Application number: 1-1976-9220 for 1589757 Alberta Ltd.

1589757 Alberta Ltd.

4036078985

4138129574

Mr. FAISAL PREMJI

CEO

4036078985

faisal@semantic.net

Mr. IRFAAN PREMJI

VP

5198514565

irfaan@semantic.net

CORPORATION

ALBERTA BUSINESS CORPORATIONS ACT

Not Available

FAISAL PREMJI
CEO

FAISAL PREMJI
CEO

FAISAL PREMJI
CEO

place

Not Available

Applicant has conducted technical analysis on the applied-for string, and concluded that there are no known potential operational or rendering issues associated with the string.
The following sections discuss the potential operational or rendering problems that can arise, and how Applicant will mitigate them.
Compliance and Interoperability
The applied-for string conforms to all relevant RFCs, as well as the string requirements set forth in Section 2.2.1.3.2 of the Applicant Guidebook.
Mixing Scripts
If a domain name label contains characters from different scripts, it has a higher likelihood of encountering rendering issues. If the mixing of scripts occurs within the top-level label, any rendering issue would affect all domain names registered under it. If occurring within second level labels, its ill effects are confined to the domain names with such labels.
All characters in the applied-for gTLD string are taken from a single script. In addition, Applicant IDN policies are deliberately conservative and compliant with the ICANN Guidelines for the Implementation of IDN Version 3.0. Specifically, Applicant does not allow mixed-script labels to be registered at the second level, except for languages with established orthographies and conventions that require the commingled use of multiple scripts, e.g. Japanese.
Interaction Between Labels
Even with the above issue appropriately restricted, it is possible that a domain name composed of labels with different properties such as script and directionality may introduce unintended rendering behavior.
Applicant adopts a conservative strategy when offering IDN registrations. In particular, it ensures that any IDN language tables used for offering IDN second level registrations involve only scripts and characters that would not pose a risk when combined with the top level label.
Immature Scripts
Scripts or characters added in Unicode versions newer than 3.2 (on which IDNA2003 was based) may encounter interoperability issues due to the lack of software support.
Applicant does not currently plan to offer registration of labels containing such scripts or characters.
Other Issues
To further contain the risks of operation or rendering problems, Applicant currently does not offer registration of labels containing combining characters or characters that require IDNA contextual rules handling. It may reconsider this decision in cases where a language has a clear need for such characters.
Applicant understands that the following may be construed as operational or rendering issues, but considers them out of the scope of this question. Nevertheless, it will take reasonable steps to protect registrants and Internet users by working with vendors and relevant language communities to mitigate such issues.
- missing fonts causing string to fail to render correctly; and
- universal acceptance of the TLD;

18 (a) Describe the mission⁄purpose of your proposed gTLD.
The applied-for TLD .PLACE is being established to accomplish the following mission and purpose:
To establish an online extension that by virtue of its semantic meaning and its open, unrestrictive and secure attributes, will be a viable generic, alternative to other gTLDs and ccTLDs; improve accessibility, usability and utility of the DNS; enhance user experience; creating a sustainable, competitive advantage through differentiation with a focus on innovation, business model diversification and customer service; protecting intellectual property as well as preventing malicious activity. 
Under this mission the TLD will be operated as a critical public resource in an open, responsible, stable and secure manner with the highest level of technical security resources and mechanisms that are aligned with technical advancement and innovation. 

The objective of 1589757 Alberta Ltd. (DotPlace) is to apply and launch the .PLACE TLD given the popularity of the term “place” that strongly relates to human navigation instincts. DotPlace will operate the TLD in a consistent manner with the following principles: stewardship, integrity, social responsibility, ICANN and Internet community involvement, transparency, standards compliance and development, entrepreneurship and innovation.
DotPlace has developed its mission statement with the primary objective of serving the interests of its registrants and Internet users while incorporating enhanced safeguards to protect intellectual property and prevent fraudulent or malicious activity by bad actors.
The mission⁄purpose is consistent with ICANN’s Affirmation of Commitments (AoC) including:
- “ensuring accountability, transparency and the interests of global Internet users” in regards to security, “enhancing the operational stability, reliability, resiliency, security, and global interoperability of the DNS” and “promoting competition, consumer trust, and consumer choice” while “adequately addressing consumer protection, malicious abuse, and rights protection issues” (http:⁄⁄www.icann.org⁄en⁄about⁄agreements⁄aoc⁄affirmation-of-commitments-30sep09-en.htm). 
Registry Mission⁄Purpose Guiding Principles: 
STANDARDS COMPLIANCE, SECURITY, RESILIENCY, AND STABILITY
The DNS Registry provider for the TLD, CentralNIC, is a market leader and innovator on the Internet. Details of technical and operational capabilities matching the TLD’s mission are provided in responses to questions #23-44. 
The TLD will meet all minimum standard ICANN requirements and will be operated in a secure, resilient and stable manner.
COMPETITION, INNOVATION, FAIRNESS, AND CONSUMER CHOICE
Prospective registrants identifying themselves with the generic TLD can register domains if they agree to the TLD’s terms and its mission. No registrant eligibility requirements are established thereby providing an open and fair registration process that gives registrants an advantage in regards to brand positioning and registering the domain of their choice that might not otherwise be available under existing TLDs or ccTLDs.
As a result, the TLD will enhance competition at both the registry, registrar and registrant level. 

INTELLECTUAL PROPERTY PROTECTION AND TRUST
DotPlace has incorporated policies to protect intellectual property, fight malicious conduct and ensure domains are allocated in fair methods.
Phased launches provide (i) rights holders a first-come allocation method in the Sunrise phase (ii) auctions if there are multiple domain inquiries during Landrush phase, and (iii) first-come, first serve open registrations for all registrants. All registrants must agree to the .PLACE Anti-Abuse policy to prevent malicious behavior and bad actors along with all other standard TLD registration policies. 
Dispute mechanisms and compliance efforts will provide an added level of intellectual property protection and trust.

18b - Benefits to Registrants, Internet Users and Others
The .PLACE TLD will benefit the registrants and Internet users by providing a generic, secure, and clearly identifiable domain name, especially if their preferred domain name selection is not currently available under existing TLDs of their choice. These benefits are detailed below.
DotPlace will provide a secure, differentiated and branded domain to be registered and used by the global Internet community in an appropriate manner under strict Anti-Abuse policy. DotPlace and its back-end operator will be customer-centric and will provide a secure technical platform and be accountable to its registrants in terms of openness, transparency, usability, net neutrality, responsibility towards registrants and Internet users, and respect towards governments, policy creators and regulatory bodies.

SECURE OPEN gTLD
The primary goal of the .PLACE TLD is to add branded value to its registrants and Internet users, while also meeting current DNS standards via its reliable, resilient and stable technical registry system as well as its intellectual protection policies and associated compliance functions. The TLD will generate trust and attract developers interested in developing the next wave of innovative applications by establishing a secure TLD with advanced technological standards and with appropriate use and anti-abuse policies that meet DNS technical operational criteria. Historically speaking, application developers have incorporated protection mechanisms for some TLDs, and it is not possible to predict the future application developer activities or actions with a potential large number of new gTLDs in the marketplace. . DotPlace is aware of this risk and will communicate its established policies and operational functionalities to the operators involved in the application-layer of the DNS to ensure usability a streamlined user experience and the wide acceptance of the TLD across a wide spectrum of applications and search engines.
PREMIUM DOMAINS
DotPlace’s objective is to use the premium names under the TLD to:
- Generate immediate income to DotPlace via auctions. Income will be used to build new innovative services to benefit registrants and Internet users.
- Develop some sites to promote the TLD’s mission.
- Engage in partnerships to develop dedicated .PLACE destinations offering differentiated value to registrants and Internet users.
18b (ii) The primary differentiation of the TLD that is non-existent in the current TLD space corresponds to the semantic, generic meaning of the extension that is synonymous with Internet presence referring to “places” while also representing a broad registrant base. The TLD will provide competition to existing TLDs that Internet users might otherwise prefer by providing value-added innovations as described earlier, enhancing security, hold itself accountable to registrants and Internet users. Secure TLD management is established following the registration policies and compliance measures as described below and in responses to questions #23-44. Every element of Registry operations meets all technical requirements, especially in regards to protocol implementations, hardware, security access requirements, anti-abuse policies and monitoring. 
Registrants will be able to register the domain of choice under the .PLACE TLD offering a differentiated, branded alternative to existing TLDs and provide the necessary competition to spur innovation in the domain space to cater to the rapidly changing Internet environment and unmet needs, including the evolving demands of the web such as increased usage due to a growing Internet population and the proliferation of web-enabled devices, especially mobile. The TLD will enhance competition at the registrant, registry and registrar level. The .PLACE TLD will compete with existing TLDs and be aligned with the U.S Federal Communications Commission following principles affirming that “free and open competition benefits consumers and the global community by ensuring lower prices, new and better products and services, and greater consumer choice than occurs under monopoly conditions. A competitive market promotes innovation by rewarding producers that invent, develop, and introduce new and innovative products and production processes. By doing so, the wealth of the society as a whole is increased (FCC, Competition in Telecommunications Services, www.fcc.gov⁄connectglobe⁄sec5.html).”

The launch of the .PLACE TLD will help increase competition in the TLD space, expand consumer choice in TLD options and stimulate innovation in business model diversification, improved customer service and lower pricing in the domain industry, while remaining committed to continually developing its infrastructure to enhance registry operations to adapt to the growing needs of Internet users.

18b (iii) The primary objective of DotPlace is to enhance the online user experience by providing an new open, relevant and highly desired term extension as a TLD. 
DotPlace will incorporate enhanced safeguards against abuse and by providing optimally secure technical operations, including adopting operational policies that take action against any illegitimate use or malicious abuse in relation to the TLD. 
If a domain is used for any illegitimate use or violates the use policy it will be taken down. Repeat offenders will be placed on a special monitoring list by DotPlace and in extreme cases will be denied domain name registrations under the TLD.
While domains cannot be validated with 100% accuracy, registrants are required to follow continuously updated registration and anti-abuse policies (such as those resulting from an ICANN consensus policy or registry best practice requirements). DotPlace will provide high level of data security robustness and privacy and confidentiality protection.
Other key objectives surrounding user experience involve adhering to industry standards in relation to privacy protection, registry-registrar agreements, offering robust levels of data escrow and security, providing accessibility, usability, network neutrality and superior customer service, and leading the DNS space.

18b (iv) To reach the abovementioned goals, DotPlace has implemented various measures and enhanced safeguards under the TLD. 
The policies were developed to take advantage the latest technology in DNS security, registry resources and best practices based on experience from previous ICANN TLD launches; and they are established to provide a higher level of security level for domains than what is considered standard in regards to TLDs. DotPlace will work on an ongoing basis with rights holders, law enforcement agencies, government entities, security focused DNS technical stakeholders, registrars and partners to ensure that the TLD management operations exceed expectations.
Aside from the below described policies, the .PLACE TLD will be launched with all standard TLD registration rules included, such as incorporating grace-periods when domains expire. See response to question #27 for the TLD lifecycle. 
DotPlace will adhere to all ICANN mandated rights protection mechanisms and consensus policies in accordance with the ICANN Registry Agreement. See response to question #28 and #29 for rights protection mechanisms and intellectual property protections under .PLACE.
RESERVATION PROTECTION: second-level names will be reserved per ICANN requirements, including country-territory names (see response #22) and names reserved for registry operations.
INNOVATIVE PREMIUM NAMES RESERVATION: Premium Name reservations will be incorporated to (i) promote the TLD through DotPlace’s existing activities, (ii) to develop strategic partnerships or alliances to introduce innovative services, facilitate information sharing and allow equal and open access to both registrants and Internet users, and (iii) to generate additional revenues to be used to create innovative services to benefit registrants and Internet users.
RIGHTS PROTECTION AND NOTIFICATIONS SYSTEM: 
• Trademark Clearing House will be implemented in accordance to ICANN specifications.
• Introductory Sunrise phase to allow trademark holders who fulfill ICANN’s trademark criteria access to register their respective domain(s) under the TLD after they have been legally validated.

THREE RESTRICTED LAUNCH PHASES in the following order (i) Sunrise Phase aimed at protecting trademark holders (ii) Landrush Phase and (iii) General Availability Phase to ensure all Internet users have the ability to register and access domains across the TLD.
Multiple applications for the same domain in either the Sunrise or Landrush Phase will be decided upon via a mini-auction after each phase is completed. In the General Availability Phase domains are available to be registered on a first-come-first-serve basis.

ANTI-ABUSE POLICY for all registrants under the TLD; incorporated in the registration agreement for all domain registrants. It is in place to prevent malicious use of domains which can lead to security and stability issues for the registry, registrars, registrants, and general users of the Internet. It is detailed in response to question #28. The primary goal of the policy is to allow registrars and DotPlace to take down domains in the case malicious activity occurring using a domain under the TLD.
DotPlace will take advice from law-enforcement agencies, government stakeholders, technical bodies focused on DNS security to always ensure that the TLD is managed in the most optimal manner using the most appropriate resources and means, while working towards adopting exemplary practices and best practices recommendations such as those highlighted in the “Five C’s” WHOIS validation model presentation at the Costa Rica ICANN meeting (http:⁄⁄costarica43.icann.org⁄meetings⁄sanjose2012⁄presentation-whois-validation-model-12mar12-en.pdf). 

COMPLIANCE AND ENFORCEMENT
DotPlace will take proactive and reactive measures to enforce its TLD policies. Proactive measures are taken at the time of registration. Reactive measures are implemented via compliance and enforcement mechanisms as well as through dispute processes.
Alleged violation of the UDRP⁄URS shall be enforced under the provisions contained therein.
The UDRP and URS are required in the registrarsʹ registration agreements with registrants, and proceedings must be brought by interested third parties in accordance with the associated policies and procedures to dispute resolution providers.
DotPlace will conduct random compliance efforts across all domains registered under the TLD. Periodically a sample of domain registrations will be verified to assure compliance enforcement with all established TLD requirements.
If a Registrant is found out of compliance with any of the TLD requirements the registrant will be notified that the domain will be placed on registry lock. The registrant will be given a reasonable time period to address and fix the compliance matter or else the domain will be terminated.
Repeat offenders will be placed on a special monitoring list that DotPlace staff will conduct additional compliance checks against. DotPlace holds the right to prohibit repeat offenders from registering domains for a period of time or indefinitely.
DotPlace will review all gTLD policies and processes in comparison against the .PLACE registration requirements on a regular basis with involvement from relevant stakeholders to support its mission benefiting registrants and Internet users in regards to domain availability focusing on security, stability, accessibility, customer service, privacy, net neutrality, innovation while adopting registry best practices and exceeding minimum ICANN technical and policy standards. Any registry services modifications will naturally go through the ICANN established processes.

18b (v) The TLD will use best practices in regards to privacy and data protection. The TLD’s back-end service provider will administer specific WHOIS protections per the response to question #26, promote WHOIS accuracy per the response to question #28, and prevent WHOIS abuse by considering various best practices recommendations such as those highlighted in the “Five C’s” WHOIS validation model presentation at the Costa Rica ICANN meeting to avoid abuse of WHOIS (http:⁄⁄costarica43.icann.org⁄meetings⁄sanjose2012⁄presentation-whois-validation-model-12mar12-en.pdf). 
The TLD is established to enable its registrants to better brand and identify them online with the domain name of choice under a broad, generic TLD. As a result, the .PLACE TLD will provide competition to existing registries and expand consumer choice for registrants. DotPlace will provide this unique, branded opportunity for enhanced visibility. The domain registration services and Premium Name development will be designed to respect the privacy of personally identifiable and confidential information, including respecting all applicable laws.

18b (vi) In order to meet the benefits described in responses to 18b (i-v) DotPlace is committed to continue to conduct and expand upon its activities in its corresponding space, including registrar channels. A primary goal with the TLD is to expand consumer choice, increase competition and be a catalyst for innovative services under the TLD. All-inclusive participation, openness and transparency are critical components to the Registry’s purpose. 
DotPlace will also educate its registrar channels to inform registrants about the branding opportunity under the TLD as well as other innovative services provided. Furthermore, DotPlace will use traditional advertising, PR, social media and its official site to increase awareness of the benefits of .PLACE to registrants and Internet users. Partners, resellers and other supply chain beneficiaries will also be leveraged to help the outreach efforts to educate potential registrants and help them understand the benefits of the .PLACE TLD and the policies surrounding it.

18c) Eliminate Social Costs
(i) DotPlace’s plan for launching the TLD is to offer a robust, cost-effective means for registrants to assert their identities online under a generic domain targeted for a broad registrant base. DotPlace is committed to launching and managing the TLD in a responsible manner to serve registrants with optimal efficiency, which will also be in the best interest of the global Internet community. Furthermore, the incorporation of enhanced safeguards will not only serve registrants and Internet users, they will help protect intellectual property and prevent malicious activity. 
The DotPlace core mission is serving its registrants and the public interest. This includes minimizing and eliminating social costs; establishing a better financial income stream and fostering innovative business models; promoting competition to reduce prices and creating differentiated value; establishing improved innovative services; sharing related information and resources; cater to the unmet needs of its registrants; adapt to any technological advances and changes in the environment relating to the Internet; to provide exceptional service and enhanced safeguards and security.
REGISTRATION PRICING
DotPlace will adopt a moderate, competitive pricing point taking into consideration:
1. As indicated by the McAfee’s 2011 security report (http:⁄⁄us.mcafee.com⁄en-us⁄local⁄docs⁄MTMW_Report.pdf), pricing is one of the most influential factors taken into consideration by registrants aiming to conduct malicious activity and abuse. Domains with low registration prices have a higher likelihood for abuse. Prices in the middle and higher end ensure there is a slight barrier to entry to reduce the number of registrants offering low quality content.
2. A benchmark analysis of comparable gTLDs and ccTLDs existing today.
3. Assuring pricing is optimally set taking into consideration registrant price sensitivity and price elasticity of the domain’s demand.
4. Acknowledging that optimal pricing is directly related to how registrants perceive the domain’s value. DotPlace will continuously innovate its business model and offerings to not only be competitive in the TLD space but also to drive user adoption of the TLD as an industry standard for its niche audience by offering a unique value proposition.
In the two initial launch phases multiple applications will be resolved via auction. During the general availability stage, domains will be allocated in a first come-first serve basis.
DotPlace will implement a competitive pricing structure based on criteria mentioned earlier to avoid abusive behavior and through benchmark analysis of comparable gTLDs and ccTLDs existing today, including addressing price sensitivity concerns by offering a unique value proposition to registrants. Registration prices ultimately are at the discretion of ICANN-accredited registrars, but it is in their financial interest to price competitively to attract higher registration volumes that can complement other domain-related services such as hosting.
DotPlace will offer an affordable domain that can help an entity build a uniquely branded and exclusive presence online, while ensuring the cost of the domain is optimally priced to prevent malicious behavior and abuse traditionally experienced in low-priced domains. Depending on the cost of doing business, market conditions, external environmental forces and other economic factors, DotPlace may from time to time increase or lower the wholesale price in accordance with the provisions of Section 2.10 of the New gTLD Registry Agreement.
ii) 
DotPlace might choose to offer cost benefits in relation to advantageous pricing, introductory discounts, or bulk discounts if there is a need to substantially increase domain sales to meet financial and operational registry needs, especially in the situation where the most likely projected registration volume is not met. In that situation, DotPlace will consider implementing targeted marketing campaigns with registrar channels that would include discounted prices.
Otherwise, DotPlace does not have specific plans for advantageous pricing, introductory pricing, nor plans for any bulk registration discounts.
iii) 
DotPlace will not offer long term or permanent contracts (beyond that of the maximum term of 10 years) for domains. DotPlace has carefully considered the needs of the market in setting its prices on its services. Any price escalations or reductions will be reasonably justified and managed in accordance with the provisions of Section 2.10 of the New gTLD Registry Agreement.
DotPlace will allow the use of parked pages but domains will be subject to the anti-abuse restrictions described in response to question 18b. 

No

Not Available

No

The range of second level names protected by Specification 5 of the Registry Operator contract is extensive (approx. 2,000 strings are blocked). This list resulted from a lengthy process of collaboration and compromise between members of the ICANN community, including the Governmental Advisory Committee. Namecheap believes this list represents a healthy balance between the protection of national naming interests and free speech on the Internet. 

Namecheap does not intend to block second level names beyond those detailed in Specification 5. Should a geographic name be registered in this TLD and used for illegal or abusive activity Namecheap will remedy this by applying the array of protections implemented in this TLD. 

Namecheap will strictly adhere to the relevant provisions of Specification 5 of the New gTLD Agreement. Specifically:

1. All two-character labels will be initially reserved, and released only upon agreement between Namecheap and the relevant government and country code manager.
2. At the second level, country and territory names will be reserved at the second and other levels according to these standards:
2.1. Short form (in English) of country and territory names documented in the ISO 3166-1 list;
2.2. Names of countries and territories as documented by the United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardization of Geographical Names, Part III Names of Countries of the World; and
2.3. The list of United Nations member states in six official UN languages, as prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names.

Namecheap will initially reserve country and territory names at the second level and at all other levels within the TLD. Namecheap supports this requirement by using the following internationally recognized lists to develop a comprehensive master list of all geographic names that are initially reserved:

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

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

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

4. The 2-letter alpha-2 code of all country and territory names contained on the ISO 3166-1 list, including all reserved and unassigned codes 

This comprehensive list of names will be ineligible for registration. Only in consultation with the GAC and ICANN would Namecheap develop a proposal for release of these reserved names, and seek approval accordingly. Namecheap understands governmental processes require time-consuming, multi-department consultations. Accordingly, we will apportion more than adequate time for the GAC and its members to review any proposal we provide.

Namecheap recognizes the potential use of country and territory names at the third level. We will address and mitigate attempted third-level use of geographic names as part of our operations.

Namecheaps list of geographic names will be transmitted to Registrars as part of the onboarding process and will also be made available to the public via the TLD website. Changes to the list are anticipated to be rare; however, Namecheap will regularly review and revise the list as government authorities make changes.

For purposes of clarity the following will occur for a domain that is reserved by the registry:
1. An availability check for a domain in the reserved list will result in a “not available” status. The reason given will indicate that the domain is reserved.
2. An attempt to register a domain name in the reserved list will result in an error.
3. An EPP info request will result in an error indicating the domain name was not found.
4. Queries for a reserved name in the WHOIS system will display information indicating the reserved status and indicate it is not registered nor is available for registration.
5. Reserved names will not be published or used in the zone in any way.
6. Queries for a reserved name in the DNS will result in an NXDOMAIN response.

Q23 - Registry Services

 Note to Reader:

1589757 Alberta Ltd. is affiliated with Namecheap, Inc. 
Namecheap, Inc. is the financial backer of 1589757 Alberta Ltd. and therefore, Namecheap resources and the financial statements and capital of Namecheap, Inc. are referenced in the application.


Applicant has chosen CentralNic as the registry infrastructure provider for the TLD. Please see Appendix 23.1 for the acceptance letter from CentralNic. Any information regarding technical and operational capability of the proposed the TLD registry (answers to questions 23 – 44) therefore refers to CentralNic’s registry infrastructure systems. 
Applicant and CentralNic hereby explicitly confirm that all registry services stated below are engineered and will be provided in a manner compliant with the new gTLD Registry Agreement, ICANN consensus policies (such as Inter-Registrar Transfer Policy and AGP Limits Policy) and applicable technical standards. Except for the registry services described above, no other services will be provided by the Registry that relate to (i) receipt of data from registrars concerning registrations of domain names and name servers; (ii) provision to registrars of status information relating to the zone servers for the TLD;(iii) dissemination of TLD zone files; (iv) operation of the Registry zone servers; or (v) dissemination of contact and other information concerning domain name server registrations in the TLD as required by the Registry Agreement. 
There are no other products or services, except those described above that the Registry Operator will provide (i) because of the establishment of a Consensus Policy, or (ii) by reason of Applicant being designated as the Registry Operator. 
Any changes to the registry services that may be required at a later time in the course of the Applicant operating the registry will be addressed using rules and procedures established by ICANN such as the Registry Services Evaluation Policy. 
Applicant proposes to operate the following registry services, utilising CentralNicʹs registry system: 

23.1. Receipt of Data From Registrars 
CentralNic will operate a Shared Registry System (SRS) for the TLD. The SRS consists of a database of registered domain names, host objects and contact objects, accessed via an Extensible Provisioning Protocol (EPP) interface, and a web based Registrar Console. Registrars will uses these interfaces to provide registration data to the registry. 
The SRS will be hosted at CentralNicʹs primary operations centre in London, UK. The primary operations centre comprises a resilient, fault-tolerant network infrastructure with multiple high quality redundant links to backbone Internet carriers. The primary operations centre is hosted in Level 3ʹs flagship European data centre and boasts significant physical security capabilities, including 24x7 patrols, CCTV and card-based access controls. 
CentralNicʹs existing SRS system currently supports more than 250,000 domain names managed by over 1,500 registrars. CentralNic has effective and efficient 24x7 customer support capabilities to support these domain names and registrars, and this capability will be expanded to meet the requirements of the TLD and provide additional capacity during periods of elevated activity (such as during Sunrise periods). 
The SRS and EPP systems are described more fully in §24 and §25. The Registrar Console is described in §31. 
EPP is an extensible protocol by definition. Certain extensions have been put in place to comply with the new gTLD registry agreement, ICANN Consensus Policies and technical standards: 
1. Registry Grace Period Mapping - compliant with RFC 3915 
2. DNSSEC Security Extensions - compliant with RFC 5910 
3. Launch Phase Extension - will be only active during the Sunrise phase, before the SRS opens for the general public. The extension is compliant with the current Internet Draft https:⁄⁄github.com⁄wil⁄EPP-Launch-Phase-Extension-Specification⁄blob⁄master⁄draft-tan-epp-launchphase.txt 
More information on EPP extensions is provided in §25. 
The SRS will implement and support all ICANN Consensus Policies and Temporary Policies, including: 
• Uniform Domain Name Dispute Resolution Policy 
• Inter-Registrar Transfer Policy 
• Whois Marketing Restriction Policy 
• Restored Names Accuracy Policy 
• Expired Domain Deletion Policy 
• AGP Limits Policy 

23.2. Provision to Registrars of Status Information Relating to the Zone Servers 
CentralNic will operate a communications channel to notify registrars of all operational issues and activity relating to the DNS servers which are authoritative for the TLD. This includes notifications relating to: 
1. Planned and unplanned maintenance; 
2. Denial-of-service attacks; 
3. unplanned network outages; 
4. delays in publication of DNS zone updates; 
5. security incidents such as attempted or successful breaches of access controls; 
6. significant changes in DNS server behaviour or features; 
7. DNSSEC key rollovers. 
Notifications will be sent via email (to preregistered contact addresses), with additional notifications made via an off-site maintenance site and via social media channels. 

23.3. Dissemination of TLD Zone Files 
CentralNic will make TLD zone files available via the Centralized Zone Data Access Provider according to specification 4, section 2 of the Registry Agreement. 
Applicant will enter into an agreement with any Internet user that will allow such user to access an Internet host server or servers designated by Applicant and download zone file data. The agreement will be standardized, facilitated and administered by a Centralized Zone Data Access Provider (the “CZDA Provider”). Applicant will provide access to zone file data using the file format described in Section 2.1.4 of Specification 4 of the New gTLD Registry Agreement. 
Applicant, through the facilitation of the CZDA Provider, will request each user to provide it with information sufficient to correctly identify and locate the user. Such user information will include, without limitation, company name, contact name, address, telephone number, facsimile number, email address, and the Internet host machine name and IP address. 
Applicant will provide the Zone File FTP (or other Registry supported) service for an ICANN-specified and managed URL for the user to access the Registry’s zone data archives. Applicant will grant the user a non-exclusive, non-transferable, limited right to access Applicant’s Zone File FTP server, and to transfer a copy of the top-level domain zone files, and any associated cryptographic checksum files no more than once per 24 hour period using FTP, or other data transport and access protocols that may be prescribed by ICANN. 
Applicant will provide zone files using a sub-format of the standard Master File format as originally defined in RFC 1035, Section 5, including all the records present in the actual zone used in the public DNS. 
Applicant, through CZDA Provider, will provide each user with access to the zone file for a period of not less than three (3) months. Applicant will allow users to renew their Grant of Access. 
Applicant will provide, and CZDA Provider will facilitate, access to the zone file to user at no cost. 

23.4. Operation of the Registry Zone Servers 
The TLD zone will be served from CentralNicʹs authoritative DNS system. This system has operated at 100% service availability since 1996 and has been developed into a secure and stable platform for domain resolution. Partnering with Community DNS, CentralNicʹs DNS system includes nameservers in more than forty cities, on five continents. The DNS system fully complies with all relevant RFCs and all ICANN specifications, and has been engineered to ensure resilience and stability in the face of denial-of-service attacks, with substantial overhead and geographical dispersion. 
The DNS system is described further in §35. 

23.5. Dissemination of Contact and Other Information Concerning Domain Name Server Registrations 
CentralNic will operate a Whois service for the TLD. The Whois service will provide information about domain names, contact objects, and name server objects stored in the Shared Registry System via a port-43 service compliant with RFC 3912. The Whois service will permit interested parties to obtain information about the Registered Name Holder, Administrative, Technical and Billing contacts for domain names. The Whois service will return records in a standardised format which complies with ICANN specifications. 
CentralNic will provide access to the Whois service at no cost to the general public. 
CentralNicʹs Whois service supports a number of features, including rate limiting to prevent abuse, privacy protections for natural persons, and a secure Searchable Whois Service. The Whois service is more fully described in §26. 
Should ICANN specify alternative formats and protocols for the dissemination of Domain Name Registration Data, CentralNic will implement such alternative specifications as soon as reasonably practicable. 

23.6. DNSSEC 
The TLD zone will be signed by DNSSEC. CentralNic uses the award-winning signer technology from Xelerance Corporation. Zone files will be signed using NSEC3 with opt-out, following a DNSSEC Practice Statement detailed in §43. 
CentralNicʹs DNSSEC implementation complies with RFCs 4033, 4034, 4035, 4509 and follows the best practices described in RFC 4641. Hashed Authenticated Denial of Existence (NSEC3) will be implemented, which complies with RFC 5155. The SRS will accept public-key material from child domain names in a secure manner according to industry best practices (specifically the secDNS EPP extension, described in RFC 5910). CentralNic will also publish in its website the DNSSEC Practice Statements (DPS) describing critical security controls and procedures for key material storage, access and usage for its own keys and secure acceptance of registrants’ public-key material. CentralNic will publish its DPS following the format described in the “DPS-framework” Internet Draft within 180 days after that draft becomes an RFC. 

23.7. Rights Protection Mechanisms 
Applicant will provide all mandatory Rights Protection Mechanisms that are specified in the Applicant Guidebook (version 11 January 2012), namely Trademark Claims Service (section 6.1) and Sunrise service (section 6.2). All the required RPM-related policies and procedures such as UDRP, URS, PDDRP and RRDRP will be adopted and used in the TLD. More information is available in §29. 
In addition to such RPMs, Applicant may develop and implement additional RPMs that discourage or prevent registration of domain names that violate or abuse another party’s legal rights. Applicant will include all ICANN mandated and independently developed RPMs in the registry-registrar agreement entered into by ICANN-accredited registrars authorised to register names in the TLD. Applicant shall implement these mechanisms in accordance with requirements established by ICANN each of the mandatory RPMs set forth in the Trademark Clearinghouse. 
The ʺLaunchPhaseʺ EPP extension (described above) will be used to implement an SRS interface during the Sunrise period for the TLD. Depending on the final specification for the Trademark Claims Service (details of which have not yet been published), an additional EPP extension may be required in order to implement this service. If this is necessary, the extension will be designed to minimise its effect on the operation of the SRS and the requirements on registrars, and will only be in place for a limited period while the Trademark Claims Service is in effect for the TLD. 

23.8. Registrar Support and Account Management 
CentralNic will leverage its 16 years of experience of supporting over 1,500 registrars to provide high-quality 24x7 support and account management for the TLD registrars. CentralNicʹs experienced technical and customer support personnel will assist the TLD registrars during the on-boarding and OT&E process, and provide responsive personal support via email, phone and a web based support ticketing system. 

23.9. Reporting to ICANN 
Applicant and CentralNic will compile and transmit a monthly report to ICANN relating to the TLD. This report will comply with Specification 3 of the New gTLD Registry Agreement. 

23.10. Personnel Resources of CentralNic 
The technical, operations and support functions of the registry will performed in-house by CentralNicʹs personnel. These personnel perform these functions on a full-time basis. 

23.10.1. Technical Operations 
Technical Operations refers to the deployment, maintenance, monitoring and security of the registry system, including the SRS and the other critical registry functions. Technical Operations staff design, build, deploy and maintain the technical infrastructure that supports the registry system, including power distribution, network design, access control, monitoring and logging services, and server and database administration. Internal helpdesk and incident reporting is also performed by the Technical Operations team. The Technical Operations team performs 24x7 monitoring and support for the registry system and mans the Network Operations Centre (NOC) from which all technical activities are co-ordinated. 
CentralNic intends to maintain a Technical Operations team consisting of the following positions. These persons will be responsible for managing, developing and monitoring the registry system for the TLD on a 24x7 basis: 
• Senior Operations Engineer(s) 
• Operations Engineer(s) 
• Security Engineer 

23.10.2. Technical Development 
The Technical Development team develops and maintains the software which implements the critical registry functions, including the EPP, Whois, Zone file generation, data escrow, reporting, backoffice and web-based management systems (intranet and extranet), and open-source registrar toolkit software. All critical registry software has been developed and maintained in-house by this team. 
CentralNic intends to maintain a Technical Development team consisting of the following positions. These persons will be responsible for maintaining and developing the registry software which will support the TLD: 
• Senior Technical Developer x 2 
• Technical Developer x 3 

23.10.3. Technical Support 
Technical Support refers to 1st, 2nd and 3rd line support for registrars and end-users. Areas covered include technical support for systems and services, billing and account management. Support personnel also deal with compliance and legal issues such as UDRP and URS proceedings, abuse reports and enquiries from law enforcement. 
1st line support issues are normally dealt with by these personnel. 2bd and 3rd line support issues (relating to functional or operational issues with the registry system) are escalated to Technical Operations or Technical Development as necessary. 
The Technical Support team will consist of the following positions: 
• Operations Manager 
• Support Manager 
• Support Agent(s) 
Our overseas account managers also perform basic support functions, escalating to the support agents in London where necessary. 

23.10.4. Key Personnel 

23.10.4.1. Gavin Brown - Chief Technology Officer 
Gavin has worked at CentralNic since 2001, becoming CTO in 2005. He has overall responsibility for all aspects of the SRS, Whois, DNS and DNSSEC systems. He is a respected figure in the domain industry and has been published in several professional technical journals, and co-authored a book on the Perl programming language. He also participates in a number of technical, public policy and advocacy groups and several open source projects. Gavin has a BSc (hons) in Physics from the University of Kent. 

23.10.4.2. Jenny White - Operations Manager 
Jenny has been with CentralNic for nine years. Throughout this time she has expertly managed customer relations with external partners, prepared new domain launch processes and documentation, managed daily support and maintenance for over 1,500 Registrars, carried out extensive troubleshooting within the registrar environment to ensure optimum usability for registrars across communication platforms, handled domain disputes (from mediation to WIPO filing), and liaised with WIPO to implement changes to the Dispute Resolution Procedure when necessary. 

23.10.4.3. Adam Armstrong - Senior Operations Engineer 
Adam has recently joined CentralNic as Senior Operations Engineer. In this role he is responsible for the operation and development of the system and network infrastructure for the registry system. Adam has previously worked at a number of large UK ISPs including Jersey Telecom and Packet Exchange. He is also the lead developer of Observium, a network management system used by ICANN (amongst others). Adam has brought his strong knowledge of network design, management and security to bear at CentralNic and will oversee the operation of the SRS for the TLD. 

23.10.4.4. Milos Negovanovic - Senior Technical Developer 
Milos has worked at CentralNic since 2009. He has a background in building rich web applications and protocol servers. His main areas of responsibility are the Registrar Console, EPP and backoffice functions. 

23.10.4.5. Mary OʹFlaherty - Senior Technical Developer 
Mary has worked at CentralNic since 2008. She plays an integral role in the ongoing design, development and maintenance of the registry as a whole and has specific experience with the EPP system, Registrar Console and Staff Console. Mary has a 1st class Honors degree in Computer Science from University College Cork and has previously worked for Intel and QAD Ireland. 

23.10.5. Job Descriptions 
CentralNic will recruit a number of new employees to perform technical duties in relation to the TLD and other gTLDs. The following job descriptions will be used to define these roles and select candidates with suitable skills and experience. 

23.10.5.1. Operations Engineer 
Operations Engineers assist in the maintenance and development of the network and server infrastructure of the registry system. Operations Engineers have a good knowledge of the TCP⁄IP protocol stack and related technologies, and are familiar with best practice in the areas of network design and management and system administration. They should be competent system administrators with a good knowledge of Unix system administration, and some knowledge of shell scripting, software development and databases. Operations Engineers have 1-2 yearʹs relevant commercial experience. Operations Engineers report to and work with the Senior Operations Engineer, who provides advice and mentoring. Operations Engineers participate in manning the NOC on a 24x7 basis and participate in the on-call shift rota. 

23.10.5.2. Security Engineer 
Security Engineers enhance and assure the security of the registry system. Day-to-day responsibilities are: responding to security incidents, performing analysis and remediating vulnerabilities, conducting tests of access controls, refining system configuration to improve security, training other team members, reviewing source code, maintaining security policies and procedures, and gathering intelligence relating to threats to the registry. Security Engineers have 1-2 yearʹs relevant commercial experience. This role reports to and works with the Senior Operations Engineer and CTO. Security Engineers participate in manning the NOC on a 24x7 basis and participate in the on-call shift rota. 

23.10.5.3. Technical Developer 
Technical Developers are maintain the software which supports the registry. Day-to-day responsibilities are developing new systems in response to requests from management and customers, correcting bugs in existing software, and improving its performance. Technical Developers have a good knowledge of general programming practices including use of revision control and code review systems. Developers have a good awareness of security issues, such as those described in advisories published by the oWASP Project. Developers have at least one yearsʹ commercial experience in developing applications in programming languages such as PHP, Perl, and Python, although knowledge of domain technologies such as EPP and DNS is not critical. Technical Developers work as part of a team, with advice and mentoring from the Senior Technical Developers, to whom they report. 

23.10.6. Resource Matrix 
To provide a means to accurately and objectively predict human resource requirements for the operation of the registry system, CentralNic has developed a Resourcing Matrix, which assigns a proportion of each employeeʹs available time to each aspect of registry activities. These activities include technical work such as operations and development, as well as technical support, registrar account management, rights protection, abuse prevention, and financial activity such as payroll, cash collection, etc. This matrix then permits the calculation of the total HR resource assigned to each area. 
A copy of the Resourcing Matrix is included as Appendix 23.2. It is important to note that the available resources cover the operation of CentralNicʹs entire registry operations: this includes CentralNicʹs own domain registry portfolio (uk.com, us.com, etc), the .LA ccTLD, as well as the gTLDs which CentralNic will provides registry service for. 
The actual proportion of human technical resources required specifically for the TLD is determined by the relative size of the TLD to the rest of CentralNicʹs operations. This calculation is based on the projected number of domains after three years of operation: the optimistic scenario is used to ensure that sufficient personnel is on hand to meet periods of enhanced demand. CentralNic has calculated that, if all its TLD clients are successful in their applications, and all meet their optimistic projections after three years, its registry system will be required to support up to 4.5 million domain names. 
Since the optimistic projection for the number of domains registered in the TLD after three years is [30,000], the TLD will therefore require [0.67]% of CentralNicʹs total available HR resources in order operate fully and correctly. In the event that registration volumes exceed this figure, CentralNic will proactively increase the size of the Technical Operations, Technical Development and support teams to ensure that the needs of the TLD are fully met. Revenues from the additional registration volumes will fund the salaries of these new hires. Nevertheless, CentralNic is confident that the staffing outlined above is sufficient to meet the needs of the TLD for at least the first 18 months of operation. 

Q24 - SRS performance
Except where specified this answer refers to the operations of the Applicantʹs outsource Registry Service Provider, CentralNic. 
24.1. Registry Type 
CentralNic operates a ʺthickʺ registry in which the registry maintains copies of all information associated with registered domains. Registrars maintain their own copies of registration information, thus registry-registrar synchronization is required to ensure that both registry and registrar have consistent views of the technical and contact information associated with registered domains. The Extensible Provisioning Protocol (EPP) adopted supports the thick registry model. See §25 for further details. 

24.2. Architecture 
Figure 24.1 provides a diagram of the overall configuration of the SRS. This diagram should be viewed in the context of the overall architecture of the registry system described in §32. 
The SRS is hosted at CentralNicʹs primary operations centre in London. It is is connected to the public Internet via two upstream connections, one of which is provided by Qube. Figure 32.1 provides a diagram of the outbound network connectivity. Interconnection with upstream transit providers is via two BGP routers which connect to the firewalls which implement access controls over registry services. 
Within the firewall boundary, connectivity is provided to servers by means of resilient gigabit ethernet switches implementing Spanning Tree Protocol. 
The registry system implements two interfaces to the SRS: the standard EPP system (described in §25) and the Registrar Console (described in §31). These systems interact with the primary registry database (described in §33). The database is the central repository of all registry data. Other registry services also interact with this database. 
An internal ʺStaff Consoleʺ is used by CentralNic personnel to perform management of the registry system. 

24.3. EPP System Architecture 
A description of the characteristics of the EPP system is provided in §25. This response describes the infrastructure which supports the EPP system. 
A network diagram for the EPP system is provided in Figure 24.2. The EPP system is hosted at the primary operations centre in London. During failover conditions, the EPP system operates from the Isle of Man Disaster Recovery site (see §34). 
CentralNic’s EPP system has a three-layer logical and physical architecture, consisting of load balancers, a cluster of front-end protocol servers, and a pool of application servers. Each layer can be scaled horizontally in order to meet demand. 
Registars establish TLS-secured TCP connections to the load balancers on TCP port 700. Load is balanced using DNS round-robin load balancing. 
The load balancers pass sessions to the EPP protocol servers. Load is distributed using a weighted-least-connections algorithm. The protocol servers run the Apache web server with the mod_epp and mod_proxy_balancer modules. These servers process session commands (ʺhelloʺ, ʺloginʺ and ʺlogoutʺ) and function as reverse proxies for query and transform commands, converting them into plain HTTP requests which are then distributed to the application servers. EPP commands are distributed using a weighted-least-connections algorithm. 
Application servers receives EPP commands as plain HTTP requests, which are handled using application business logic. Application servers process commands and prepare responses which are sent back to the protocol servers, which return responses to clients over EPP sessions. 
Each component of the system is resilient: multiple inbound connections, redundant power, high availability firewalls, load balancers and application server clusters enable seamless operation in the event of component failure. This architecture also allows for arbitrary horizontal scaling: commodity hardware is used throughout the system and can be rapidly added to the system, without disruption, to meet an unexpected growth in demand. 
The EPP system will comprise of the following systems: 
• 4x load balancers (1U rack mount servers with quad-core Intel processors, 16GB RAM, 40GB solid-state disk drives, running the CentOS operating system using the Linux Virtual Server [see http:⁄⁄www.linuxvirtualserver.org⁄]) 
• 8x EPP protocol servers (1U rack mount servers with dual-core Intel processors, 16GB RAM, running the CentOS operating system using Apache and mod_epp) 
• 20x application servers (1U rack mount servers with dual-core Intel processors, 4GB of RAM, running the CentOS operating system using Apache and PHP) 

24.3.1. mod_epp 
mod_epp is an Apache server module which adds support for the EPP transport protocol to Apache. This permits implementation of an EPP server using the various features of Apache, including CGI scripts and other dynamic request handlers, reverse proxies, and even static files. mod_epp was originally developed by Nic.at, the Austrian ccTLD registry. Since its release, a large number of ccTLD and other registries have deployed it and continue to support its development and maintenance. Further information can be found at http:⁄⁄sourceforge.net⁄projects⁄aepps. CentralNic uses mod_epp to manage EPP sessions with registrar clients, and to convert EPP commands into HTTP requests which can then be handled by backend application servers. 

24.3.2. mod_proxy_balancer 
mod_proxy_balancer is a core Apache module. Combined with the mod_proxy module, it implements a load-balancing reverse proxy, and includes a number of load balancing algorithms and automated failover between members of a cluster. CentralNic uses mod_proxy_balancer to distribute EPP commands to backend application servers. 

24.4. Performance 
CentralNic performs continuous remote monitoring of its EPP system, and this monitoring includes measuring the performance of various parts of the system. As of writing, the average round-trip times (RTTs) for various functions of the EPP system were as follows: 
• connect time: 87ms 
• login time: 75ms 
• hello time: 21ms 
• check time: 123ms 
• logout time: 20ms 
These figures include an approximate latency of 2.4ms due to the distant between the monitoring site and the EPP system. They were recorded during normal weekday operations during the busiest time of the day (around 1300hrs UTC) and compare very favourably to the requirement of 4,000ms for session commands and 2,000ms for query commands defined in the new gTLD Service Level Agreement. RTTs for overseas registrars will be higher than this due to the greater distances involved, but will remain well within requirements. 

24.5. Scaling 
Horizontal scaling is preferred over vertical scaling. Horizontal scaling refers to the introduction of additional nodes into a cluster, while vertical scaling involves using more powerful equipment (more CPU cores, RAM etc) in a single system. Horizontal scaling also encourages effective mechanisms to ensure high-availability, and eliminate single points of failure in the system. 
Vertical scaling leverages Mooreʹs Law: when units are depreciated and replaced, the new equipment is likely to be significantly more powerful. If the average lifespan of a server in the system is three years, then its replacement is likely to be around four times as powerful as the old server. 
For further information about Capacity Management and Scaling, please see §32. 

24.6. Registrar Console 
The Registrar Console is a web-based registrar account management tool. It provides a secure and easy-to-use graphical interface to the SRS. It is hosted on a virtual platform at the primary operations centre in London. As with the rest of the registry system, during a failover condition it is operated from the Isle of Man. The virtual platform is described in Figure 24.3. 
The features of the Registrar Console are described in §31. 
The virtual platform is a utility platform which supports systems and services which do not operate at significant levels of load, and which therefore do not require multiple servers or the additional performance that running on ʺbare metalʺ would provide. The platform functions as a private cloud, with redundant storage and failover between hosts. 
The Registrar Console currently sustains an average of 6 page requests per minute during normal operations, with peak volumes of around 8 requests per minute. Volumes during weekends are significantly lower (fewer than 1 requests per minute). Additional load resulting from this and other new gTLDs is expected to result in a trivial increase in Registrar Console request volumes, and CentralNic does not expect additional hardware resources to be required to support it. 

24.7. Quality Assurance 
CentralNic employs the following quality assurance (QA) methods: 
1. 24x7x365 monitoring provides reports of incidents to NOC 
2. Quarterly review of capacity, performance and reliability 
3. Monthly reviews of uptime, latency and bandwidth consumption 
4. Hardware depreciation schedules 
5. Unit testing framework 
6. Frequent reviews by QA working group 
7. Schema validation and similar technologies to monitor compliance on a real-time, ongoing basis 
8. Revision control software with online annotation and change logs 
9. Bug Tracking system to which all employees have access 
10. Code Review Policy in place to enforce peer review of all changes to core code prior to deployment 
11. Software incorporates built-in error reporting mechanisms to detect flaws and report to Operations team 
12. Four stage deployment strategy: development environment, staging for internal testing, OT&E deployment for registrar testing, then finally production deployment 
13. Evidence-based project scheduling 
14. Specification development and revision 
15. Weekly milestones for developers 
16. Gantt charts and critical path analysis for project planning 
Registry system updates are performed on an ongoing basis, with any user-facing updates (ie changes to the behaviour of the EPP interface) being scheduled at specific times. Disruptive maintenance is scheduled for periods during which activity is lowest. 

24.8. Billing 
CentralNic operates a complex billing system for domain name registry services to ensure registry billing and collection services are feature rich, accurate, secure, and accessible to all registrars. The goal of the system is to maintain the integrity of data and create reports which are accurate, accessible, secured, and scalable. The foundation of the process is debit accounts established for each registrar. CentralNic will withdraw all domain fees from the registrar’s account on a per-transaction basis. CentralNic will provide fee-incurring services (e.g., domain registrations, registrar transfers, domain renewals) to a registrar for as long as that registrar’s account shows a positive balance. 
Once ICANN notifies Applicant that a registrar has been issued accreditation, CentralNic will begin the registrar on-boarding process, including setting up the registrarʹs financial account within the SRS. 

24.9. Registrar Support 
CentralNic provides a multi-tier support system on a 24x7 basis with the following support levels: 
• 1st Level: initial support level responsible for basic customer issues. The first job of 1st Level personnel is to gather the customer’s information and to determine the customer’s issue by analyzing the symptoms and figuring out the underlying problem. 
• 2nd Level: more in-depth technical support level than 1st Level support containing experienced and more knowledgeable personnel on a particular product or service. Technicians at this level are responsible for assisting 1st Level personnel solve basic technical problems and for investigating elevated issues by confirming the validity of the problem and seeking for known solutions related to these more complex issues. 
• 3rd Level: the highest level of support in a three-tiered technical support model responsible for handling the most difficult or advanced problems. Level 3 personnel are experts in their fields and are responsible for not only assisting both 1st and 2nd level personnel, but with the research and development of solutions to new or unknown issues. 
CentralNic provides a support ticketing system for tracking routine support issues. This is a web based system (available via the Registrar Console) allowing registrars to report new issues, follow up on previously raised tickets, and read responses from CentralNic support personnel. 
When a new trouble ticket is submitted, it is assigned a unique ID and priority. The following priority levels are used:  
1. Normal: general enquiry, usage question, or feature enhancement request. Handled by 1st level support. 
2. Elevated: issue with a non-critical feature for which a work-around may or may not exist. Handled by 1st level support. 
3. Severe: serious issue with a primary feature necessary for daily operations for which no work-around has been discovered and which completely prevents the feature from being used. Handled by 2nd level support. 
4. Critical: A major production system is down or severely impacted. These issues are catastrophic outages that affect the overall Registry System operations. Handled by 3rd level support. 
Depending on priority, different personnel will be alerted to the existence of the ticket. For example, a Priority 1 ticket will cause a notification to be emailed to the registrar customer support team, but a Priority 4 ticket will result in a broadcast message sent to the pagers of senior operations staff including the CTO. The system permits escalation of issues that are not resolved within target resolution times. 

24.10. Enforcement of Eligibility Requirements 
The SRS supports enforcement of eligibility requirements, as required by specific TLD policies. 
Figure 24.4 describes the process by which registration requests are validated. Prior to registration, the registrantʹs eligibility is validated by a Validation Agent. The registrant then instructs their registrar to register the domain. The SRS returns an ʺObject Pendingʺ result code (1001) to the registrar. 
The request is sent to the Validation Agent by the registry. The Validation Agent either approves or rejects the request, having reconciled the registration information with that recorded during the eligibility validation. If the request has been approved, the domain is fully registered. If it is rejected, the domain is immediately removed from the database. A message is sent to the registrar via the EPP message queue in either case. The registrar then notifies the registrant of the result. 

24.11. Interconnectivity With Other Registry Systems 
The registry system is based on multiple resilient stateless modules. The SRS, Whois, DNS and other systems do not directly interact with each other. Interactions are mediated by the database which is the single authoritative source of data for the registry as a whole. Individuals modules perform ʺCRUDʺ (create, read, update, delete) actions upon the database. These actions then affect the behaviour of other registry systems: for example, when a registrar adds the ʺclientHoldʺ status to a domain object, this is recorded in the database. When a query is received for this domain via the Whois service, the presence of this status code in the database results in the ʺStatus: CLIENT HOLDʺ appearing in the whois record. It will also be noted by the zone generation system, resulting in the temporary removal of the delegation of the domain name from the DNS. 

24.12. Resilience 
The SRS has a stateless architecture designed to be fully resilient in order to provide an uninterrupted service in the face of failure or one or more parts of the system. This is achieved by use of redundant hardware and network connections, and by use of continuous ʺheartbeatʺ monitoring allowing dynamic and high-speed failover from active to standby components, or between nodes in an active-active cluster. These technologies also permit rapid scaling of the system to meet short-term increases in demand during ʺsurgeʺ periods, such as during the initial launch of a new TLD. 

24.12.1. Synchronisation Between Servers and Sites 
CentralNicʹs system is implemented as multiple stateless systems which interact via a central registry database. As a result, there are only a few situations where synchronisation of data between servers is necessary: 
1. replication of data between active and standby servers (see §33). CentralNic implements redundancy in its database system by means of an active⁄standby database cluster. The database system used by CentralNic supports native real-time replication of data allowing operation of a reliable hot standby server. Automated heartbeat monitoring and failover is implemented to ensure continued access to the database following a failure of the primary database system. 
2. replication is used to synchronise the primary operations centre with the Disaster Recovery site hosted in the Isle of Man (see §34). Database updates are replicated to the DR site in real-time via a secured VPN, providing a ʺhotʺ backup site which can be used to provide registry services in the event of a failure at the primary site. 

24.13. Operational Testing and Evaluation (OT&E) 
An Operational Testing and Evaluation (OT&E) environment is provided for registrars to develop and test their systems. The OT&E system replicates the SRS in a clean-room environment. Access to the OT&E system is unrestricted and unlimited: registrars can freely create multiple OT&E accounts via the Registrar Console. 

24.14. Resourcing 
As can be seen in the Resourcing Matrix found in Appendix 23.2, CentralNic will maintain a team of full-time developers and engineers which will contribute to the development and maintenance of this aspect of the registry system. These developers and engineers will not work on specific subsystems full-time, but a certain percentage of their time will be dedicated to each area. The total HR resource dedicated to this area is equivalent to more than one full-time post. 
CentralNic operates a shared registry environment where multiple registry zones (such as CentralNicʹs domains, the .LA ccTLD, this TLD and other gTLDs) share a common infrastructure and resources. Since the TLD will be operated in an identical manner to these other registries, and on the same infrastructure, then the TLD will benefit from an economy of scale with regards to access to CentralNicʹs resources. 
CentralNicʹs resourcing model assumes that the ʺdedicatedʺ resourcing required for the TLD (ie, that required to deal with issues related specifically to the TLD and not to general issues with the system as a whole) will be equal to the proportion of the overall registry system that the TLD will use. After three years of operation, the optimistic projection for the TLD states that there will be [30,000] domains in the zone. CentralNic has calculated that, if all its TLD clients are successful in their applications, and all meet their optimistic projections after three years, its registry system will be required to support up to 4.5 million domain names. Therefore the TLD will require [0.67]% of the total resources available for this area of the registry system. 
In the event that registration volumes exceed this figure, CentralNic will proactively increase the size of the Technical Operations, Technical Development and support teams to ensure that the needs of the TLD are fully met. Revenues from the additional registration volumes will fund the salaries of these new hires. Nevertheless, CentralNic is confident that the staffing outlined above is sufficient to meet the needs of the TLD for at least the first 18 months of operation. 

Question No. 25
The Extensible Provisioning Protocol (EPP, defined in RFC 5730 and others) is an application layer client-server protocol for the provisioning and management of objects stored in a shared central repository. EPP defines generic object management operations and an extensible framework that maps protocol operations to objects. EPP has become established as the common protocol by which domain registrars can manage domain names, nameservers and contact details held by domain registries. It is widely deployed in the gTLD and ccTLD registry space. 
CentralNic has operated its EPP system since 2005, and it currently operates at significant load in terms of registrars, sessions and transaction volumes. CentralNicʹs EPP system is fully compliant with the following RFC specifications: 
• 5730 - Base Protocol 
• 5731 - Domain Mapping 
• 5732 - Host Mapping 
• 5733 - Contact Mapping 
• 5734 - TCP Transport 
• 3735 - Extension Guidelines 
• 3915 - RGP Extension 
• 5910 - DNSSEC Extension 

25.1. Description of Interface 
EPP is a stateful XML protocol that can be layered over multiple transport protocols, the most popular implementation being that described in RFC 3734. Protected using lower-layer security protocols, clients exchange identification, authentication, and option information, and then engage in a series of client-initiated command-response exchanges. All EPP commands are atomic (there is no partial success or partial failure) and designed so that they can be made idempotent (executing a command more than once has the same net effect on system state as successfully executing the command once). 
EPP provides four basic service elements: service discovery, commands, responses, and an extension framework that supports definition of managed objects and the relationship of protocol requests and responses to those objects. 
An EPP server responds to client-initiated communication (which can be either a lower-layer connection request or an EPP service discovery message) by returning a greeting to a client. The server then responds to each EPP command with a coordinated response that describes the results of processing the command. 
EPP commands fall into three categories: session management commands, query commands, and object transform commands. Session management commands are used to establish and end persistent sessions with an EPP server. Query commands are used to perform read-only object information retrieval operations. Transform commands are used to perform read-write object management operations. 
Commands are processed by a server in the order they are received from a client. Though an immediate response confirming receipt and processing of the command is produced by the server, the protocol includes features that allow for offline review of transform commands before the requested action is actually completed. In such situations, the response from the server will clearly note that the command has been received and processed but that the requested action is pending. The state of the corresponding object then reflects processing of the pending action. The server will also notify the client when offline processing of the action has been completed. Object mappings describe standard formats for notices that describe completion of offline processing. 
EPP uses XML namespaces to provide an extensible object management framework and to identify schemas required for XML instance parsing and validation. These namespaces and schema definitions are used to identify both the base protocol schema and the schemas for managed objects. 

25.1.1. Objects supported 
Registrars may create and manage the following object types in the CentralNic EPP system: 
• domain names (RFC 5731) 
• host objects (RFC 5732) 
• contact objects (RFC 5733) 

25.1.2. Commands supported 
CentralNic supports the following EPP commands: 
• ʺhelloʺ - retrieve the ʺgreetingʺ from the server 
• ʺloginʺ and ʺlogoutʺ - session management 
• ʺpollʺ - message queue management 
• ʺcheckʺ - availability check 
• ʺinfoʺ - object information 
• ʺcreateʺ - create object 
• ʺupdateʺ - update object 
• ʺrenewʺ - renew object 
• ʺdeleteʺ - delete objects 
• ʺtransferʺ - manage object transfers 

25.2. EPP state diagram 
Figure 25.1 describes the state machine for the EPP system. This derived from RFC 5730. Clients establish a connection with the server, which sends a greeting. Clients then authenticate, and once a login session is established, submits commands and receive responses until the server closes the connection, the client sends a logout command, or a timeout is reached. 

25.3. EPP Object Policies 
The following policies apply to objects provisioned via the EPP system: 

25.3.1. Domain Names 
1. domain names must comply with the Preferred name syntax described in RFC 1035 §2.3.1. Additionally, the first label of the name must be between 3 and 63 characters in length. 
2. domain names must have a registrant attribute which is associated with a contact object in the registry database. 
3. domain names must have an administrative contact attribute which is associated with a contact object in the registry database. 
4. domain names must have a technical contact which attribute is associated with a contact object in the registry database. 
5. domain names may have an billing contact attribute which is associated with a contact object in the registry database. 
6. domain names may have between 0 (zero) and thirteen (13) DNS servers. A domain with no name servers will not resolve and no records will be published in the DNS. CentralNicʹs EPP system uses the host object model for domain names, rather than the host attribute model (see RFC 5731, §1.1). 
7. domain names may have a number of status codes. These codes are described in RFC 5731, § 2.3. The presence of certain status codes indicates the domain nameʹs position in the lifecycle, which is described further in §27. 
8. where TLD policy requires, the server will response to a ʺdomain:createʺ command with an ʺObject Pendingʺ (1001) response. When this occurs, the domain is placed onto the pendingCreate status while an out-of-band validation process takes place. 
9. when registered, the expiry date of a domain may be set up to ten years from the initial date of registration. Registrars can specify registration periods in one-year increments from one to ten. 
10. when renewed, the expiry date of a domain may be set up to ten years from the current expiry date. Registrars can specify renewal periods in one-year increments from one to ten. Domain names which auto-renew are renewed for one year at a time. 
11. domain names must have an authInfo code which is used to authenticate inter-registrar transfer requests. This authInfo code may contain up to 48 bytes of UTF-8 character data. 
12. domain names may have one or more DS records associated with them. DS records are managed via the secDNS EPP extension, as specified in RFC 5910. 
13. only the sponsoring registrar of the domain may submit ʺupdateʺ, ʺrenewʺ or ʺdeleteʺ commands for the domain. 

25.3.2. Host objects 
1. host names must comply with RFC 1035. The maximum length of the host name may not exceed 255 characters. 
2. in-bailiwick hosts must have an IPv4 address. They may optionally have an IPv6 address. 
3. multiple IP addresses are not currently permitted. 
4. sponsorship of host objects is determined as follows: if an object is in-bailwick (ie subordinate to a domain in the registry database, and therefore also subordinate to a TLD in the system), then the sponsor is the sponsor of the superordinate domain name. If the object is out-of-bailiwick, the sponsor is the registrar which created the contact. 
5. if a registrar submits a change to the name of a host object, if the new host name is subordinate to an in-bailiwick domain, then that registrar must be the sponsor of the new parent domain. 
6. registrars are not permitted to create host objects that are subordinate to a non-existent in-bailiwick domain, or to change the name of a host object so that it us subordinate to a non-existent in-bailiwick domain. 
7. a host object cannot be deleted if one or more domain names are delegated to it (the registry may delete host objects to remove orphan glue, see §28). 
8. inter-registrar transfers of hosts are not permitted. 
9. only the sponsoring registrar of the host may submit ʺupdateʺ or ʺdeleteʺ commands for the object. 

25.3.3. Contact objects 
1. contact IDs may only contain characters from the set [A-Z, 0-9, . (period), - (hyphen) and - (underscore)] and are case-insensitive. 
2. phone numbers and email addresses must be valid as described in RFC 5733 §2.5 and §2.6. 
3. contact information is accepted and stored in ʺinternationalizedʺ format only: that is, contact objects only have a single ʺcontact:postalInfoʺ element and the type attribute is always ʺintʺ. 
4. the ʺcontact:orgʺ, ʺcontact:spʺ, ʺcontact:pcʺ, ʺcontact:phoneʺ and ʺcontact:faxʺ elements are optional. 
5. contact objects must have an authInfo code which is used to authenticate inter-registrar transfer requests. This authInfo code may contain up to 48 bytes of UTF-8 character data. 
6. a contact object cannot be deleted if one or more domain names are associated with it. 
7. only the sponsoring registrar of the domain may submit ʺupdateʺ or ʺdeleteʺ commands for the object. 
8. the ʺcontact:discloseʺ element may be used to cause a contact object to be opted-out of display in the Whois (see §26 and the discussion of the Contact Type extension below. Note that this feature is redundant and will be disabled for TLDs which forbid registration by natural persons). 

25.4. EPP Extensions 
CentralNic has implemented the following EPP extensions. Rather than include detailed descriptions of these extensions, references to external specifications are included instead. CentralNicʹs implementations fully comply with the required specifications. 

25.4.1. Registry Grace Period Mapping 
Various grace periods and hold periods are supported by the Registry Grace Period mapping, as defined in RFC 3915. This is described further in §27. 

25.4.2. DNSSEC Security Extensions Mapping 
Registrars may submit Delegation Signer (DS) record information for domains under their sponsorship. This permits the establishment of a secure chain-of-trust for DNSSEC validation. 
CentralNic supports the most recent specification of the secDNS extension, defined in RFC 5910. This specification supports two interfaces: the DS Data Interface and Key Data Interface (see RFC 5910, §4). CentralNic supports the former interface (DS Data), whereby registrars submit the keytag, algorithm, digest type and digest for DS records as XML elements, rather than as opaque (to EPP) DNSKEY data. DNSKEY data is accepted and stored where it is provided as a child element of the ʺsecDNS:dsDataʺ element. 
The maxSigLife element is optional in the specification and is not currently supported. 

25.4.3. Launch Phase Extension 
CentralNic has contributed to a project to develop a standardised EPP extension for domain registry ʺlaunch phasesʺ (ie Sunrise and Landrush periods), during which the steady-state mode of ʺfirst-come, first-servedʺ operation does not apply. This extension permits registrars to submit requests for domain names with support for claimed rights such as a registered trademark. The extension is currently described in an Internet-Draft which has been included as Appendix 25.1. It is hoped that this draft will eventually be published as an RFC which can be implemented by other registries and registrars. 
CentralNicʹs system implements this extension and will support the most recent version of the draft during the initial launch of the TLD. Once the TLD enters the General Availability phase, this extension will no longer be available for use by registrars. Example command and response frames describing the use of this extension are included in Appendix 25.2. As of writing, the current Internet Draft does not include a full schema definition, but a schema from a previous version has been included in Appendix 25.3. When the Draft is updated to include a schema, it will be based on this version. 

25.5. Registrar Credentials and Access Control 
Registrars are issued with a username (their registrar ID) and a password which is used to access the EPP system. This password cannot be used to access any other service and only this password can be used to access the EPP system. Registrar officers with the ʺManagementʺ access level can change their EPP password via the Registrar Console. Password changes take effect immediately, but do not affect any existing login sessions. 
RFC 5730 requires that EPP clients and servers implement ʺmutual, strong client-server authenticationʺ. To that effect, CentralNic requires that all registrars connect to the EPP system using a client SSL certificate. This certificate may be obtained from a recognised certificate authority, or it may be a self-signed certificate registered with CentralNic via the Registrar Console. Registrar officers with the ʺManagementʺ access level can upload SSL certificates for their account. 

25.6. Session Limits and Transaction Volumes 
CentralNic does not impose limits on the number of active sessions a registrar can maintain with the server. Similarly, there are no limits on the volume of transactions a registrar may send. However the system is fully capable of imposing connection limits and this measure may be used in future to ensure equal access amongst registrars. 

25.7. Transaction Logging and Reporting 
All ʺtransformʺ EPP commands are logged. Transform commands are: ʺcreateʺ, ʺrenewʺ, ʺupdateʺ, ʺdeleteʺ and ʺtransferʺ. The system logs the time and date when the command was received, the registrar which submitted it, the request frame, the response frame, the result code and message, and the time taken by the system to generate the response. All commands, whether successful or not, are logged. 
The EPP transaction log is stored in the primary registry database. Registrars have access to the full log for their account via the Registrar Console. The log viewer permits filtering by command, object type, object ID (domain name, host name, contact ID), result code and timestamp. 
Query commands (ʺcheckʺ, ʺinfoʺ, ʺpoll op=ʺreqʺʺ) and session commands (ʺloginʺ, ʺlogoutʺ and ʺhelloʺ) are not logged due to the large volume of such queries (particularly ʺcheckʺ queries). The EPP system uses counters for these commands to facilitate generation of monthly reports. 

25.8. EPP Message Queue 
The EPP protocol provides a message queue to provide registrars with notifications for out-of-band events. CentralNic currently supports the following EPP messages: 
• notification of approved inbound transfer 
• notification of rejected inbound transfer 
• notification of new outbound transfer 
• notification of cancelled outbound transfer 
• notification of approved or rejected domain registration request (where TLD policy requires out-of-band approval of ʺdomain:createʺ requests) 

25.9. Registrar Support, Software Toolkit 
CentralNic has supported of EPP for many years. Following the deployment of its EPP service in 2005, CentralNic released a number of open source client libraries for several popular programming languages. These libraries have been used by registrars (both ICANN accredited and ccTLD registrars) and registries around the world. CentralNic currently maintains the following open source EPP libraries: 
• Net::EPP, which is a general purpose EPP library for Perl. See http:⁄⁄code.google.com⁄p⁄perl-net-epp⁄ 
• Preppi, a graphical EPP client written in Perl. See https:⁄⁄www.centralnic.com⁄company⁄labs⁄preppi 
• Net_EPP, a PHP client class for EPP. See https:⁄⁄github.com⁄centralnic⁄php-epp 
• Simpleepp, a Python client class for EPP. See https:⁄⁄bitbucket.org⁄milosn⁄simpleepp 
• tx-epp-proxy, a EPP reverse proxy for shared-nothing client architectures written in Python. See https:⁄⁄bitbucket.org⁄milosn⁄tx-epp-proxy 
Being open source, these libraries are available for anyone to use, at no cost. CentralNic continues to develop and update these libraries, and accepts submissions and bug reports from users around the world. 

25.10. Quality Assurance, RFC Compliance 
To ensure that its EPP system fully complies with the relevant specifications documents, CentralNic has implemented the following: 

25.10.1. Schema Validation 
The EPP system automatically validates all response frames against the XSD schema definitions provided in the RFCs. Should a non-validating response be sent to a registrar, an alert is raised with the NOC to be investigated and corrected. By default, this feature is disabled in the production environment but it is enabled in all other environments (as described below). 

25.10.2. Multi-stage Deployment and Testing 
EPP system code is developed, tested and deployed in a multi-stage environment: 
1. Developers maintain their own development environment in which new code is written and changes are prepared. Development environments are configured with the highest level of debugging and strictness to provide early detection of faults. 
2. All changes to the EPP system are subjected to peer review: other developers in the team must review, test and sign off the changes before being committed (or, if developed on a branch, being merged into the stable branch). 
3. Changes to EPP system code are then deployed in the OT&E environment. Registrars continually test this system as part of their own QA processes, and this additional phase provides an additional level of quality assurance. 

25.10.3. Registrar Feedback 
CentralNic registrars are provided with an easy way to report issues with the EPP system, and many perform schema validation and other tests on the responses they receive. When issues are detected by registrars, they are encouraged to submit bug reports so that developers can rectify the issues. 

25.11. EPP System Resourcing 
As can be seen in the Resourcing Matrix found in Appendix 23.2, CentralNic will maintain a team of full-time developers and engineers which will contribute to the development and maintenance of this aspect of the registry system. These developers and engineers will not work on specific subsystems full-time, but a certain percentage of their time will be dedicated to each area. The total HR resource dedicated to this area is equivalent to more than one full-time person. 
CentralNic operates a shared registry environment where multiple registry zones (such as CentralNicʹs domains, the .LA ccTLD, this TLD and other gTLDs) share a common infrastructure and resources. Since the TLD will be operated in an identical manner to these other registries, and on the same infrastructure, then the TLD will benefit from an economy of scale with regards to access to CentralNicʹs resources. 
CentralNicʹs resourcing model assumes that the ʺdedicatedʺ resourcing required for the TLD (ie, that required to deal with issues related specifically to the TLD and not to general issues with the system as a whole) will be equal to the proportion of the overall registry system that the TLD will use. After three years of operation, the optimistic projection for the TLD states that there will be [30,000] domains in the zone. CentralNicʹs resource model (described in Appendix 23.3) therefore projects that the TLD will require [0.67]% of the total resources available for this area of the registry system. 
In the event that registration volumes exceed this figure, CentralNic will proactively increase the size of the Technical Operations and Technical Development teams, (and if necessary, the support team) to ensure that the needs of the TLD are fully met. Revenues from the additional registration volumes will fund the salaries of these new hires. Nevertheless, CentralNic is confident that the staffing outlined above is sufficient to meet the needs of the TLD for the first 18 months of operation. 

Question 26
The Whois system (also known as NICNAME) is one of the oldest Internet protocols still in use. It allows interested persons to retrieve information relating to Internet resources, specifically domain names and IP address allocations. Whois services are operated by the registries of these resources, namely TLD registries and RIRs. 
Whois is described by RFC 3912. This document serves as a description of existing implementations rather than prescribing specific behaviours from clients and servers. The protocol is a query-response protocol, in which both the query and the response are opaque to the protocol, and their meanings are known only the server and to the human user who submits a query. Whois has a number of limitations, but remains ubiquitous as a means for obtaining information about name and number resources. 

26.1. Compliance 
The Whois service for the .PLACE TLD will comply with RFC3912 and Specifications 4 and 10 of the New gTLD Registry Agreement. The service will be provided to the general public at no cost. If ICANN specify alternative formats and protocols (such as WEIRDS) then CentralNic will implement these as soon as reasonably practicable. 
CentralNic will monitor its Whois system to confirm compliance. Monitoring stations will check the behaviour and response of the Whois service to ensure the correctness of Whois records. CentralNic will maintain a public Whois contact to which bug reports and other questions about the Whois service can be directed. 

26.2. Domain Name 
By default, any query submitted to the Whois service is assumed to be a domain name unless a keyword is prepended to the query. If the domain exists, then registration is returned, including the following fields: 
• Domain ROID 
• Domain Name 
• Domain U-label (if IDN) 
• Creation Date 
• Last Updated 
• Expiration Date 
• EPP status codes 
• Registrant Contact Information 
• Administrative Contact Information 
• Technical Contact Information 
• Billing Contact Information (if any) 
• Sponsoring Registrar ID 
• Sponsoring Registrar Contact Information 
• DNS servers (if any) 
• DNSSEC records (if any) 
An example of a domain whois response is included in Appendix 26.1. The Domain ROID is the Repository Object Identifier as described in RFC 5730, §2.8. The ROID field corresponds to the ʺdomain:roidʺ element of EPP ʺinfoʺ responses. 
A domain may be associated with one or more status codes. These are represented in Whois responses as phrases rather than EPP mnemonics. A domain may have any of the following status codes: 
• PENDING CREATE - a ʺdomain:createʺ command has been received through the SRS, but the registration has not yet been finalised as an out-of-band review process has not yet been completed. 
• ADD PERIOD - the domain is in the Add Grace Period 
• CLIENT HOLD - the registrar has added the clientHold status 
• DELETE PROHIBITED - this may be present if the domain has either clientDeleteProhibited or serverDeleteProhibited (or both) 
• INACTIVE - the domain has no DNS servers 
• PENDING DELETE - the domain has left the Redemption Grace Period and is scheduled for deletion 
• PENDING DELETE RESTORABLE - the domain is in the Redemption Grace Period 
• PENDING RESTORE - a restore request has been received, but the Restore Report has not been received 
• PENDING TRANSFER - there is an active inter-registrar transfer for the domain 
• RENEW PERIOD - the domain is either in the Renew Grace Period or the Auto-Renew Grace Period 
• RENEW PROHIBITED - this may be present if the domain has either clientRenewProhibited or serverRenewProhibited (or both) 
• SERVER HOLD - the registry has added the serverHold status 
• TRANSFER PERIOD - the domain is in the Transfer Grace Period 
• TRANSFER PROHIBITED - this may be present if the domain has either clientTransferProhibited or serverTransferProhibited (or both) 
• UPDATE PROHIBITED - this may be present if the domain has either clientUpdateProhibited or serverUpdateProhibited (or both) 
• OK - present if none of the above apply. 
The Registrant, Administrative, Technical and Billing Contact sections of the Whois record display the contact information for the contact objects that are associated with the domain. The information displayed replicates the information showed for a contact query (see below). The server shows similar information for the sponsoring registrar. 
Domains may have 0-13 DNS servers. If a domain name has no DNS servers, then the ʺINACTIVEʺ status code appears in the Status section. If the registrant provided DS records for their DNSSEC-signed domain, then these are included. For each DS record, then the key tag, algorithm, digest type and digest are displayed. 

26.3. Contact 
Users can query for information about a contact by submitting a query of the form ʺcontact [ID]ʺ, where ʺ[ID]ʺ is the contact ID equivalent to the ʺcontact:idʺ element in EPP ʺinfoʺ responses. This is also the ID used when referring to contacts in domain responses. 
The following information is included in Dontact records: 
• Contact ID 
• Sponsoring Registrar 
• Creation Date 
• Last Updated Date 
• EPP Status Codes 
• Contact Name 
• Organisation 
• Street Address (1-3 fields) 
• City 
• State⁄Province 
• Postcode 
• Country Code (2 character ISO-3166 code) 
• Phone number (e164a format) 
• Fax number (e164a format) 
• Email address 
An example of a contact object whois response is included in Appendix 26.2. A contact object may be associated with one or more status codes. These are represented in Whois responses as phrases rather than EPP code mnemonics. A contact object may have any of the following status codes: 
• DELETE PROHIBITED - present if the contact object has either clientDeleteProhibited or serverDeleteProhibited (or both) 
• TRANSFER PROHIBITED - present if the contact object has either clientTransferProhibited or serverTransferProhibited (or both) 
• UPDATE PROHIBITED - present if the contact object has either clientUpdateProhibited or serverUpdateProhibited (or both) 
• PENDING TRANSFER - there is an active inter-registrar transfer for the contact object 
• LINKED - the contact object is associated with one or more domain names. A LINKED contact object automatically has the DELETE PROHIBITED status 

26.4. Nameserver 
Users can query for information about a nameserver by submitting a query of the form ʺnameserver [HOST]ʺ. The following information is included in Nameserver records: 
• Server Name 
• IPv4 address (if any) 
• IPv6 address (if any) 
• EPP status codes 
• Sponsoring Registrar 
• Creation Date 
• Referral URL (if any) 
An example of a contact object whois response is included in Appendix 26.3. A nameserver object may have an IPv4 or IPv6 address if the host is ʺin-bailiwickʺ, ie subordinate to a domain name within a TLD operated by the registry. IP address information is not shown for ʺout-of-bailiwickʺ nameservers. 
Nameserver objects may only have two status codes: 
• INACTIVE - the nameserver is not associated with any domain names 
• LINKED - the nameserver is associated with one or more domain names 
The Referral URL is the website of the Sponsoring Registrar for this nameserver. If the nameserver is subordinate to a domain name in .PLACE, this will be the sponsoring registrar of the parent name. If the nameserver is out-of-bailiwick, then the sponsoring registrar is the registrar who issued the original ʺcreateʺ request. 

26.5. Character Encoding 
All responses are encoded as UTF-8. All queries are assumed to be encoded in UTF-8. 

26.6. IDN Support 
The Whois service fully supports Internationalised Domain Names. Users may submit queries for IDN domains using either the U-label or the A-label. 

26.7. Bulk Access 
CentralNic will provide ICANN on a weekly basis (the day to be designated by ICANN) with up-to-date registration data. CentralNic will provide the following data for all registered domain names: domain name, repository object id (roid), registrar id (IANA ID), statuses, last updated date, creation date, expiration date, and name server names. For sponsoring registrars it will provide: registrar name, registrar repository object id (roid), hostname of registrar Whois server, and URL of registrar. Data will be provided in the format specified in Specification 2 for Data Escrow (including encryption, signing, etc.) but including only the fields mentioned in the above. 
At the request of ICANN, CentralNic will provide ICANN with up-to-date data for the domain names of de-accredited registrar to facilitate a bulk transfer. The data will be provided in the format specified in Specification 2 for Data Escrow. The file will only contain data related to the domain names of the losing registrar. CentralNic will provide the data within 2 business days. 

26.8. Load Projections 
As described in §31, CentralNicʹs existing Whois system receives an average of 0.36 queries per day for each domain name in the registry, including misses for non-existent objects as well as hits. 
The number of daily queries per domain was calculated for each existing gTLD was calculated using figures for the month of November 2011 published by ICANN. This analysis may be found in Appendix 26.6. It shows little correlation between the number of domains in the TLD and the number of queries that each domain receives. Smaller gTLDs such as .aero and .museum receive more queries per domain than larger gTLDs, but .jobs (which is much larger than either .aero or .museum) received more queries per domain than either. It should be noted that the high volumes observed for .XXX are very likely due to activities surrounding the Landrush and initial launch of that TLD. 
CentralNic believes that the query rate observed for its own registry system is mainly affected by its efforts to deter abuse, and its outreach to registrars, who have traditionally used whois to perform availability checks, to encourage them to use the EPP ʺcheckʺ command instead. CentralNic believes that this query rate will also apply for [TLD]. A projection of the query load for the .PLACE Whois system for .PLACE for the first 24 months of operation can be found in Appendix 26.4. This model also includes data transit rates and bandwidth projections for the same period. As can be seen, the data and bandwidth requirements are relatively small compared to those for the Shared Registry System and authoritative DNS. 

26.9. Technical Implementation 
A diagram describing the infrastructure supporting the Whois service may be found in Figure 26.1. 
During normal operations, the Whois service is operated at the primary operations centre in London. During failover conditions, it is operated at the Disaster Recovery site in the Isle of Man (see §34). 
Queries from clients pass through the firewall system to one of two front-end load balancers. Round-robin DNS is used to distribute whois queries between the two devices. The load balancers are configured in High Availability mode so that if one of the servers fails, the other can resume service on its IP address until the server can be restored. Queries are distributed to backend Whois application servers via weighted least connections algorithm. 

26.9.1. Application Server Architecture 
Whois application servers are built on commodity server hardware running the Linux operating system. The whois service is provided using the mod_whois Apache module (see http:⁄⁄modwhois.sf.net⁄). This module causes the Apache server to listen on port 43 and accept whois queries, which are then handled using a PHP script which generates and returns the response. 

26.9.2. Caching 
Whois application servers use caching to reduce database query load. Subsequent identical queries are returned a cached record until the cache expires, after which a new record is generated. Records are currently cached for 600 seconds (ten minutes), meaning that if a domain is updated immediately after its Whois record has been cached, the updated record will become visible after ten minutes. This compares favourably to the 60 minute requirement in the standard gTLD Service Level Agreement. 
Records are cached in a shared Memached server. Memcached is a high-performance caching server used by some of the largest Internet sites in the world, including Wikipedia, Flickr, Wordpress.com and Craigslist. 

26.9.2. Database 
The Whois service draws data directly from the primary registry database system. The query volume required to sustain the Whois service is comparable to that of a modest web application such as a small e-commerce site, and as a result a dedicated database for the Whois system is not required. As can be seen in Figure 26.1, a separate logging database is used to aggregate log data for use with the rate limiting system. 

26.10. Web based Whois Service 
CentralNic provides a web interface to the Whois service on its website. In addition, Applicant will provide a similar service on the www.nic.PLACE website. The web Whois acts as a proxy to the port 43 Whois service: users enter a query into an HTML form, and a server-side process submits the query to the Whois server, and displays the response. This service will not be subjected to the rate limiting described above, but users will be required to complete a CAPTCHA to prevent high-volume automated access. 

26.11. Searchable Whois Service 
Applicant will provide a Searchable Whois Service (SWS) for .PLACE. This service will be made available on the www.nic.PLACE website. The SWS provides third parties with a search interface that allows queries for partial matches against a number of domain name properties, including: 
• domain name (partial match) 
• registrant name, organisation, address, email 
• administrative, technical and billing contact information 
• Delegated nameservers 
• Nameserver IPv4⁄IPv6 address 
Access to the SWS is restricted. To gain access, users must submit an account request via the website, and agree to the terms and conditions which governs their access to the the system. These terms are included as Appendix 26.5. Once their request has been reviewed and approved, they are issued with credentials which permit them to login to the SWS. 
To prevent abuse of the SWS, users may only make fifty queries per day initially. This limit can be increased upon request and demonstration of legitimate need. 

26.12. Anti-Abuse Mechanisms 
CentralNic has implemented measures to mitigate the threat of abuse of the Whois service. The primary threat to the Whois service are so-called ʺdictionaryʺ attacks, where the attacker attempts to enumerate the Whois database by flooding the server with queries for domains taken from a precompiled list: since zone files are easy to obtain, this presents a threat to the privacy of contact information in the registry database. The contact information harvested can be used to compile email databases for spamming, or to send domain renewal scam letters, for example. 
The Whois service implements rate-limiting to impede dictionary attacks. Each time a query is received, a counter associated with the client IP address is incremented. For subsequent queries, this counter determines the number of queries received within the previous hour. If the number of queries exceeds a pre-set maximum (currently 240 queries per hour), then the server returns an error, warning the user that they have exceeded the permitted query rate. If the user stops sending queries, then eventually the query rate will drop below the limit, and subsequent queries will be permitted. If the user continues to send queries, and the query rate exceeds the limit by a further 25% (300 queries per hour), then the IP address is permanently blocked. For queries over IPv6 (where an attacker might have access to billions of IP addresses), the enclosing ⁄48 will be blocked. 
CentralNicʹs experience indicates that is an effective mechanism for preventing abuse of the Whois. The rate limit has been tuned to ensure that legitimate uses of the Whois are allowed, but abusive use of the whois is restricted to levels which make it unappealing for attackers. 
CentralNic keeps a ʺwhite listʺ of IP addresses used by legitimate high-volume users of the Whois service. These include law enforcement organisations, brand protection agencies, and other research and anti-abuse entities. All registrar access lists are also incorporated into the white list, and IP addresses registered on the ICANN RADAR system will also be included. Queries from IP addresses that appear on the white list are not subject to the rate-limiting system (as they have unlimited access to the data through the EPP system). Interested parties can request addition to the white list by contacting CentralNicʹs public customer service team. 
The web-based Whois does not implement rate-limiting, but users of this service must complete a CAPTCHA to access Whois records. 

26.12.1. Denial-of-Service attacks 
The rate-limiting system in place provides protection against DoS and DDoS attacks, as any host that attempts to flood the Whois service with queries will be very quickly blocked. However, a DDoS attack could still saturate upstream links requiring filtering at the edges of CentralNicʹs network, as well as their upstream providers. Continuous surveillance and monitoring of the Whois system (see §42) will proactively detect and defend against these threats. As the Whois service directly queries the primary SRS database, CentralNic maintains rate-limiting on the database backend to prevent a DDoS attack against the Whois service from disrupting registrar access to the SRS. 

26.13. Monitoring and Logging 
Remote monitoring is used to verify the availability of the service and to record the round-trip times for different queries (warm hit, warm miss). Local monitoring records query volumes. 

26.14. Resourcing 
As can be seen in the Resourcing Matrix found in Appendix 23.2, CentralNic will maintain a team of full-time developers and engineers which will contribute to the development and maintenance of this aspect of the registry system. These developers and engineers will not work on specific subsystems full-time, but a certain percentage of their time will be dedicated to each area. The total HR resource dedicated to this area is equivalent to almost one full-time person (83%. 
CentralNic operates a shared registry environment where multiple registry zones (such as CentralNicʹs domains, the .LA ccTLD, this TLD and other gTLDs) share a common infrastructure and resources. Since the TLD will be operated in an identical manner to these other registries, and on the same infrastructure, then the TLD will benefit from an economy of scale with regards to access to CentralNicʹs resources. 
CentralNicʹs resourcing model assumes that the ʺdedicatedʺ resourcing required for the TLD (ie, that required to deal with issues related specifically to the TLD and not to general issues with the system as a whole) will be equal to the proportion of the overall registry system that the TLD will use. After three years of operation, the optimistic projection for the TLD states that there will be [30,000] domains in the zone. CentralNicʹs resource model (described in Appendix 23.3) therefore projects that the TLD will require [0.67]% of the total resources available for this area of the registry system. 
In the event that registration volumes exceed this figure, CentralNic will proactively increase the size of the Technical Operations and Technical Development teams, (and if necessary, the support team) to ensure that the needs of the TLD are fully met. Revenues from the additional registration volumes will fund the salaries of these new hires. Nevertheless, CentralNic is confident that the staffing outlined above is sufficient to meet the needs of the TLD for the first 18 month

Question No. 27
The lifecycle of a domain in the registry is described in Figure 27.1, and closely follows that of domain names in existing gTLD registries. The lifecycle is described below. 

27.1. Available 
The domain is not registered. No delegation (or any other records) exist in the DNS, and the whois system will return a ʺNOT FOUNDʺ response to queries. An EPP ʺcheckʺ command will return an ʺavailʺ status of 1. 

27.2. Registered 
A registar submits an EPP ʺcreateʺ command or registers the domain name via the Registrar Console. The registration fee is deducted from the registrarʹs balance. The initial registration period may be any whole number of years between one (1) and ten (10). 
For five (5) calendar days after the registration of the domain, the registrar can delete the domain and receive a credit for the registration fee (subject to the Add Grace Period Limits Policy). 
While the domain is registered, it is delegated to the specified name servers and will resolve normally. During this time, the registrar may update the domain nameʹs DNS settings, lock statuses and contact associations, and may extend the registration period (subject to a maximum of ten (10) years) by submitting a ʺrenewʺ EPP command or using the Registrar Console. 
The domain may also be transferred to a different sponsoring registrar. Upon such transfer the domain name is automatically renewed for one year. 

27.3. Expired 
When the expiry date is reached, the domain name is automatically renewed for a period of one year, and the renewal fee is deducted from the registrarʹs account. 
For forty-five (45) days after the auto-renewal (Auto-Renew Grace Period), the registrar can delete the domain and receive a credit for the renewal fee. 

27.4. Redemption Grace Period 
Should the registrar delete the domain, the domain enters the Redemption Grace Period. During this period, the domain name will no longer resolve as all delegation information is removed from the TLD zone. 
For the first thirty (30) days after receipt of the delete request, the domain is in the ʺPending Delete Restorableʺ state. During this time, the registrar may submit an RGP restore request via EPP or the Registrar Console. The domain is then placed into the ʺPending Restoreʺ state. 
The registrar must then submit an RGP Restore Report detailing the reason why the restore request has been submitted. If the Restore Report is received within five (5) calendar days of the original restore request, then the domain is restored. However, if the Restore Report is not received within this period, then the domain falls back into the ʺPending Delete Restorableʺ state. 

27.5. Redemption Period State Diagram 
Figure 27.2 describes the state diagram for domain names in the Redemption Grace Period. This diagram is taken from RFC 3915. 

27.6. Pending Delete 
Forty (40) days after the receipt of the delete request, the domain leaves the ʺPending Delete Restorableʺ and enters the ʺPending Deleteʺ status. The registrar cannot submit a Restore Request during this period. 

27.7. Released 
Five (5) days after the domain enters the ʺPending Deleteʺ status the domain name is purged from the database and is once again available for registration. 

27.8. Other Grace Periods 
The registry also implements the following grace periods. In general, these grace periods allow registrars to delete domain names following billable transactions and receive a refund. 

27.8.1. Add Grace Period 
As described above, the Add Grace Period (AGP) is the five (5) calendar days following the initial registration of the domain. 

27.8.2. Auto-renew Grace Period 
As described above, the Auto-renew Grace Period is the forty five (45) calendar days following the auto-renewal of the domain. 

27.8.3. Renew Grace Period 
The Renew Grace Period is the five (5) calendar days following the renewal of the domain via an EPP ʺrenewʺ command, or via the Registrar Console. 

27.8.4. Transfer Grace Period 
The Transfer Grace Period is the five (5) calendar days following the successful completion of an inter-registrar transfer. 

27.9. Hold Periods 
The registry implements the following hold periods: 

27.9.1. Registration Hold Period 
The Registration Hold Period forbids inter-registrar transfers of domain names within sixty (60) days of initial registration. 

27.9.2. Transfer Hold Period 
The Transfer Hold Period forbids transfers of domain names within sixty (60) days of a previous inter-registrar transfer. This Hold Period does not affect disputed transfers that are undone by the registry following the outcome of a Transfer Dispute Resolution process. 

27.10. Lock Statuses 
The registry system permits the following lock statuses for domain names: 

27.10.1. clientHold 
This status may be set by registrars using an EPP ʺupdateʺ command, or via the Registrar Console. Domains with this status are removed from the DNS and will not resolve. 

27.10.2. clientDeleteProhibited 
This status may be set by registrars using an EPP ʺupdateʺ command, or via the Registrar Console. When set, all attempts by the registrar to delete the domain using an EPP ʺdeleteʺ command will be refused with EPP response code 2304 (Status Prohibits Operation). Registrars must remove the code using an EPP ʺupdateʺ command before they can delete the domain. 

27.10.3. clientRenewProhibited 
This status may be set by registrars using an EPP ʺupdateʺ command, or via the Registrar Console. When set, all attempts by the registrar to renew the domain using an EPP ʺrenewʺ command will be refused with EPP response code 2304 (Status Prohibits Operation). Registrars must remove the code using an EPP ʺupdateʺ command before they can renew the domain. 

27.10.4. clientUpdateProhibited 
This status may be set by registrars using an EPP ʺupdateʺ command, or via the Registrar Console. When set, all attempts by the registrar to update the domain using an EPP ʺupdateʺ command will be refused with EPP response code 2304 (Status Prohibits Operation), unless the ʺupdateʺ request frame includes a ʺremʺ element to remove this status. Once the status has been removed, subsequent ʺupdateʺ commands will succeed. 

27.10.5. clientTransferProhibited 
This status may be set by registrars using an EPP ʺupdateʺ command, or via the Registrar Console. When set, all attempts by other registrars to submit a transfer request for the the domain using an EPP ʺtransferʺ command, or via the Registrar Console, will be refused with EPP response code 2304 (Status Prohibits Operation). The sponsoring registrar must remove this status before any other registrar can submit a transfer request. 

27.10.6. serverHold 
This status is set by the registry in accordance with policy. It cannot be removed by registrars. Domains with this status are removed from the DNS and will not resolve. 

27.10.7. serverDeleteProhibited 
This status is set by the registry in accordance with policy. It cannot be removed by registrars. When set, all attempts by the registrar to delete the domain using an EPP ʺdeleteʺ command will be refused with EPP response code 2304 (Status Prohibits Operation). 

27.10.8. serverUpdateProhibited 
This status is set by the registry in accordance with policy. It cannot be removed by registrars. When set, all attempts by the registrar to update the domain using an EPP ʺupdateʺ command will be refused with EPP response code 2304 (Status Prohibits Operation). 

27.10.9. serverRenewProhibited 
This status is set by the registry in accordance with policy. It cannot be removed by registrars. When set, all attempts by the registrar to renew the domain using an EPP ʺrenewʺ command will be refused with EPP response code 2304 (Status Prohibits Operation). 

27.10.10. serverTransferProhibited 
This status is set by the registry in accordance with policy. It cannot be removed by registrars. When set, all attempts by the registrar to transfer the domain using an EPP ʺtransferʺ command will be refused with EPP response code 2304 (Status Prohibits Operation). 

27.11. Lifecycle Processing 
Domain names move through the lifecycle in one of two ways: in real-time as a result of registrar activity, or during daily billing runs. 
Billing runs take place once per day. The billing run performs the following batch jobs: 
• auto-renewal of expired domains 
• processing of registration and renewal fees for domains that move outside their grace periods 
• processing of domains in the RGP state (from restorable to not restorable, checking for missing restore reports, etc) 
• purging of domains scheduled for deletion 
The billing runs also perform registrar account management functions such as generation of invoices, sending balance warnings, and generation of internal reports. 

27.12. Inter-Registrar Transfer Period 
When a transfer request is received, the action date of the transfer is set to five (5) calendar days from the moment of the original request. Successful transfers are approved at the end of this period. 

27.13. pendingCreate Status 
The Registry system supports the ʺpendingCreateʺ status for domain names, as described in RFC 5731, §3.3. Domains in this state are fully registered in the database (subsequent ʺcreateʺ commands would fail with an Object Exists error) but are not present in the DNS. 
This status is used when a particular TLD implements a policy whereby registration requests are verified by a third party such as a Sponsoring Organisation or Validation Agent. Following out-of-band review of the request, the registration may be approved or denied. 
If a request is denied, then the domain is immediately purged from the registry system, and the registrar notified via email and the EPP message queue. The registrar also receives a credit for the registration fee. If approved, then the pendingCreate status is removed from the domain which begins to resolve. 

27.14. Resourcing 
The domain registration lifecycle is managed through automated backend processes that generally require no human intervention, and real-time business logic implemented in Shared Registry System application code. Operations personnel will be responsible for maintaining and developing the computing infrastructure which supports the lifecycle processing systems. Backend systems are hosted on a flexible virtual infrastructure hosted at the primary operations centre at the Goswell Road Data Centre in London. 
The domain registration lifecycle does have customer and registrar support requirements, so a proportion of the time of the Operations Manager, Support Manager and Support Agent has been dedicated to this area. This time primarily relates to dealing with questions and comments from registrars and registrants about the status of their domain names. 
As can be seen in the Resourcing Matrix found in Appendix 23.2, CentralNic will maintain a team of full-time developers and engineers which will contribute to the development and maintenance of this aspect of the registry system. These developers and engineers will not work on specific subsystems full-time, but a certain percentage of their time will be dedicated to each area. The total HR resource dedicated to this area is equivalent to 30% of a full time person. Because of the maturity and stability of this system (which has been in use for more than 16 years), only 5% of time of a technical developer has been allocated to this area. 
CentralNic operates a shared registry environment where multiple registry zones (such as CentralNicʹs domains, the .LA ccTLD, this TLD and other gTLDs) share a common infrastructure and resources. Since the TLD will be operated in an identical manner to these other registries, and on the same infrastructure, then the TLD will benefit from an economy of scale with regards to access to CentralNicʹs resources. 
CentralNicʹs resourcing model assumes that the ʺdedicatedʺ resourcing required for the TLD (ie, that required to deal with issues related specifically to the TLD and not to general issues with the system as a whole) will be equal to the proportion of the overall registry system that the TLD will use. After three years of operation, the optimistic projection for the TLD states that there will be [30,000] domains in the zone. CentralNicʹs resource model (described in Appendix 23.3) therefore projects that the TLD will require [0.67]% of the total resources available for this area of the registry system. 
In the event that registration volumes exceed this figure, CentralNic will proactively increase the size of the Technical Operations and Technical Development teams, (and if necessary, the support team) to ensure that the needs of the TLD are fully met. Revenues from the additional registration volumes will fund the salaries of these new hires. Nevertheless, CentralNic is confident that the staffing outlined above is sufficient to meet the needs of the TLD for the first 18 months of operation. 

Question No. 28
Top Level Domain registries stand in a unique position within the global DNS infrastructure. 
TLD registries collect registrants’ registration data and so normally “know” the person responsible for a particular domain name. TLD registries record associations between domain names, registrars and registrants and therefore are in the core of the control chain for every domain name in the TLD. Registries also directly control the delegation records and therefore have the power to enable or disable a particular domain name in the DNS. 
This unique position gives power and calls for responsibility. Applicant as a future TLD registry recognizes its important role in maintaining law and order and is committed to acting in the best interests of the public. 
Hereby we provide a description of the principles and procedures we will apply to mitigate abusive conduct. 

28.1. Single Abuse Point of Contact 
To streamline the information flow and to facilitate ease of communication with the public Applicant will dedicate a single abuse point of contact responsible for addressing matters requiring expedited attention and providing a timely response to abuse complaints concerning all names registered in the TLD. The contact information will consist of at least an email address and a telephone number. This point of contact will be prominently published on the registry website by the commencement of the Sunrise period. 
Applicant will ensure that: 
• The e-mail account is continuously monitored and all communication securely stored 
• The telephone number is either answered by a live person or diverted to a monitored voicemail account. 
• Abuse contact information will be kept current and will be updated should it ever change in a timely manner 
Messages received through the published abuse point of contact will be processed via the same procedure and within the same timeframe as the signals coming from the monitoring systems. Each message, both via email and phone channels, triggers the creation of a support ticket in a dedicated queue and procedures for ticket escalation exist. Messages originating from law enforcement authorities are by default assigned an escalated level. For critical tickets personnel is available 24x7 to react accordingly. 
Applicant and CentralNic commit to responding to all abuse complaints within 24 hours of receipt (on a 24x7 basis). During the time periods when its global offices are open (typically 8am-6pm in London, Los Angeles and Dubai) response times are expected to be substantially faster, at around 2-3 hours. 

28.2. Policy on Handling Complaints Regarding Abuse 
Applicant is prepared to deal with situations where registry intervention may be required in order to stop illegal activity, prevent abusive conduct or to enforce the law. 
Applicant will adopt a comprehensive Eligibility and⁄or Acceptable Use Policy that will establish what constitutes acceptable use of the domain and will contain a description of procedures registry that will apply to enforce the Policy. The initial policy is described in detail in 18.b.iv. 
An enforcement action may be triggered by a variety of events including complaints from the public, registrars or ICANN, decisions of a competent dispute resolution provider, outreach from a governmental agency or findings produced by internal investigation or monitoring processes. 
Normally if abusive behaviour in a TLD is encountered, the reports of such behaviour and the evidence available will be analysed by the Registry. If the Registry, in its sole discretion, concludes that a Domain Name Holder has indeed violated a TLD Policy, the registrant will be given a notice and opportunity to correct the breach. 
Furthermore, the registry reserves the right to lock the domain name or put it on hold (preventing domain resolution in the DNS). In extreme cases where a domain is involved in malicious or illegal activity there are provisions for rapid takedown of the domain name in question. The situations in which rapid takedown provisions may be applied, include, but are not limited to: 
• Phishing 
• Pharming 
• Distribution of illegal content 
• Distribution of malware 
• Fast flux hosting 
• Botnetting 
• Unauthorized access to information systems 
• Threats to the security and⁄or stability of the TLD 
The .PLACE Eligibility and Acceptable use Policy will be incorporated into the Registry-Registrar agreements and Registrars will be required to pass through the requirements to comply with the policy to the registrants. 
Applicant will take reasonable steps to investigate and respond to any reports of illegal activity in connection with the use of the TLD and will cooperate with the competent governmental agencies in such investigations. 
Applicant will utilize the expert services of its registry services provider CentralNic to implement and enforce all of our anti-abuse policies in our TLD. CentralNic has dedicated and scalable resources for this function, described below. 
CentralNic has long experience in the domain registry business, and is an industry leader with respect to its anti-abuse policies. CentralNic has a dedicated Dispute Resolution Policy in place with WIPO, found at WIPO’s website: http:⁄⁄www.wipo.int⁄amc⁄en⁄domains⁄gtld⁄cnic⁄index.html. CentralNic has trained personnel who handle interaction with WIPO, to ensure that panelists’ decisions are carried out expeditiously as required by the DRP. 
CentralNic also enforces a Policy on Phishing and Fraud, found at its dedicated Phishing & Abuse page at the following website: https:⁄⁄www.centralnic.com⁄support⁄abuse. Pursuant to clause 13, sections (f) and (h) of CentralNicʹs Terms and Conditions, CentralNic may cancel the registration or suspend registration of a domain name: 
(f) if CentralNic believes that the domain name was registered for use in a ʺphishingʺ attack or other illegal activity of any kind. 
(h) if inaccurate or false contact details are provided. 
Further to these conditions, CentralNic operates the following policy regarding suspected ʺphishingʺ domain names: 
- If we have a reasonable suspicion that a domain name registered at CentralNic is being used in a phishing attack, or otherwise being used for other illegal activities, we will place the domain name ʺOn Holdʺ and under a Registry Lock. - We will then notify the current registrar for the domain name. If the registrar can provide confirmation that the domain name was registered in ʺgood faithʺ by the registrant, then CentralNic will immediately unlock the domain name and place it on the ʺLiveʺ status. - If no confirmation is received, or the registrars agree that the domain name was registered in ʺbad faithʺ, the domain name will be placed onto ʺPending Deletionʺ, and will be fully deleted from the database after 45 days. 

28.3. Orphan Glue 
CentralNicʹs registry system includes effective measures to prevent the abuse of orphan glue records. 
Firstly, the Shared Registry System will reject any request to create host object that is the child of a non-existent domain name. That is, if EXAMPLE.PLACE does not exist, then NS0.EXAMPLE.PLACE cannot be created. If the parent domain name does exist, then only the sponsoring registrar of that domain is permitted to create child host objects. 
CentralNicʹs registry system currently follows the third model described in the SAC 048 report: orphan glue records are deleted from the registry and removed from the DNS when the parent domain name is deleted. If other domains in the database are delegated to orphan hosts that are removed, then the delegation is also removed from these domains. 

28.4. Measures to Maintain Whois Accuracy 
Applicant will operate a “thick” WHOIS system, in which all registrants’ contact information will be stored in a single database maintained by the registry. Accredited registrars will have the ability to change the records in that database through the Shared Registration System. The Registry-Registrar agreement requires registrars to ensure that the WHOIS data is accurate at the time of submission and also requires the information provided on the system to be updated in a timely manner in case of any changes. Corresponding provisions also exist in the Registrar Accreditation Agreement (RAA), para. 3.7.7. 
In addition to the standard measures described above, the .PLACE WHOIS system will feature extra levels of reliability with regards to Whois information. 

28.4.1. Extra checks on WHOIS data 
Applicant, through its Registry-Registrar agreements will require registrars to perform the following additional checks on the WHOIS data: 
• Verify syntactic correctness of email addresses and phone numbers by validating them against the corresponding standards 
• Verify that the domain holder receives email at the addresses listed in WHOIS as registrant’s email address and administrative contact email address, by requiring them to click a unique web link that is sent to those addresses. 
28.4.2. Random audits of WHOIS records by the Registry 
Applicant will periodically (at least once every 12 months) perform a random check of WHOIS records in .PLACE for prima facie evidence of fraudulent or inaccurate WHOIS information. For those suspicious records that may be found, Applicant will further require registrars to conduct a reasonable investigation and to respond with one of the three possible actions: 
• confirm that the information provided in WHOIS is accurate, or 
• correct the WHOIS information, or 
• delete the domain name(s). 
The measures described above exceed the ICANN requirements and are adequate to improve accuracy of WHOIS information while maintaining low implementation cost for registrars and good user experience for registrants. 

28.5. Resourcing 
Applicant and CentralNic will provide abuse response on a 24x7 basis. The resourcing to fulfill this function will be provided by a combined team of support and operations personnel. The first response function will be provided by support agents during normal office hours, with this responsibility being passed to the Network Operations Centre(NOC) during 24x7 operations. 
As can be seen in the Resourcing Matrix found in Appendix 23.2, CentralNic will maintain a team of full-time developers and engineers which will contribute to the development and maintenance of this aspect of the registry system. These developers and engineers will not work on specific subsystems full-time, but a certain percentage of their time will be dedicated to each area. The total HR resource dedicated to this area is equivalent to 75% of a full-time role. 
CentralNic operates a shared registry environment where multiple registry zones (such as CentralNicʹs domains, the .LA ccTLD, this TLD and other gTLDs) share a common infrastructure and resources. Since the TLD will be operated in an identical manner to these other registries, and on the same infrastructure, then the TLD will benefit from an economy of scale with regards to access to CentralNicʹs resources. 
CentralNicʹs resourcing model assumes that the ʺdedicatedʺ resourcing required for the TLD (ie, that required to deal with issues related specifically to the TLD and not to general issues with the system as a whole) will be equal to the proportion of the overall registry system that the TLD will use. After three years of operation, the optimistic projection for the TLD states that there will be [30,000] domains in the zone. CentralNicʹs resource model (described in Appendix 23.3) therefore projects that the TLD will require [0.67]% of the total resources available for this area of the registry system. 
In the event that registration volumes exceed this figure, CentralNic will proactively increase the size of the Technical Operations and Technical Development teams, (and if necessary, the support team) to ensure that the needs of the TLD are fully met. Revenues from the additional registration volumes will fund the salaries of these new hires. Nevertheless, CentralNic is confident that the staffing outlined above is sufficient to meet the needs of the TLD for the first 18 months of operation. 

28.6. Periodic review of anti-abuse policies 
Applicant acknowledges that new types of abusive behaviour emerge in cyber space and is prepared to take steps to counter any new types of abuse. Applicant will periodically (once every 12 months, or more frequently depending on the circumstances) require CentralNic to provide reports regarding the received abuse-related complaints. Such reports should contain categorisation of the abusive behaviour reported, actions taken and response time. Applicant will analyse the reports and will review its anti-abuse policies to continually improve the handling of abuse complaints. 

Question No. 29
Applicant recognizes providing appropriate mechanisms to protect legal rights of others as one of the core objectives of the Registry. Applicant will follow rules and policies developed by ICANN with regards to Rights Protection Mechanisms (RPMs). Applicant will fully comply with Specification 7 of the new gTLD registry agreement and will provide additional rights protection mechanisms over and above the ICANN requirements. Both standard and additional RPMs are described below. 

29.1. Sunrise Period 
Prior to the open registration phase Applicant will offer a priority registration period for owners of trademarks and service marks. This period will last at least 30 days. 
Applicant will support Trademark Clearinghouse (TCH) once it is implemented by ICANN. Owners of trademarks pre-validated by the Clearinghouse will be able to secure their domain registrations during the Sunrise period without further verification of their intellectual property rights. 
The flowchart of the Sunrise and eligibility validation process is available in Figure 24.4. 

29.1.1. Sunrise Eligibility Requirements 
Any entity that holds a trademark or service mark will be qualified to register a domain during the Sunrise period. Registrations obtained during the Sunrise Period will be subject to challenge as described below. 
As a minimum, the Registry will recognize as qualifying all word marks that: 
• Are nationally or regionally registered and for which proof of use is available, or 
• Marks that have been validated by the court, or 
• Marks that are specifically protected by a statute or treaty. 
All the Sunrise Eligibility requirements will have to be met by the cut-off date which will be announced in due course. 
Full details of the Sunrise registration process will be finalized after the Trademark Clearinghouse service is implemented and full documentation, policies, terms and conditions are made available. For guidance, data items that will need to be provided by the qualifying applicant to apply for a .PLACE Sunrise registration are listed below: 
• name or description of the trademark 
• registration number 
• registration date 
• country of registration 
• capacity of the applicant 
• reference to the Trademark Clearinghouse database record 
• Representation that the information provided is true and correct 

29.1.2. Sunrise Challenge Process 
The result of the evaluation of Sunrise applications will be published on the Registry website. A process will be in place to allow third parties to dispute the registrant rights to own a domain name. Applicant will engage with a reputable adjudicator to manage the Sunrise challenge process. The adjudicator will charge a reasonable fee for Sunrise challenges. 
The Sunrise Challenge rules will allow challenges based on at least the following four grounds: 
• at the 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; 
• the domain name is not identical to the mark on which the registrant based its Sunrise registration; 
• the trademark registration on which the registrant based its Sunrise registration is not of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; or 
• 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. 

29.2. Trademark Claims Service 
The Trademark Claims service will be launched by the registry as soon as the open registration period starts and will be provided for at least 90 days (exceeding the period mandated by ICANN). The Applicant will review the effect of the Trademark Claims service and based on the results of such review Applicant is prepared to consider providing the Trademark Claims service on an ongoing basis. 
The essence of the Trademark Claims service is as follows: if a domain name registration is attempted for which there exists a matching record in the Trademark Clearinghouse database, then the prospective registrant will be presented with a notice that third party trademark rights exist for a matching designation and will be required to provide a statement that to the best of his or her knowledge, the registration and use of the requested domain name will not infringe on the rights of the trademark holders. 
If the registrant chooses to proceed with the registration, the corresponding trademark holder(s) will be notified that such registration has taken place. 
Operational rules of the Trademark Claims service are heavily dependent on the specific implementation of the Trademark Clearinghouse which is not yet available in writing. Therefore full details of the Trademark Claims service will be finalized after the TCH is implemented by ICANN and full documentation, policies, terms and conditions become available. 

29.3. Uniform Domain Name Dispute Resolution Policy (UDRP) 
The Uniform Domain Name Dispute Resolution Policy is an ICANN consensus policy for adjudication of disputes between domain name holders and owners of matching trademarks. Every registrant must agree to this mandatory administrative procedure in its Domain Registration Agreement with the registrar. Registrars have certain responsibilities to facilitate adjudication of UDRP disputes and to enforce the decisions of the arbitration panels. 
.PLACE will comply with the Uniform Domain Name Dispute Resolution Policy or with any successor thereof. The UDRP will be incorporated by reference into Registry-Registrar Agreements. Similarly, Registrars will be required to incorporate it into their Domain Registration agreements with the Registrants. 
The UDRP process does not provide for any participation by the Registry and is fully borne by the Registrar, Registrant, Complainant and the Dispute Resolution Provider. However, Applicant is prepared to collaborate with all relevant stakeholders to ensure UDRP decisions are implemented. 
CentralNic, Applicant’s registry services provider, has maintained a similar dispute resolution policy with WIPO which is available at http:⁄⁄www.wipo.int⁄amc⁄en⁄domains⁄gtld⁄cnic⁄index.html. CentralNic has dedicated personnel trained to address these types of complaints and to communicate with WIPO and other relevant stakeholders. 

29.4. Uniform Rapid Suspension System (URS) 
The Uniform Rapid Suspension System (URS) described in the ICANN gTLD Applicant Guidebook is a new Rights Protection Mechanism for rapid takedown of domain names that by clear and convincing evidence infringe on legitimate trademark rights of third parties. 
As opposed to the UDRP procedure, registries are required to participate in the URS procedure and enforcement of the URS decisions. Applicant will comply with the URS policy once implemented by ICANN. 
The current URS procedure as described in the Applicant Guidebook is as follows: within 24 hours of receipt of the Notice of Complaint from a URS Provider, the Registry has to lock the domain, restricting all changes to the registration data, including transfer and deletion. The domain name will continue to resolve at this stage. The Registry will notify the URS Provider immediately upon locking the domain name. 
If the URS Determination is in favour of Complainant, upon receipt of the Determination the Registry will suspend the domain name which is intended to remain suspended for the balance of the registration period and will not resolve to the original web site. Instead, the nameservers will be redirected to an informational web page provided by the URS Provider about the URS. The Whois record for the domain name will continue to display all of the information of the original Registrant except for the redirection of the nameservers. In addition, the Whois will reflect that the domain name will not be able to be transferred, deleted or modified for the life of the registration. 
If the URS Determination is in favour of the Respondent, the Registry will remove the lock status from the domain name allowing the registrant to continue using it normally. 
The URS compliance function will be performed by CentralNic and overseen by the Applicant. Given CentralNic long-standing experience in dealing with trademark-related disputes in domain names, Aplicant has no doubt that this function will be performed by CentralNic flawlessly. 

29.5 Mediation 
CentralNic has implemented a solution that complements the UDRP by adopting a best practice of Nominet and other ccTLDs. CentralNic has experienced a high percentage of domain disputes resolved without the need for filing a formal and relatively expensive UDRP complaint, by offering informal mediation to any person or entity who submits a Request for Mediation to the registry. The Mediation rules that CentralNic intends to apply to gTLDs are copied below: 
ʺCentralNicʺ means CentralNic Ltd, 35-39 Moorgate, London EC2R 6AR, United Kingdom. 
ʺComplainantʺ means the party submitting a Request for Mediation concerning a Domain Name registration pursuant to the CentralNic Mediation Rules. 
ʺDomain Nameʺ means any domain name registered under a sub-domain provided by CentralNic. 
ʺMediationʺ means a mediation conducted by CentralNic in accordance with the CentralNic Mediation Rules that are incorporated by reference and made a part of the Registration Agreement. 
ʺPartyʺ means a Complainant or a Respondent. 
ʺRegistration Agreementʺ means the agreement between CentralNic and a Domain Name holder. 
ʺRespondentʺ means the holder of a Domain Name registration in respect of which a Request for Mediation is submitted pursuant to the CentralNic Mediation Rules. 
1. Request for Mediation: (a) Any person or entity may submit a Request for Mediation relating to a Domain Name registration in accordance with the CentralNic Mediation Rules. A copy of the Request for Mediation shall be sent to the Respondent and to CentralNic. (b) The Request for Mediation shall be submitted in writing by e-mail and shall: (i) State that the Complainant wishes to submit the dispute to Mediation in accordance with the CentralNic Mediation Rules; (ii) Provide the name, postal and e-mail addresses, and the telephone and telefax numbers of the Complainant and of any representative authorized to act for the Complainant in the Mediation; (iii) Specify a preferred method for communications directed to the Complainant in the Mediation (including person to be contacted, medium, and address information); (iv) Provide the name of the Respondent and all information (including any postal and e-mail addresses and telephone and telefax numbers) known to Complainant regarding how to contact the Respondent or any representative of the Respondent, including contact information based on pre-Request dealings; (v) Specify the Domain Name(s) that is⁄are the subject of the Request; (vi) Contain a brief statement of the nature of the dispute. (c) The Request for Mediation may relate to more than one Domain Name, provided that the Domain Names are registered by the same Domain-Name holder. 
2. Commencement: (a) The date of commencement of the Mediation shall be the date on which the Request for Mediation is received by CentralNic. (b) CentralNic shall inform the Parties of the receipt by it of the Request and of the date of commencement of the Mediation. 
3. Mediation: (a) CentralNic shall conduct the Mediation in a manner which CentralNic, in its sole discretion, considers appropriate. (b) The language of the Mediation shall be English, unless decided otherwise by CentralNic. (c) CentralNic will not reveal details of the Mediation to any third parties unless ordered by a court of competent jurisdiction or required by applicable laws or regulations or except as may be provided under the CentralNic Dispute Resolution Policy and the Rules for CentralNic Dispute Resolution Policy. 
4. Termination of the Mediation: The Mediation will terminate ten (10) calendar days after the date of commencement. At the request of the Parties or on its own motion, CentralNic may, in exceptional cases, extend the period of time for the Mediation. The fact of termination shall be recorded by CentralNic. 
5. Fees: No fees shall be payable by either party for the conduct of the Mediation. 
6. Exclusion of Liability: Except in the case of deliberate wrongdoing, CentralNic shall not be liable to a Party for any act or omission in connection with the Mediation. 
7. Waiver of Defamation: The Parties agree that any statements or comments, whether written or oral, made or used by them or their representatives in preparation for or in the course of the Mediation shall not be relied upon to found or maintain any action for defamation, libel, slander or any related complaint, and this Paragraph may be pleaded as a bar to any such action. 
8. Amendments: CentralNic reserves the right to modify these Rules at any time. CentralNic will post the revised Rules at at least thirty (30) calendar days before they become effective. The version of these Rules in effect at the time of the submission of the Request for Mediation to CentralNic shall apply to the Mediation commenced thereby. 
Applicant notes this is CentralNic’s current policy for its current registry businesses. Applicant may make modifications to this Policy, without limitation by charging a reasonable fee and⁄or by specifying the mediation mechanism, as its business plans develop prior to launch of the TLD. However, Applicant remains committed to offering a less formal and less expensive procedure than the UDRP, and perhaps even the URS, to the extent commercially feasible. 

29.6 Abusive use⁄takedown policies 
Answer to question 28 contains a detailed description of measures that the Applicant will take to prevent and mitigate abusive registrations and the description of policies that the Applicant will apply to handle complaints regarding abuse and take down abusive registrations. To summarise, 
• Applicant will dedicate a single abuse point of contact. Correspondence and complaints coming through that point of contact will be continuously monitored and responded to within 24 hours 
• Applicant will adopt a comprehensive Eligibility and⁄or Acceptable Use Policy that will set forth the limits of acceptable use of domains and the procedures the Registry will apply in case of violations of applicable laws or policies, including takedown procedures. The initial Acceptable Use Policy is described in section 18.b.iv 
• Applicant will delete orphan glue records once the parent domain is deleted to prevent abuse of these orphan glue records 
• Applicant will require registrars to perform extra checks on WHOIS data to improve its accuracy 
• Applicant will perform random audits of WHOIS data and will flag suspicious registrations via registrars 

29.7. Post-Delegation Dispute Resolution Procedure 
Applicant reaffirms its intent to comply with the ICANN-mandated Post-Delegation Dispute Resolution Procedure (PDDRP). 
Applicant believes that its choice of TLD string and the way the TLD is intended to be operated represents a good faith offering of Top Level Domain Registry service and does not infringe on any legitimate third party trademark rights. 

Applicant also reaffirms its commitment to maintain .PLACE free of violations of third party trademark rights through second level domain registration and use. Applicant has all the required resources, policies and procedures in place to address any situations of abuse without the need to invoke the PDDRP procedure. 

29.8. Resourcing 
The Rights Protection Mechanisms described above include a combination of both technical and non-technical systems: for example, the Trademark Claims Service may (depending on the final specification published by ICANN) require development, maintenance and support of an EPP extension, as well as real-time integration with the TCH API, whereas the UDRP is a primarily manual process of managing and responding to communications from complaints, respondents and UDRP service providers. 
As can be seen in the Resourcing Matrix found in Appendix 23.2, CentralNic will maintain a team of full-time developers and engineers which will contribute to the development and maintenance of this aspect of the registry system. These developers and engineers will not work on specific subsystems full-time, but a certain percentage of their time will be dedicated to each area. The total HR resource dedicated to this area is equivalent to half of a full-time role. 
CentralNic operates a shared registry environment where multiple registry zones (such as CentralNicʹs domains, the .LA ccTLD, this TLD and other gTLDs) share a common infrastructure and resources. Since the TLD will be operated in an identical manner to these other registries, and on the same infrastructure, then the TLD will benefit from an economy of scale with regards to access to CentralNicʹs resources. 
CentralNicʹs resourcing model assumes that the ʺdedicatedʺ resourcing required for the TLD (ie, that required to deal with issues related specifically to the TLD and not to general issues with the system as a whole) will be equal to the proportion of the overall registry system that the TLD will use. After three years of operation, the optimistic projection for the TLD states that there will be [30,000] domains in the zone. CentralNicʹs resource model (described in Appendix 23.3) therefore projects that the TLD will require [0.67]% of the total resources available for this area of the registry system. 
In the event that registration volumes exceed this figure, CentralNic will proactively increase the size of the Technical Operations and Technical Development teams, (and if necessary, the support team) to ensure that the needs of the TLD are fully met. Revenues from the additional registration volumes will fund the salaries of these new hires. Nevertheless, CentralNic is confident that the staffing outlined above is sufficient to meet the needs of the TLD for the first 18 months of operation. 

Our Information Security (IS) Program and associated IS Policy, Standards and Procedures apply to all Company entities, employees, contractors, temps, systems, data, and processes. The Security Program is managed and maintained by the IS Team, supported by Executive Management and the Board of Directors.

Data and systems vary in sensitivity and criticality and do not unilaterally require the same control requirements. Our security policy classifies data and systems types and their applicable control requirements. All registry systems have the same data classification and are all managed to common security control framework. The data classification applied to all registry systems is our highest classification for confidentiality, availability and integrity, and the supporting control framework is consistent with the technical and operational requirements of a registry, and any supporting gTLD string, regardless of its nature or size. We have the experienced staff, robust system architecture and managed security controls to operate a registry and TLD of any size while providing reasonable assurance over the security, availability, and confidentiality of the systems supporting critical registry functions (i.e., registration services, registry databases, zone administration, and provision of domain name resolution services).

This document describes the governance of our IS Program and the control frameworks our security program aligns to (section 1.0), Security Policy requirements (section 2.0); security assessments conducted (see section 3.0), our process for executive oversight and visibility of risks to ensure continuous improvement (section 4.0), and security commitments to registrants (section 5). Details regarding how these control requirements are implemented, security roles and responsibilities and resources supporting these efforts are included in Security Policy B response.

2.0. INFORMATION SECURITY PROGRAM

The IS Program for our registry is governed by an IS Policy aligned to the general clauses of ISO 27001 requirements for an Information Security Management System (ISMS) and follows the control objectives where appropriate, given the data type and resulting security requirements. (ISO 27001 certification for the registry is not planned, however, our DNS⁄DNSSEC solution is 27001 certified). The IS Program follows a Plan-Do-Check-Act (PDCA) model of continuous improvement to ensure that the security program grows in maturity and that we provide reasonable assurance to our shareholders and Board of Directors that our systems and data are secure.

The High Security Top Level Domain (HSTLD) control framework incorporates ISO 27002, the code of practice for implementing an ISO 27001 ISMS. Therefore, our security program is already closely aligned HSTLD control framework. Furthermore, we agree to abide by the HSTLD Principle 1 and criteria 1.1 - 1.3. (See specifics in Security Policy B response):

Registry systems will be in-scope for Sarbanes-Oxley (SOX) compliance and will follow the SOX control framework governing access control, account management, change management, software development life cycle (SDLC), and job monitoring of all systems. Registry systems will be tested frequently by the IS team for compliance and audited by our internal audit firm, Protiviti, and external audit firm, Price Waterhouse Coopers (PWC), for compliance.

2.1. SECURITY PROGRAM GOVERNANCE

Our Information Security Program is governed by IS Policy, supported by standards, and guided by procedures to ensure uniformed compliance to the program. Standards and associated procedures in support of the policy are shown in Attachment A, Figure 1. Security Program documents are updated annually or upon any system or environment change, new legal or regulatory requirements, and⁄or findings from risk assessments. Any updates to security program are reviewed and approved by the Executive Vice President (EVP) of Information Technology (IT), EVP of Legal & General Counsel, and the EVP of People Operations before dissemination to all employees. 

All employees are required to sign the IS Policy upon hire, upon any major changes, and⁄or annually. By signing the IS Policy, employees agree to abide by the supporting Standards and Procedures applicable to their job roles. To enable signing of the IS Policy, employees must pass a test to ensure competent understanding of the IS Policy and its key requirements. 

3.0. INFORMATION SECURITY POLICY

3.1. INFORMATION ASSET CLASSIFICATION 

The following data classification is applied to registry systems: High Business Impact (HBI): Business Confidential in accordance with the integrity, availability and confidentiality requirements of registry operations. All registry systems will follow Security Policy requirements for HBI systems regardless of the nature of the TLD string, financial materiality or size. HBI data if not properly secured, poses a high degree of risk to the Company and includes data pertaining to the Company’s adherence to legal, regulatory and compliance requirements, mergers and acquisitions (M&A), and confidential data inclusive of, but is not limited to: Personally Identifiable Information (PII) (credit card data, Social Security Numbers (SSN) and account numbers); materially important financial information (before public disclosure), and information which the Board of Directors⁄Executive team deems to be a trade secret, which, if compromised, would cause grave harm to the execution of our business model. 

HBI safeguards are designed, implemented and measured in alignment with confidentiality, integrity, availability and privacy requirements characterized by legal, regulatory and compliance obligations, or through directives issued by the Board of Directors (BOD) and Executive team. Where guidance is provided, such as the Payment Card Industry (PCI) Data Security Standard (DSS) Internal Audit Risk Control Matrices (RCMs), local, state and federal laws, and other applicable regulations, we put forth the appropriate level of effort and resources to meet those obligations. Where there is a lack of guidance or recommended safeguards, Risk Treatment Plans (RTP’s) are designed in alignment with our standard risk management practices. 

Other data classifications for Medium Business Impact (MBI): Business Sensitive and Low Business Impact (LBI): Public do not apply to registry systems.

3.2. INFORMATION ASSET MANAGEMENT

All registry systems have a designated owner and⁄or custodian who ensures appropriate security classifications are implemented and maintained throughout the lifecycle of the asset and that a periodic review of that classification is conducted. The system owner is also responsible for approving access and the type of access granted. The IS team, in conjunction with Legal, is responsible for defining the legal, regulatory and compliance requirements for registry system and data.

3.3. INFORMATION ASSET HANDLING, STORAGE & DISPOSAL

Media and documents containing HBI data must adhere to their respective legal, regulatory and compliance requirements and follow the HBI Handling Standard and the retention requirements within the Document Retention Policy.

3.4. ACCESS CONTROL

User authentication is required to access our network and system resources. We follow a least-privileged role based access model. Users are only provided access to the systems, services or information they have specifically been authorized to use by the system owner based on their job role. Each user is uniquely identified by an ID associated only with that user. User IDs must be disabled promptly upon a user’s termination, or job role change. 

Visitors must sign-in at the front desk of any company office upon arrival and escorted by an employee at all times. Visitors must wear a badge while on-site and return the badge when signing out at the front desk. Dates and times of all visitors as well as the name of the employee escorting them must be tracked for audit purposes. 

Individuals permitted to access registry systems and HBI information must follow the HBI Identity & Access Management Standard. Details of our access controls are described in Part B of Question 30 response including; technical specifications of access management through Active Directory, our ticketing system, physical access controls to systems and environmental conditions at the datacenter.

3.5. COMMUNICATIONS & OPERATIONAL SECURITY

3.5.1. MALICIOUS CODE

Controls shall be implemented to protect against malicious code including but not limited to: 
- Identification of vulnerabilities and applicable remediation activities, such as patching, operating system & software upgrades and⁄or remediation of web application code vulnerabilities. 
- File-integrity monitoring shall be used, maintained and updated appropriately. 
- An Intrusion Detection Solution (IDS) must be implemented on all HBI systems, maintained & updated continuously. 
- Anti-virus (AV) software must be installed on HBI classified web & application systems and systems that provide access to HBI systems. AV software and virus definitions are updated on a regular basis and logs are retained for no less than one year. 

3.5.2. THREAT ANALYSIS & VULNERABILITY MANAGEMENT 

On a regular basis, IS personnel must review newly identified vulnerability advisories from trusted organizations such as the Center for Internet Security, Microsoft, SANS Institute, SecurityFocus, and the CERT at Carnegie-Mellon University. Exposure to such vulnerabilities must be evaluated in a timely manner and appropriate measures taken to communicate vulnerabilities to the system owners, and remediate as required by the Vulnerability Management Standard. Internal and external network vulnerability scans, application & network layer penetration testing must be performed by qualified internal resource or an external third party at least quarterly or upon any significant network change. Web application vulnerability scanning is to be performed on a continual basis for our primary web properties applicable to their release cycles. 

3.5.3. CHANGE CONTROL

Changes to HBI systems including operating system upgrades, computing hardware, networks and applications must follow the Change Control Standard and procedures described in Security Policy question 30b. 

3.5.4. BACKUP & RESTORATION

Data critical to our operations shall be backed up according to our Backup and Restoration Standard. Specifics regarding Backup and Restoration requirements for registry systems are included in questions 37 & 38.

3.6. NETWORK CONTROLS

 - Appropriate controls must be established for ensuring the network is operated consistently and as planned over its entire lifecycle. 
 - Network systems must be synchronized with an agreed upon time source to ensure that all logs correctly reflect the same accurate time.
 - Networked services will be managed in a manner that ensures connected users or services do not compromise the security of the other applications or services as required in the HBI Network Configuration Standard. Additional details are included in Question 32: Architecture response.

3.7. DISASTER RECOVERY & BUSINESS CONTINUITY

The SVP of IT has responsibility for the management of disaster recovery and business continuity. Redundancy and fault-tolerance shall be built into systems whenever possible to minimize outages caused by hardware failures. Risk assessments shall be completed to identify events that may cause an interruption and the probability that an event may occur. Details regarding our registry continuity plan are included in our Question 39 response. 

3.8 SOFTWARE DEVELOPMENT LIFECYCLE

Advance planning and preparation is required to ensure new or modified systems have adequate security, capacity and resources to meet present and future requirements. Criteria for new information systems or upgrades must be established and acceptance testing carried out to ensure that the system performs as expected. Registry systems must follow the HBI Software Development Lifecycle (SDLC) Standard. 

3.9. SECURITY MONITORING

Audit logs that record user activities, system errors or faults, exceptions and security events shall be produced and retained according to legal, regulatory, and compliance requirements. Log files must be protected from unauthorized access or manipulation. IS is responsible for monitoring activity and access to HBI systems through regular log reviews.

3.10. INVESTIGATION & INCIDENT MANAGEMENT RESPONSE

Potential security incidents must be immediately reported to the IS Team, EVP of IT, the Legal Department and⁄or the Incident Response. The Incident Response Team (IRT) is required to investigate: any real or suspected event that could impact the security of our network or computer systems; impose significant legal liabilities or financial loss, loss of proprietary data⁄trade secret, and⁄or harm to our goodwill. The Director of IS is responsible for the organization and maintenance of the IRT that provides accelerated problem notification, damage control, investigation and incident response services in the event of security incidents. Investigation and response processes follow the requirements of the Investigation and Incident Management Standard and supporting Incident Response Procedure (see Question 30b for details).

3.11. LEGAL & REGULATORY COMPLIANCE

All relevant legal, regulatory and contractual requirements are defined, documented and maintained within the IS Policy. Critical records are protected from loss, destruction and falsification, in accordance with legal, contractual and business requirements as described in our Document Retention Policy. Compliance programs implemented that are applicable to Registry Services include:

- Sarbanes Oxley (SOX): All employees managing and accessing SOX systems and⁄or data are required to follow SOX compliance controls. 
- Data Privacy and Disclosure of Personally Identifiable Information (PII): data protection and privacy shall be ensured as required by legal and regulatory requirements, which may include state breach and disclosure laws, US and EU Safe Harbor compliance directives. 

Other compliance programs implemented but not applicable to Registry systems include the Payment Card Industry (PCI) Data Security Standard (DSS), Office of Foreign Assets Control (OFAC) requirements, Copyright Infringement & DMCA. 

4.0. SECURITY ASSESSMENTS

Our IS team conducts frequent security assessments to analyze threats, vulnerabilities and risks associated with our systems and data. Additionally, we contract with several third parties to conduct independent security posture assessments as described below. Details of these assessments are provided in our Security Policy B response. 

4.1. THIRD PARTY SECURITY ASSESSMENTS

We outsource the following third party security assessments (scope, vendor, frequency and remediation requirements of any issues found are detailed in our Security Policy B response); Web Application Security Vulnerability testing, quarterly PCI ASV scans, Sarbanes-Oxley (SOX) control design and operating effectiveness testing and Network and System Security Analysis.

4.2. INTERNAL SECURITY ASSESSMENTS

The IS team conducts routine and continual internal testing (scope, frequency, and remediation requirements of any issues found are detailed in our Security Policy B response) including; web application security vulnerability testing, external and internal vulnerability scanning, system and network infrastructure penetration testing, access control appropriateness reviews, wireless access point discovery, network security device configuration analysis and an annual comprehensive enterprise risk analysis.

5.0. EXECUTIVE OVERSIGHT & CONTINUOUS IMPROVEMENT

In addition to the responsibility for Information Security residing within the IS team and SVP of IT, risk treatment decisions are also the responsibility of the executive of the business unit responsible for the risk. Any risk with potential to impact the business financially or legally in a material way is overseen by the Incident Response Management team and⁄or the Audit Committee. See Figure 2 in Attachment A. The Incident Response Management Team or Audit Committee will provide assistance with management action plans and remediation. 

5.1. GOVERNANCE RISK & COMPLIANCE 

We have deployed RSA’s Archer Enterprise Governance Risk and Compliance (eGRC) Tool to provide an independent benchmarking of risk, compliance and security metrics, assist with executive risk reporting and reduce risk treatment decision making time, enforcing continuous improvement. The eGRC provides automated reporting of registry systems compliance with the security program as a whole, SOX Compliance, and our Vulnerability Management Standard. The eGRC dashboard continuously monitors risks and threats (through automated feeds from our vulnerability testing tools and third party data feeds such as Microsoft, CERT, WhiteHat, etc.) that are actionable. See Attachment A for more details on the GRC solutions deployed.

6.0. SECURITY COMMITMENTS TO REGISTRANTS

We operate all registry systems in a highly secured environment with appropriate controls for protecting HBI data and ensuring all systems remain confidential, have integrity, and are highly available. Registrants can assume that:

1. We safeguard the confidentiality, integrity and availability of registrant data through access control and change management:
 - Access to data is restricted to personnel based on job role and requires 2 factors of authentication.
 - All system changes follow SOX-compliant controls and adequate testing is performed to ensure production pushes are stable and secure.
2. The network and systems are deployed in high availability with a redundant hot datacenter to ensure maximum availability. 
3. Systems are continually assessed for threats and vulnerabilities and remediated as required by the Vulnerability Management Standard to ensure protection from external malicious acts.
 - We conduct continual testing for web code security vulnerabilities (cross-site scripting, SQL Injection, etc.) during the development cycle and in production.
4. All potential security incidents are investigated and remediated as required by our Incident Investigation & Response Standard, any resulting problems are managed to prevent any recurrence throughout the registry.

We believe the security measures detailed in this application are commensurate with the nature of the TLD string being applied for. In addition to the system⁄ infrastructure security policies and measures described in our response to this Q30, we also provide additional safety and security measures for this string.

These additional measures, which are not required by the applicant guidebook are:

1.Periodic audit of Whois data for accuracy;
2.Remediation of inaccurate Whois data, including takedown, if warranted;
3.A new Domain Protected Marks List (DPML) product for trademark protection;
4.A new Claims Plus product for trademark protection;
5.Terms of use that prohibit illegal or abusive activity;
6.Limitations on domain proxy and privacy service;
7.Published policies and procedures that define abusive activity; and
8.Proper resourcing for all of the functions above.