded directly to the Applicant. Domain names with two or more applications will proceed to a closed mini auction, between the respective Applicants, where the highest bidder wins.

General Availability Period
Applicants must meet registration requirements.
Names will be awarded on a first-come, first serve basis which is determined as of the time of the initial request, not when authentication occurs.

Domain Name Contentions
Name contentions will arise when both a Sunrise A and Sunrise B application are submitted for the same name, the following actions will be taken to resolve the contention.
a) Both Applicants will be notified of the contention and the Sunrise A Applicant will be given first right to either register their requested domain or withdraw their application. A domain applied for under Sunrise A will, all else being equal, receive priority over the identical domain applied for under Sunrise B. Sunrise A names get priority over Sunrise B names. 
b) If the Sunrise A Applicant chooses to register their name regardless of the contention, then the Sunrise B Applicant may choose to pursue further action independently of DOT Food, LLC to contest the name. 
c) If two Sunrise A Applicants apply for the same domain name (i.e., Delta Airlines and Delta Faucet both seek to be awarded the use of DELTA.FOOD) then DOT Food, LLC will notify both Applicants of the contention and proceed to an auction process as described in Section 9.
d) If a Sunrise A Applicant and a Landrush Applicant apply for the same domain name, the Sunrise A Applicant, all else being equal will have priority over the Landrush Applicant.
e) If two Sunrise B Applicants apply for the same domain name (i.e., Delta Airlines and Delta Faucet, both seek to block the use of DELTA. FOOD), then DOT Food, LLC will accept both applications as valid and block the use of the indicated domain.
 
Appeal of Rejected Sunrise Applications
An Applicant can file a request for reconsideration within 10 days of the notification of DOT Food, LLC’s rejection. Reconsideration can be requested by completing a reconsideration form and filing a reconsideration fee with DOT Food, LLC. Forms, fee information, and process documentation will be available on the DOT Food, LLC website. Upon receipt of the reconsideration form and the corresponding fee, DOT Food, LLC or its Agents will re-examine the application, and notify the Registrant of all findings or additional information needed. The Request for Reconsideration must be submitted through the Registrant’s registrar, and a reconsideration fee must be paid to DOT Food, LLC.

Auctions
Sunrise A names found to be in contention as described above will result in Auction. DOT Food, LLC plans to have a qualified third party conduct our auction processes, therefore the rules contained in this document are subject to change based on the selection of an auctioneer: 
a) When your auction account is created, it will be assigned a unique bidder alias in order to ensure confidential bidding. The bidder alias will not reflect any information about your account. You may change your bidder alias to a name of your choosing but once set, it cannot be changed again.
b) All auction participants are expected to keep their account information current, throughout the auction process. 
c) Auction participants will receive up to date communication from the auctioneer as the auction progresses, bidding status changes, or issues arise.
d) Bidding
i) Auctions will follow a standard process flow: scheduled (upcoming), open and closed. 
ii) You will receive an “Auction Scheduled” notice at least ten (10) days prior to the scheduled auction start date. You will receive an “Auction Start” notice on the auction start date, which will indicate that you may begin placing bids through the interface. Once closed, the auction is complete and if you are the winning bidder, you will proceed to the payment process.
iii) If you choose to bid for a particular domain and you are the highest bidder at the end of an auction, you are obligated to complete the transaction and pay the Auctioneer the amount of your winning bid. Carefully consider your bids prior to placing them - bids are not retractable under any circumstances.
iv) If no bids are placed on a particular domain, the Registry will register the domain on behalf of the first customer (in the respective phase) to submit an application through a registrar. 
e) Extensions
i) A normal auction period is anticipated to last a minimum of 7 (seven) days. However, in the event of significant auction activity, an auction close may extend during the last twenty-four (24) hours of scheduled operation to better need the volume of the auction.
ii) Auction extensions are meant to provide a mechanism that is fair for bidders in all time zones to respond to being outbid.
iii) An auction extension will occur whenever the auction lead changes in the last twenty four (24) hours of the schedule of an auction. The close will be revised to reflect a new closing time set at twenty four (24) hours after the change in auction lead occurred. Essentially, this means that a winning maximum bid has to remain unchallenged for a period of twenty four (24) hours before the auction will close.
iv) It is important to note that extensions are not simply based on the auction value changing since this could occur as a result of proxy bidding where the same bidder retains their lead. In this case, the maximum bid has not changed, the leader has not changed and therefore no extension will occur.
f) Payment Default
In the event that you as the winning bidder decide not to honor your payment obligations (or in the event of a reversal of payment or a charge back by a credit card company or other payment provider) on any outstanding balance, the Registry has the right to cancel any⁄all of your winning registrations for any .FOOD domain name, regardless of whether they have been paid for or not. You do not have the right to “pick and choose” the names you wish to keep or not keep. Winning an auction creates an obligation to remit payment. Failure to remit payment is a breach of your agreement.. You will lose any previously won domains and will no longer be allowed to bid on any current or future auctions sponsored by DOT Food, LLC. Participants are encouraged therefore to consider carefully each bid submitted as any bid could be a winning bid.
Trademark Claims Service

DOT Food, LLC will offer a Trademark Claims Service indefinitely to provide maximum protection and value to rights holders. The Trademark Claims Service will be monitored and operated by DOT Food, LLC’s RPM Team that will receive all communications regarding the Trademark Claims Service and catalog them. DOT Food, LLC’s registrar will review all domain name requests to determine if they are an identical match of a trademark filed with the Trademark Clearinghouse. A domain name will be considered an identical match when the domain name consists of the complete and identical textual elements of the mark, and includes domain names where (a) spaces contained within a mark that are either replaced by hyphens (and vice versa) or omitted; (b) certain special characters contained within a trademark are spelled out with appropriate words describing it (e.g., @ and &); and (c) punctuation or special characters contained within a mark that are unable to be used in a second-level domain name are either (i) omitted or (ii) replaced by spaces, hyphens or underscores. Domain names that are plural forms of a mark, or that merely contain a mark, will not qualify as an identical match.

If the registrar determines that a prospective domain name registration is identical to a mark registered in the Trademark Clearinghouse, the registrar will be required to email a “Trademark Claims Notice” (Notice) in English to the protective registrant of the domain name and copy DOT Food, LLC’s RPM Team The Notice will provide the prospective registrant information regarding the trademark referenced in the Trademark Claims Notice to enhance understanding of the Trademark rights being claimed by the trademark holder. The Notice will be provided in real time without cost to the prospective registrant. 

After receiving the notice, the registrar will provide the prospective registrant five (5) days to reply to the Trademark Claims Service with a signed document that specifically warrants that: (i) the prospective registrant has received notification that the mark is included in the Clearinghouse; (ii) the prospective registrant has received and understood the notice; and (iii) to the best of the prospective registrant’s knowledge the registration and use of the requested domain name will not infringe on the rights that are the subject of the notice. If the warranty document satisfies these requirements, the registrar will effectuate the registration and notify DOT Food, LLC’s RPM Team. 

After the effectuation of a registration that is identical to a mark listed in the Trademark Clearinghouse, the registrar will provide clear notice to the trademark owner consisting of the domain name that has been registered and copy DOT Food, LLC’s RPM Team. The trademark owner then has the option of filing a Complaint under the Uniform Domain Name Dispute Resolution Policy (UDRP) or the Uniform Rapid Suspension System (URS). 

Uniform Rapid Suspension System (URS)

DOT Food, LLC will specify in the Registry Agreement, all RRAs, and all Registration Agreements used in connection with the TLD that it and its registrars will abide by all decisions made by panels in accordance with the Uniform Rapid Suspension System (URS). DOT Food, LLC’s RPM Team will receive all URS Complaints and decisions, and will notify its registrar to suspend all registrations determined by a URS panel to be infringing within a commercially reasonable time of receiving the decision. DOT Food, LLC’s RPM Team will catalog all abuse communications, but only provide them to third-parties under limited circumstances, such as in response to a subpoena or other such court order or demonstrated official need by law enforcement.

Uniform Domain Name Dispute Resolution Policy (UDRP)

DOT Food, LLC will specify in the Registry Agreement, all Registry-Registrar Agreements, and Registration Agreements used in connection with the TLD that it will promptly abide by all decisions made by panels in accordance with the Uniform Domain Name Dispute Resolution Policy (UDRP). DOT Food, LLC’s RPM Team will receive all UDRP Complaints and decisions, and will notify its registrar to cancel or transfer all registrations determined to by a UDRP panel to be infringing within ten (10) business days of receiving the decision. DOT Food, LLC’s [RPM Team] will catalog all abuse communications, but only provide them to third-parties under limited circumstances, such as in response to a subpoena or other such court order or demonstrated official need by law enforcement.

Proven Registrars

In order to reduce abusive registrations and other activities that affect the legal rights of others, DOT Food, LLC will only contract with ICANN-accredited registrars. The registrar, according to the RRA, will not be able to register any domain names, thus eliminating the possibility of front-running. 

Pre-Authorization and Authentication

Registrant authentication shall occur in accordance with the registration eligibility criteria and the Anti-Abuse Policy for .FOOD as set forth in Question 28. 

The verification process is designed to prevent a prospective registrant from providing inaccurate or incomplete data, such that, if necessary, the registrant can be readily contacted regarding an infringing use of its site; indeed, the process (including verification of a registrant’s certificate of incorporation) is designed to ensure that only qualified members of the community are permitted to register in the TLD. 


Thick WhoIs

DOT Food, LLC will include a thick WhoIs database as required in Specification 4 of the Registry agreement. A thick WhoIs provides numerous advantages including a centralized location of registrant information, the ability to more easily manage and control the accuracy of data, and a consistent user experience. 

Grace Period

If a Registrant previously awarded a .FOOD domain is dissolved and⁄or forfeited for any reason, then such .FOOD domain will be forfeited to DOT Food, LLC at their designated renewal time; unless such Registrant takes all reasonable steps to become reinstated and such Registrant is reinstated within six months of being dissolved and⁄or forfeited. 

Takedown Procedure

DOT Food, LLC will provide a Takedown Procedure modeled after the Digital Millennium Copyright Act’s notice-and-takedown procedure.

At all times, DOT Food, LLC will publish on its home website at NIC.FOOD contact information for receiving rights protection complaints (Complaint) from rights holders, including but not limited to trademark and copyright Complaints. Complaints will be addressed to and received by DOT Food, LLCs RPM Team who will catalogue and ticket in DOT Food, LLC’s CRM software and review as outlined herein. DOT Food, LLC will catalog all rights protection communications and only provide them to third parties under limited circumstances, such as in response to a subpoena or other such court order or demonstrated official need by law enforcement.

Any Complaint from a rights holder will be relayed to DOT Food, LLC’s RPM Team. A member of DOT Food, LLC’s RPM Team will then send an email to the Complainant within forty-eight (48) hours of receiving the Complaint confirming receipt of the email, and that DOT Food, LLC will notify the Complainant of the results of the Complaint within (10) days of receiving the Complaint.

After sending the confirmation email, DOT Food, LLC’s RPM Team will review the Complaint. If DOT Food, LLC or its registrar determines that the registration was in bad faith, DOT Food, LLC or its registrar may cancel or suspend the resolution of the domain name. Bad faith registration includes, but is not limited to, the registration of a domain identical to a registered trademark where the registrant has proceeded with registration after receipt of a Clearinghouse notice, as described above. 

If the registrant responds within ten (10) business days, its response will be reviewed by the DOT Food, LLC’s RPM Team If DOT Food, LLC’s RPM Team is satisfied by the registrant’s response that the content has been taken down or is not infringing, DOT Food, LLC’s RPM Team will unsuspend the domain name. DOT Food, LLC’s RPM Team will then notify the Complainant that its complaint was ultimately denied and provide the reasons for the denial. If the registrant does not respond within ten (10) business days, DOT Food, LLC or its registrar may cancel or suspend the resolution of the domain name.

This Takedown Procedure will not prejudice any party’s election to pursue another dispute mechanism, such as URS or UDRP, as set forth in DOT Food, LLC’s response to Question 28.

30.(a).1 Security Policies



DOT Food, LLC and our back-end operator, Neustar recognize the vital need to secure the systems and the integrity of the data in commercial solutions. The ʺ.FOODʺ registry solution will leverage industry-best security practices including the consideration of physical, network, server, and application elements. 

Neustarʹs approach to information security starts with comprehensive information security policies. These are based on the industry best practices for security including SANS (SysAdmin, Audit, Network, Security) Institute, NIST (National Institute of Standards and Technology), and CIS (Center for Internet Security). Policies are reviewed annually by Neustarʹs information security team.



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



1. Summary of the security policies used in the registry operations

2. Description of independent security assessments

3. Description of security features that are appropriate for ʺ.FOODʺ

4. List of commitments made to registrants regarding security levels



All of the security policies and levels described in this section are appropriate for the ʺ.FOODʺ registry.



30.(a).2 Summary of Security Policies 



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



-The policies for internal users and our clients to ensure the safe, organized and fair use of information resources.

-The rights that can be expected with that use. 

-The standards that must be met to effectively comply with policy.

-The responsibilities of the owners, maintainers, and users of Neustarʹs information resources.

-Rules and principles used at Neustar to approach information security issues



The following policies are included in the Program:



1. Acceptable Use Policy

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



2. Information Risk Management Policy

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



3. Data Protection Policy 

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



4. Third Party Policy

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



5. Security Awareness and Training Policy

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



6. Incident Response Policy

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



7. Physical and Environmental Controls Policy

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



8. Privacy Policy

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



9. Identity and Access Management Policy

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



10. Network Security Policy

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



11. Platform Security Policy

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



12. Mobile Device Security Policy

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



13. Vulnerability and Threat Management Policy

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



14. Monitoring and Audit Policy

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



15. Project and System Development and Maintenance Policy

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



30.(a).3 Independent Assessment Reports



Neustar IT Operations is subject to yearly Sarbanes-Oxley (SOX), Statement on Auditing Standards #70 (SAS70) and ISO audits. Testing of controls implemented by Neustar management in the areas of access to programs and data, change management and IT Operations are subject to testing by both internal and external SOX and SAS70 audit groups. Audit Findings are communicated to process owners, Quality Management Group and Executive Management. Actions are taken to make process adjustments where required and remediation of issues is monitored by internal audit and QM groups.

External Penetration Test is conducted by a third party on a yearly basis. As authorized by Neustar, the third party performs an external Penetration Test to review potential security weaknesses of network devices and hosts and demonstrate the impact to the environment. The assessment is conducted remotely from the Internet with testing divided into four phases:



-A network survey is performed in order to gain a better knowledge of the network that was being tested

-Vulnerability scanning is initiated with all the hosts that are discovered in the previous phase

-Identification of key systems for further exploitation is conducted

-Exploitation of the identified systems is attempted.



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



30.(a).4 Augmented Security Levels and Capabilities



There are no increased security levels specific for ʺ.FOODʺ. However, Neustar will provide the same high level of security provided across all of the registries it manages. 

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

 

-Include annual independent review of information security practices 

-Include annual external penetration tests by a third party 

-Conform to the ISO 9001 standard (Part of Neustarʹs ISO-based Quality Management System)

-Are aligned to Information Technology Infrastructure Library (ITIL) and CoBIT best practices 

-Are aligned with all aspects of ISO IEC 17799

-Are in compliance with Sarbanes-Oxley (SOX) requirements (audited annually)

-Are focused on continuous process improvement (metrics driven with product scorecards reviewed monthly).



A summary view to Neustarʹs security policy in alignment with ISO 17799 can be found in section 30.(a).5 below.



30.(a).5 Commitments and Security Levels 



The ʺ.FOODʺ registry commits to high security levels that are consistent with the needs of the TLD. These commitments include:



Compliance with High Security Standards



-Security procedures and practices that are in alignment with ISO 17799

-Annual SOC 2 Audits on all critical registry systems

-Annual 3rd Party Penetration Tests 

-Annual Sarbanes Oxley Audits



Highly Developed and Document Security Policies



-Compliance with all provisions described in section 30.(b) and in the attached security policy document.

-Resources necessary for providing information security

-Fully documented security policies

-Annual security training for all operations personnel



High Levels of Registry Security



-Multiple redundant data centers

-High Availability Design

-Architecture that includes multiple layers of security

-Diversified firewall and networking hardware vendors

-Multi-factor authentication for accessing registry systems

-Physical security access controls

-A 24x7 manned Network Operations Center that monitors all systems and applications

-A 24x7 manned Security Operations Center that monitors and mitigates DDoS attacks

-DDoS mitigation using traffic scrubbing technologies