Application number: 1-2029-6966 for DotBook, LLC

DotBook, LLC

201 754 4345

734 424 2915

Ms. Annie Callanan

Manager

201 754 4345

734 424 2915

anniecallanan.book@gmail.com

Mr. Andrew Weissberg

Manager

201 906 2967

andyweissberg.book@gmail.com

Limited Liability Company

Delaware, United States of America

Not Available

Andrew Weissberg
Manager
Annie Callanan
Manager
Neil Posner
Manager

Annie Callanan
Chief Executive Officer

Andrew Weissberg
Manager
Annie Callanan
Manager
Jason Du
Member
Neil Posner
Manager

book

Not Available

Dotbook, LLC foresees no known rendering issues in connection with the proposed .book TLD string which it is seeking to apply for as a gTLD. This answer is based upon consultation with DotBook’s backend provider, Neustar, which has successfully launched a number of new gTLDs over the last decade. In reaching this determination, the following data points were analyzed:
• ICANN’s Security Stability Advisory Committee (SSAC) entitled Alternative TLD Name Systems and Roots: Conflict, Control and Consequences (SAC009);
• IAB - RFC3696 “Application Techniques for Checking and Transformation of Names”
• Known software issues which Neustar has encountered during the last decade launching new gTLDs;
• Character type and length;
• ICANN supplemental notes to Question 16; and
• ICANN’s presentation during its Costa Rica regional meeting on TLD Universal Acceptance;

Our mission is to establish .book as the most preferred top level domain for book consumers and the global book industry stakeholders that serve them. Our objectives are:
• To expressly democratize, simplify and cost-efficiently expand the discoverability of book titles and information about books. 
• To enable authors, book publishers and other industry service providers to directly and intuitively be found by their prospective customers.
• To facilitate a contemporary path for continuous promotion and an extended digital shelf life for books.
• To empower stakeholders to leverage the low cost and massive reach of the internet as an alternative global platform for increased discovery and competition in the distribution of books.
• To promote a modern and universal semantic definition of ʹbookʹ that reinforces efforts by book industry stakeholders to market increasingly unique book products and services.
• To increase international trade by preserving the profitable growth of an innovative, yet defined, book publishing market within the larger information footprint and in accordance with existing contractual agreements.
• To help drive the decentralized, stakeholder-driven production of natural language words and phrases in .book domain strings that will help consumers around the world efficiently discover and purchase books.

People have been using books to organize the worldʹs information for centuries but only a small percentage of our global population has been afforded the chance to access these materials or even find out more about them. This is because book publishing and distribution models have been trapped in outdated supply chain practices and imbalanced economic models that have impeded a transparent book market and disadvantaged each of the industryʹs key stakeholders. But the internet, as a global information platform, has the power to improve economic sustainability for all book publishing stakeholders while providing maximum choice for consumers.

Universal discoverability and accessibility are the $29 billion book industryʹs greatest economic challenges. Independent bookstores, chain book retailers and even big-box stores cannot allocate sufficient physical space for print inventory to make true universal discovery and continuous availability of books economically feasible. A 2007 estimate of the total size of the frontlist, or current titles in print and marketed for sale, was approximately 1.7 million; yet in 2010, Google estimated there were about 130 million unique books in the world. By some estimates, up to 52 percent of frontlist titles are not even sold in bookstores and consumer are challenged to find them. Numerous books are merchandised sporadically via mail order and online catalogs, through book clubs, direct sales channels and in other nontraditional retail outlets. Some estimates suggest another 18-20 million books are scattered across a plethora of websites and discoverable only via serendipity. Moreover, retail stores that do carry books are famous for returning them, often at the publisherʹs expense. Typically 25-36 percent of all books printed and supplied to retailers for sale are physically returned to the publisher for a refund. The economics of a brick and mortar business model will always necessitate a limited catalog of mostly current and blockbuster titles. With a very low investment however, almost anyone who can read and write can access information about a book on the internet through a .book title domain or distribute such information directly to millions of people around the world, and at a price point they set for themselves. 

Books are still the single best documented recording of the hearts and minds of the human race. We may live in an electronic age but the human output captured in books is worth preserving and making accessible to every interested citizen of the world who can access the internet. The internet has become the worldʹs ultimate global distribution platform. While the scarcity of shelf space once prevented the true lifetime value of a book from being realized, the adoption of .book title domains will allow any book to become instantly and abundantly available for an extended period of time, or even in perpetuity if the economics support it. This new system of .book TLDs will accelerate the ability of publishers and authors to develop more targeted domain schemas for faster and more cost-effective worldwide distribution for those not restricted by legacy territorial agreements.

Despite the fact that physical pages of books are slowly disappearing, the universal definition of the word ʹbookʹ is hardly foreign to global book consumers. The number of world nations who print the International Book Standard Number on the back of every printed book currently stands at 160 countries, according to the International ISBN Agency. As such, most consumers will not require training or rigorous bookmarking to search for books as the term ‘book’ is already a universally comprehended and highly regarded organizing label for information. Some industry pundits worry that the notion of a book is unraveling and quickly becoming a relic of the ancient past. Indeed the definition of a book as ʺthe matter printed between two coversʺ is fast becoming outdated. We are in the throes of a mighty transition from a print to an online publishing model. E-book sales in 2011 in the U.S. accounted for 21% of book sales, up from just 9 percent in the prior year. It has also been widely reported that Amazon sells more e-books than print books, a mere four years after launching the Kindle. 

In February, market analyst Nielsen reported that e-book production in the UK outpaced hardcover production for the first time in 2011. Market researcher Gfk also found that e-book sales increased 77% in Germany over a one-year period, totaling EUR 38 million in 2011. According to a recent Harris Interactive poll, nearly three out of ten adults in the U.S. use an electronic device or tablet to read electronic books, up from 15 percent in July 2011. And eMarketer estimates that by 2014, the number of tablet users will rise to nearly 90 million, or 27.7 percent of the U.S. population. As Angela Bole, Deputy Executive Director at the BISG summarizes, the “e-book market is developing very quickly, with consumer attitudes and behavior changing over the course of months, rather than years.” Ironically, readers are embracing digital books in every flavor but still lack the ability to easily discover the full range of book titles that map to their interests. In 1925 there were 397 book publishers. Today there are over 80,000, with up to 10,000 new publishers entering the field every year. The adoption of new .book domains will lower the cost barrier for authors to publish their own works and reach their intended audiences. The New York Times reported in 2002 that “81 percent of people feel that they have a book in them…and should write it.” In the U.S. alone that statistic represents over 200 million people who might be persuaded to author a book in their lifetime. The definition of what constitutes a book and how it can be found must be allowed to evolve. An independent .book registry that is not specifically affiliated with one of the primary stakeholders is the best recipe for engendering consumer and stakeholder trust. Our goal as an impartial entity is to preserve the future of books and book publishing by uniting all industry participants around consumer-centric use cases without distorting some and preventing the development of others. Industry adoption of the .book domain will advantage all economic stakeholders by lowering the overall cost of matching each book with its intended reader. As Kevin Kelly, one of our more thoughtful thinkers of the modern digital age states: ʺA book is complete in the sense that it contains its own beginning, middle, and end.ʺ Now is the time for this next chapter

Since its inception, the webʹs dramatic growth has been demanding new solutions to problems of information organization and discovery. Information growth and the need to categorize and label it all has fueled growth in the proliferation of monographs, blogs, research sites, dissertations, mobile apps, audio books and other manifestations of once traditional book material. At its core, the internet is about democratizing the production of, and access to, this information; but book discovery has yet to be sufficiently advanced by this axiom. 

In 2006, the amount of digital information created was 161 Exabytes – about 3 million times the information in all books ever written. The production of new information is still growing at an annual rate of 66% per year, and is accelerating. The internet has the potential to link together a growing percentage of the worldʹs book publishing output in a single networked corpus, on the only global platform capable of expanding at the worldʹs pace of production. .book domains will accelerate the creation of a vibrant and competitive market by placing product innovation and transparency in the hands of any registrant who can put up a secure website and any Internet user with the ability to access one.

The book is still the worldʹs oldest communication medium. And just as the invention of the printing press by Johannes Gutenberg in 1440 marks the entry of the book into the industrial age, the information age is ushering in a new transition from a print to a digital publishing model. But global consumer interests are not yet fully served as the industry undergoes this transformation. Most citizens in many of the 160 countries that have adopted the ISBN have never even seen or read an e-book. Psychological research affirms the positive motivational consequences of having personal choice. But a persistently inefficient supply chain model has only served to limit consumer choice in recent years as more physical bookstores disappear and distribution consolidates into a small handful of players. 

Books have a great deal of catching up to do in leveraging the power of the internet. Formats, prices, branding and business models are still not freely induced by consumer choice and increased competition but rather by the business models of powerful leaders in the space. By way of example, consumers are now being told their days of fondly collecting books are over. ʺElectronic book and music distributors are stripping away the entire idea of ownershipʺ in favor of the rental model, according to author and law professor Jason Mazzone. Exacerbating this dynamic is the fact that consumer electronics gadgets have a short lifespan due to planned obsolescence. E-book readers, mobile phones and tablet devices can only be expected to last a few years before the battery or hardware fail. 

Moreover, the future of reading is being held hostage in a format ʹstandards warʹ over versions of proprietary technologies with little regard for a consumerʹs need to collect and preserve their purchases as formats and standards evolve. Today the consumer can have little confidence that a small elite group of leading e-reader distribution providers, in competition with one another, will work together to make cross-platform accessibility feasible in the near term. 

The issue of who controls book content distribution is likely to only become more controversial as the cloud makes it possible to store, sync and share content from any device any time. The television and movie industries are attempting to shift their business models from ownership to rental. Consumers want access and the ability to share. But many want to do so without giving up control of their personalized images, videos and documents. 

According to Kevin Kelly, books will not be owned but rather accessed, ʺstreamed in paid subscription services; youʹll just ʹborrowʹ what you want.ʺ But many consumers are no more concerned about these objects taking up space on their hard drives than they were about books, movies and photos taking up space on their shelves. The digitizing of information has opened up a great number of possibilities but book consumers must also be concerned that minimal competition and lack of consumer choice will result in a day when they no longer have access to knowledge, but only access to access.

New .book gTLDs are being introduced to aid publishers in marketing titles directly to consumers, and to enable consumers to intuitively self-engage in the discovery of books that most appeal to their unique interests. Consumers would then immediately fulfill that purchase from the same browser if the publisher or self-published author chooses to enable that capability. New .book gTLDs will permit writers and authors to be more assertive and experimental in fostering direct relationships with readers and buyers by marketing titles to them in a language syntax these customers can comprehend, recollect and return to with ease. The act of purchasing books on .book domains affords the consumer choice and advantage, and publishers the potential for a more efficient distribution model where they preserve control over their content, and without the need to become experts in any technology more complicated than what is used to power their own e-commerce websites.

Consumers are increasingly preconditioned to the notion that information is finding its permanent home on the internet. As such, many buyers engaging in these online models in other retail segments are realizing numerous advantages such as price transparency, increased choice, discounting, reviews, friend recommendations, home delivery and the holy grail of e-commerce: infinite categorization. But micro-market segmentation has not been an affordable alternative for many book publishers. Many are hindered by the mass market economics of print publishing where demand is often required to be projected in advance. As a result, the user experience for most book buyers typing in basic terms into a search engine has not yet been optimized in a manner that transparently surfaces every relevant book available.

The existence of .book domains names will enable innovative solutions for enhanced discoverability and new aggregation strategies around micro-markets of potentially thousands of small niche subject categories, definable in natural language syntax. Consumers are already demonstrating a propensity for self-direction in seeking information on the web. Consumers conditioned through the ease of using natural language terms will be empowered to more successfully discover books that harmonize with their spontaneous interests. Consumers cannot easily find these segments on their own today by typing in natural language search terms. Publishers and authors are not encouraged to select narrow niches when profitability barriers are so high. Niche markets address special interests that have heretofore been underserved due to the high cost of finding their intended audience. 

Publishers adopting natural-language focused .book domains will be able to experiment with mash-ups, combined genres and specialty interest subjects, which would likely be unprofitable in the traditional book publishing model. Writers working for them will not be penalized for being less formulaic and for writing more freely about topics they’re especially knowledgeable about. And self-published authors taking these paths will be able to build their own brands from a single .book domain such as FifthGradeMath.book, PulpNoirComics.book, ParanormalThriller.book, ArabianHorses.book, DestinationWeddings.book, DiabeticCooking.book or AbrahamLincolnVampireHunter.book. But they will also be able to conveniently discover publicists (SciFiPublicist.book), marketing resources (OnlineMarketingSpecialist.book), freelance editors with a particular specialty (FreelanceBiographyEditor.book), and new and unique distribution partners (Cook.book) or (CoffeeTableReleases.book) if they so choose.

.book gTLDs will also bestow distinct branding benefits to publishers and other stakeholders who make use of them. From the perspective of consumer discoverability, the power of Romance.book or audio.book over romance.com or audio.com is clear. For customer engagement, .book domains will allow increased promotional benefits; publishing brands will now have the possibility of securing website addresses like TeachYourself.book, SingaporeMath.book, BaseballBiographies.book, CivilRightsInAmerica.book, AncientEmpires.book, SelfEmpowerment.book, AfricanLiterature.book, CollegeChemistry.book, ModernPoliticalTheory.book or MilitaryHistory.book, which consumers can easily locate. The .book brand will open up new possibilities for decentralized customer and reader engagement, expanded consumer choice and increased competition for lower cost online distribution outlets. 

Emphasis on format sequencing and imprint branding in release strategies will also evolve to better reflect the needs of consumers. Terms like Hardcover, Softcover and Mass Market Paperback will give way to more descriptive and subject-oriented terms that consumers can map to their unique interests. In the childrenʹs category, for example, most consumers shopping for Amelia Bedelia books will be more apt to search AmeliaBedelia.book than www.harpercollinschildrens.com⁄kids⁄gamesandcontests⁄...⁄amelia⁄ or even by imprint at harpercollins.com⁄imprints⁄index.aspx?imprintid=517996, for the Greenwillow Books imprint that publishes the beloved character books. Likewise, a popular title by Lisa Greenwald will be easier to find for a consumer under MyLifeInPinkAndGreen.book than under the obscure and unknown imprint, amuletbooks.com or even abramsbooks.com, the imprintʹs publisher.

Impulse book buying today is often cumbersome and non-intuitive. Nearly 4 in 10 consumers admit to being impulse buyers. And yet, a consumer attempting to find The Hunger Games book on their mobile device after hearing about the movie reviews would be challenged. The top two URL destinations would have required either familiarity with both publisher and author, or solid search engine optimization skills on the part of both entities to surface either of these URLs on a leading search engine: www.scholastic.com⁄thehungergames⁄ and www.suzannecollinsbooks.com⁄the_hunger_games_69765.htm. But by enabling a .book domain, the simple act of typing in TheHungerGames.book on a mobile device could result in being sent directly to the publisherʹs landing page with reviews, author information and links to purchasing options. In another example, even with prior knowledge that McGraw Hill is one of the largest textbook and professional publishers in the world, a consumer would need to visit the unintuitive http:⁄⁄www.mhprofessional.com⁄ to find portions of their catalog, or otherwise click through a series of links on the home page to find the appropriate domain.

As an effective means of enabling differentiation, branding and consumer choice, .book domains will appeal to virtually all book industry stakeholders, including publishers, authors, book sellers, book designers, publicists and literary agents, editors, book illustrators and photographers, reading groups, libraries, book social networking sites, book rental companies, online aggregators and distributors, and even bloggers and researchers eager to compile their fragmented bits of text and join them together into a self-contained authoritative wrapper. 

.book domains will advantage all publisher markets, from Trade and Religion publishers to K-12 and college textbooks, to professional and scholarly (primary research from academia, corporate and government) works such as reference books, manuals, monographs and materials from University Presses. Many publishers in the Science, Technical, Medical (STM), College, K-12 and Professional markets (law, medicine, business, science, humanities, social sciences and technology) are already seeing the largest percentage of sales coming from their own websites, according to a recent survey by Aptara. .book domains will facilitate intuitive discovery further through the use of natural language subject terms that link right to specific books on publisher websites without the expense of an agent or intermediary.

Despite recent advances, the needs of consumers are simple, and yet highly underserved in this market. Is it reasonable that in the race for digitization, consumers would be denied the option of sharing books in households with multiple and incompatible devices? Should consumers be forced to repurchase titles repeatedly as devices and formats evolve? Is it acceptable for consumers to enjoy the freedom to read books on one device and purchase through another, or to easily find and locate books that are of interest on the internet, without knowing specific URLs or the multitude of highly unfamiliar publisher and imprint names? Today the lack of consumer choice impedes book sales.

Author choice and remuneration have also been hindered in the traditional publishing model due to the fact that only mainstream publishers had the ability to place a book in hundreds of bookstores around the globe. But there has perhaps never been a better time to become self-published--virtually anyone with a credit card can do it when the distribution platform is the internet. Self-publishing is becoming a big business for unknowns and famed authors alike. A wealth of resources are starting to surface on the web, and well respected authors like Stephen King and J.K. Rowling have already experimented with their own marketing and pricing strategies. In 2011, John Locke became the first self-published author to sell over a million e-books on Amazon. .book domains will further lower the cost of selling direct to consumers and facilitating a meaningful direct branding relationship with fans. 

Finally, publishers who are strong in selection, market segmentation and marketing will also thrive in this model. Marketing and distribution costs could drop significantly as the market shifts to electronic content on .book domains. Printing, shipping and storage costs will only apply to a shrinking number of print titles. Consumers proactively using descriptive words to find book information without being trained will allow publishers to drive marketing costs way down through the adoption of title .book domains. And distribution costs will also decline for publishers selling direct through their .book websites rather than through high end sales reps, non-transparent catalogs and third-party e-tailers. About 20 percent of online sales today are of titles not physically available in traditional brick-and-mortar stores. Projections are this figure will soon reach a third of all book sales. Competition for those sales today is minimal. .book domains can keep publishers competitive in terms of capturing more of that business, and provide new distribution alternatives for consumers as well.

Consumers have very few choices in terms of where they can purchase books today. In aggregate, online retail is gaining market share that other channels are losing, but due to a few prominent outlets the growth in this channel is only further limiting choices for consumers. Consumers are clearly switching their purchasing preferences as the e-book format takes off, but few new entrants can successfully compete. The .book domain will help level the playing field for publishers, authors and even new niche aggregators to create innovative ways to manage book information and profitably expose it to the world. 
The .book domain has positive implications for scholarly and professional publishing as well. In the professional world, managing information is a crucial component of being successful. For scholars, publishing is the basis for almost all professional advancement. Serious scholars have traditionally frowned on electronic dissemination of monographs but recent trends in the culture of publishing are bringing about a reexamination of these outdated attitudes. Most scholars are already leveraging their institutions and a network of colleagues in their discipline to market their books on the web. Hyper-linking directly back from those connections to a .book domain can prove more cost-effective than engaging marketing departments to issue promotional catalogs that cannot be discovered by anyone other than a librarian or bookseller. 

Adoption of new .book domains will enable the potential for new innovative aggregation domains to flourish by acting as niche clearinghouses where students, researchers and professionals can see book information on a given topic from as many sources as possible. The information aggregation value proposition is one that is very strong, familiar and appealing to professional and scholarly end users. Aggregators can enhance the supply chain by facilitating the diversity of discovery from large numbers of publishers at one time rather than promoting the continued compilation of conglomerate-centric collections. Many aggregators will also enhance the value of publisher content by making the necessary investments in technology, indexing and usability to maximize discovery in a digital environment.

Libraries may also be able to play a role in facilitating new niche aggregation domains as they search to reinvent their value proposition in an increasingly digital world. With the mandate to quickly address the needs of students, faculty and researchers, academic and corporate librarians can leverage their subject matter expertise and support greater transparency in scholarship and research by playing a meaningful role in facilitating the aggregation of niche collections under semantic .book domains their patrons can comprehend. Some of the most passionate and knowledgeable book consumers are librarians, many of whom still spend a great deal of time assembling subject-specific collections of books sourced from multiple publishers, and organizing them on shelves. As credible conduits of knowledge exchange, librarians can have a centralizing impact on the manner in which books are found in a digital world. 

Books will continue to represent the voices that fill our planet but their contained knowledge must be discovered. Soon we will be able to not only read and listen to books but also watch and interact with them. But as books introduce new and dynamic attributes to delight us, they will require an unambiguous word that enduringly defines them. The .book domain will serve as a virtual binding, a unifying naming convention providing an invisible verification to all who see it that we are still engaged and trading in the same core product we have placed our trust in over centuries. DotBook LLC is committed to working in partnership with all book industry stakeholders to maximize their commercial interests, within the framework of full trademark and intellectual property rights protection, and with the larger goal of seeing the full potential of consumer choice for book buyers realized.

The DotBook registryʹs mission is to establish .book as the most preferred top level domain for global book industry stakeholders and the book consumers that purchase from them. To ensure success for all participants, it is vital that publisher and author registrants be safeguarded from abusive registrations that might be used to promote unauthorized access to copyrighted text and image based works legally assigned to rightsholders. DotBook will provide both a Trademark Claims and a Sunrise Service for the safeguarding of trademarks and non-trademarked ʺbook titleʺ domains as part of its registry operations.

The goal of DotBookʹs sunrise period is to ensure that all book stakeholders are able to successfully leverage the brand recognition and value established from their works in the context of new ʺtitleʺ .book domain assignments, if they choose to do so. We recognize that trademarks are an important business asset for book industry stakeholders and as such, we will be implementing a pre-launch Rights Protection Mechanism (RPM) that will involve a phased sunrise period to fully support the registration needs of book industry stakeholders and their trademarked brands. But non-trademarked titles will also receive special outreach.

This approach to protecting both trademarked and non-trademarked names is necessitated by the fact that many of the most recognizable ʺbrandsʺ in book publishing are the actual titles of books, which for the most part are not subject to trademark protection. Moreover, .book title domains mean that publishers donʹt have to compete with movie producers for URLs in instances where books are converted into films. Numerous titles that represent common words and phrases that are already taken in the existing TLDs such as .com can be accommodated with greater clarity in a .book domain. 

Publisher and authors have a tremendous amount of goodwill attached to certain titles that cannot be formally assigned trademark protection. But consumer trust and full stakeholder adoption will be enhanced if consumers can rely on the fact that when they visit a .book domain to purchase a particular title, that seller has the legal distribution rights. We trust such extra community-oriented measures will greatly reduce the risk of title domains being registered by applicants that do not have the rights to distribute or sell the book, including any portion of its content.

The Sunrise period will be in effect for up to two years, with different phases running both concurrently and in succession. All applicants arriving within the timeframe of a given phase will be considered to have arrived at the same time. The longer timeframe is being implemented in support of both authors and publishers. Ultimately, our objective is to allocate desirable terms such as title names, semantic subject terms and trademarks fairly and appropriately between eligible claimants from across jurisdictions and to avoid disputes wherever possible. 


Minimizing Consumer Vulnerabilities

For the .book TLD, DotBook will institute numerous operating rules and procedures in order to eliminate or minimize consumer vulnerabilities or other negative consequences which may be imposed upon consumers, registrants, IP rightsholders and other .book TLD registry stakeholders. 

DotBook intends to utilize our back-end registry service provider’s Threat Mitigation Services as part of the .book registry’s standard operating procedures. These will ensure that DotBook can proactively identify, detect, catalog, and disrupt any malicious activity within the .book TLD which threaten end-user safety or security. Additionally, these measures will importantly combat the potential brand damaging effects of phishing, malware distribution, exploit hosting, and botnets that exploit registrants and rightsholders. 

If warranted, DotBook may take down any .book domains verified to be harboring and⁄or supporting online threats to the .book registry and the broader internet community of users. This action shuts down all activities associated with the domain name, including all websites. Our philosophy in administering this procedure is that removing threats to the consumer outweighs any potential damage to the registrar⁄registrant relationship. DotBook will commit to keeping its registrars updated of any malicious activity within the .book TLD through weekly or monthly reporting. We will also leverage our back-end provider’s existing relationships with international law enforcement agencies as necessary and in support of these procedures.


Procedures for Resolving Multiple Requests for Top Level Names

Procedures for resolving requests and limiting unqualified registrations of titles will be implemented in the Sunrise period, and are intended to accomplish the following objectives:

• To ensure trademark protection for all trademarks across all book industry stakeholders.
• To assign ʺbook titleʺ domains to the current registered electronic rights holder if the rights holder submits an application in the sunrise period and can provide verification of their IP rights.
• To assign book title domains to works without a verifiable electronic rights holder on a first-come, first-serve basis to either the publisher or the author, or through an auction process if applications are submitted from both parties in the same sunrise phase of the sunrise period.
• To assign title domains for titles common to more than one legitimate party (author or publisher) in an auction process if the applications are submitted in the same sunrise phase, or on a first-come, first-serve basis if only one legitimate party submits an application in the sunrise period. 
• To assign title and author domains for public domain works in an auction process if more than one publisher who has previously published the work submits an application in the same sunrise phase, or on a first-come, first-serve basis if only one publisher submits an application during the sunrise period.
• To ensure protection of first level geographic names.
• To avoid legal disputes related to multiple claims on single titles and unqualified registrations.

Other reserved names for which it is envisioned that multiple applications may be requested shall be sold in conjunction with third-party domain name auction services, brokers or other commercial services providers as authorized by DotBook at its own discretion. All policies and procedures as described herein with respect to reserved names have been developed in accordance with the ICANN New gTLD Registry Agreement and specifically Provision 2.6 as it is currently published and available.


Registry Pricing Policies 

Wholesale Price Stability
With respect to cost benefits for registrants, DotBook intends to maintain its introductory wholesale pricing model for registrars for the first three (3) years of registry operations. By providing a predictable wholesale price, we believe this will simplify efforts among registrars to facilitate and achieve end-customer (registrant) adoption at levels which have been forecasted for the .book registry. 

Price stability will be particularly meaningful to publisher, self-publisher and author rightsholders that we have identified for .book. As such, even as a matter of making “defensive registration decisions” we felt it would be important to provide some level of predictability for an initial three-year period, which would avoid concerns for pricing as a barrier to .book’s early-stage market adoption. DotBook anticipates coordinating pricing incentives for registrations of titles and bulk registrations from those with larger numbers of names to register. Bulk registrations above a reasonable number of .book domain names from one registrant will be eligible for such discounting incentives through the coordination of our registrar network. Registrants will be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years.

Contractual Commitments

Pursuant to provision 2.10 as contained in the current ICANN New gTLD Registry Agreement, DotBook will make several contractual commitments to registrants regarding the magnitude of price escalation. We will provide ICANN and each ICANN accredited registrar that has executed the registry-registrar agreement for the .book TLD advance written notice of any price increase of no less than thirty (30) calendar days. With respect to renewal of domain name registrations, DotBook shall provide ICANN and each ICANN accredited registrar that has executed the registry-registrar agreement for the .book TLD advance written notice of any price increase, including as a result of the elimination of any refunds, rebates, discounts, product tying, Qualified Marketing Programs or other programs (which had the effect of reducing the price charged to registrars) of no less than one hundred eighty (180) calendar days.

Notwithstanding the foregoing, with respect to renewal of domain name registrations, DotBook will provide at least thirty (30) calendar days notice of any price increase if the resulting price is less than or equal to (A) for the period beginning on the Effective Date and ending twelve (12) months following the Effective Date, the initial price charged for registrations in the .book TLD, or (B) for subsequent periods, a price for which DotBook provided a notice within the twelve (12) month period preceding the effective date of the proposed price increase.

DotBook shall offer registrars the option to obtain domain name registration renewals at the current price (i.e. the price in place prior to any noticed increase) for periods of one to ten years at the discretion of the registrar, but no greater than ten years. In addition, DotBook will maintain uniform pricing for renewals of domain name registrations, for which the price for each domain registration renewal must be identical to the price of all other domain name registration renewals in place at the time of such renewal. Such price must take into account universal application of any refunds, rebates, discounts, product tying or other programs in place at the time of renewal. 

DotBook will make available to registrars Qualified Marketing Programs in which discounted renewal pricing will be offered for up to one hundred eighty (180) calendar days. All ICANN accredited registrars for the .book TLD will be provided the same opportunity to qualify for such discounted Renewal Pricing. These programs will not to exclude any particular class or classes of registrations or increase the renewal price of any particular classes of registrations.

For complete transparency, DotBook will provide public query-based DNS lookup service for the TLD at its sole expense.

No

Not Available

No

In preparation for answering this question, DotBook, LLC (“DotBook”) reviewed the following relevant background material regarding the protection of geographic names in the DNS, including: 

-ICANN Board Resolution 01-92 regarding the methodology developed for the reservation and release of country names in the .INFO top-level domain (see http:⁄⁄www.icann.org⁄en⁄minutes⁄minutes-10sep01.htm); 

-ICANN’s Proposed Action Plan on .INFO Country Names (see http:⁄⁄www.icann.org⁄en⁄meetings⁄montevideo⁄action-plan-country-names-09oct01.htm); 

-“Report of the Second WIPO Internet Domain Name Process: The Recognition and Rights and the Use of Names in the Internet Domain Name System,ʺ Section 6, Geographical Identifiers (see http:⁄⁄www.wipo.int⁄amc⁄en⁄processes⁄process2⁄report⁄html⁄report.html); 

-ICANN’s Governmental Advisory Committee (GAC) Principles Regarding New gTLDs, (see https:⁄⁄gacweb.icann.org⁄download⁄attachments⁄1540128⁄gTLD_principles_0.pdfversion=1&modificationDate=1312358178000); and 

-ICANN’s Generic Names Supporting Organization (GNSO) Reserved Names Working Group – Final Report (see http:⁄⁄gnso.icann.org⁄issues⁄new-gtlds⁄final-report-rn-wg-23may07.htm).
 Initial Reservation of Country and Territory Names

DotBook is committed to initially reserving the country and territory names contained in the internationally recognized lists described in Article 5 of Specification 5 attached to the New gTLD Applicant Guidebook at the second level and at all other levels within the .book gTLD at which domain name registrations will be provided. Specifically, DotBook will reserve:

-The short form (in English) of all country and territory names contained on the ISO 3166- 1 list, as updated from time to time, including the European Union, which is exceptionally reserved on the ISO 3166-1 list, and its scope extended in August 1999 to any application needing to represent the name European Union (see http:⁄⁄www.iso.org⁄iso⁄support⁄country_codes⁄iso_3166_code_lists⁄iso-3166-1_decoding_table.htm#EU);
-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
-The list of United Nations member states in six official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names.

Potential Allocation and Future Release of Names

During its Sunrise period, DotBook will implement an outreach campaign targeting National Libraries in each country or territory to inform them about .book and to facilitate the responsible release of names as previously described. The protection of first level geographic names for individual countries will occur through the assignment of those names to each representative countryʹs National Library, or in the absence of one, their authoritative bibliographic representative. In most countries, fulfilling a nationʹs goal of bibliographic control of all locally published books and documents is the role of the national library. A national library is a library specifically established by the government of a country, often with legal deposit laws, to serve as the preeminent repository of information under a mandate to preserve that countryʹs national heritage. 

DotBook will work with the International Federation of Library Associations (IFLA), The European Library and other library associations to invite each national library to secure first level geographic names for their respective countries - names such as Italy.book and Korea.book. DotBook will also work collaboratively with the International Standard Book Number (ISBN) Agency on behalf of their nearly 160 issuing ISBN agencies to help identify these national libraries or authoritative bibliographic representatives. Today many national ISBN agencies are managed by the countryʹs national library, and serve as the official book registration authorities while maintaining the full listing of each countryʹs Books In Print catalog. Securing these geographic names will afford each national library the opportunity to make discoverable their full catalog of books. Potential registrant categories: National libraries and their respective ISBN agencies.

While DotBook foresees no immediate need for plans to make use of these initially reserved country names at the second level within the .book namespace, DotBook recognizes that there has been several successful and non-misleading use of country names by new gTLD operators as evidenced below:

〈AUSTRALIA.COOP〉 – Is operated by Co-operatives Australia the national body for State Co-operative Federations and provides a valuable resource about cooperatives within Australia.

〈UK.COOP〉 – Is operated by Co-operatives UK the national trade body that campaigns for co-operation and works to promote, develop and unite co-operative enterprises within the United Kingdom. 

〈NZ.COOP〉 – Is operated by the New Zealand Cooperatives Association which brings together the country’s cooperative mutual business in a not-for-profit incorporated society.

〈USA.JOBS〉 - Is operated by DirectEmployers Association (DE). While Employ Media the registry operator of the .JOBS gTLD is currently in a dispute with ICANN regarding the allocation of this and other domain names. 
Direct Employers has a series of partnerships and programs with the United States Department of Labor, the National Association of State Workforce Agencies and Facebook to help unemployed workers find jobs. 

〈MALDIVIAN.AERO〉 - Is the dominant domestic air carrier in Maldives, and provides a range of commercial and leisure air transport services.

The more likely request by DotBook will come in connection with the un-reservation and allocation of two-letter .book domain names, e.g. 95.book, 12.book, etc. If DotBook should decide in the future to attempt and allocate these domain names, it would submit the proper Registry Service Evaluation Processes (RSEP) with ICANN. In evaluating similar RSEP requests that have been submitted to ICANN by other gTLD registry operators, DotBook believes that its request would be favorably granted.

Creation and Updating the Policies
DotBook is committed to continually reviewing and updating when necessary its policies in this area. Consistent with this commitment, DotBook intends to remain an active participant in any ongoing ICANN policy discussion regarding the protection of geographic names within the DNS.

23.1 Introduction 

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

23.2 Standard Technical and Business Components

Neustar will provide the highest level of service while delivering a secure, stable and comprehensive registry platform. DotBook will use Neustar’s Registry Services platform to deploy the .book registry, by providing the following Registry Services (none of these services are offered in a manner that is unique to .book: 

• Registry-Registrar Shared Registration Service (SRS)
• Extensible Provisioning Protocol (EPP)
• Domain Name System (DNS)
• WHOIS
• DNSSEC
• Data Escrow
• Dissemination of Zone Files using Dynamic Updates
• Access to Bulk Zone Files
• Dynamic WHOIS Updates
• IPv6 Support
• Rights Protection Mechanisms
• Internationalized Domain Names (IDN). [Optional – should be deleted if not being offered].

The following is a description of each of the services. 

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

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

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

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

Standard WHOIS (Port 43)
Standard WHOIS (Web)
Searchable WHOIS (Web)

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

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

• Protect against data loss
• Follow industry best practices
• Ensure easy, accurate, and timely retrieval and restore capability in the event of a hardware failure
• Minimizes the impact of software or business failure.

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

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

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

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

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

Required Rights Protection Mechanisms
DotBook, will provide all ICANN required Rights Mechanisms, including: 
• Trademark Claims Service
• Trademark Post-Delegation Dispute Resolution Procedure (PDDRP)
• Registration Restriction Dispute Resolution Procedure (RRDRP)
• UDRP
• URS
• Sunrise service.

More information is presented in the response to Question 29.

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

23.3 Unique Services 
DotBook will not be offering services that are unique to .book.

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

24.1 Introduction

DotBook, LLC (“DotBook”) has partnered with Neustar, Inc, an experienced TLD registry operator, for the operation of the .book Registry. The applicant is confident that the plan in place for the operation of a robust and reliable Shared Registration System (SRS) as currently provided by Neustar will satisfy the criterion established by ICANN. Neustar built its SRS from the ground up as an EPP based platform and has been operating it reliably and at scale since 2001. The software currently provides registry services to five TLDs (.BIZ, .US, TEL, .CO and .TRAVEL) and is used to provide gateway services to the .CN and .TW registries. Neustar’s state of the art registry has a proven track record of being secure, stable, and robust. It manages more than 6 million domains, and has over 300 registrars connected today. 

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

24.2 The Plan for Operation of a Robust and Reliable SRS

High-level SRS System Description
The SRS to be used for .book will leverage a production-proven, standards-based, highly reliable and high-performance domain name registration and management system that fully meets or exceeds the requirements as identified in the new gTLD Application Guidebook. The SRS is the central component of any registry implementation and its quality, reliability and capabilities are essential to the overall stability of the TLD. Neustar has a documented history of deploying SRS implementations with proven and verifiable performance, reliability and availability. The SRS adheres to all industry standards and protocols. By leveraging an existing SRS platform, DotBook is mitigating the significant risks and costs associated with the development of a new system. Highlights of the SRS include:
• State-of-the-art, production proven multi-layer design
• Ability to rapidly and easily scale from low to high volume as a TLD grows
• Fully redundant architecture at two sites
• Support for IDN registrations in compliance with all standards 
• Use by over 300 Registrars
• EPP connectivity over IPv6
• Performance being measured using 100% of all production transactions (not sampling).
 
SRS Systems, Software, Hardware, and Interoperability 
The systems and software that the registry operates on are a critical element to providing a high quality of service. If the systems are of poor quality, if they are difficult to maintain and operate, or if the registry personnel are unfamiliar with them, the registry will be prone to outages. Neustar has a decade of experience operating registry infrastructure to extremely high service level requirements. The infrastructure is designed using best of breed systems and software. Much of the application software that performs registry-specific operations was developed by the current engineering team and a result the team is intimately familiar with its operations.

The architecture is highly scalable and provides the same high level of availability and performance as volumes increase. It combines load balancing technology with scalable server technology to provide a cost effective and efficient method for scaling.The Registry is able to limit the ability of any one registrar from adversely impacting other registrars by consuming too many resources due to excessive EPP transactions. The system uses network layer 2 level packet shaping to limit the number of simultaneous connections registrars can open to the protocol layer.

All interaction with the Registry is recorded in log files. Log files are generated at each layer of the system. These log files record at a minimum:
• The IP address of the client
• Timestamp
• Transaction Details
• Processing Time.

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

SRS Design
The SRS incorporates a multi-layer architecture that is designed to mitigate risks and easily scale as volumes increase. The three layers of the SRS are:
• Protocol Layer
• Business Policy Layer
• Database. 

Each of the layers is described below. 

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

The EPP servers authenticate against a series of security controls before granting service, as follows:
• The registrar’s host exchanges keys to initiates a TLS handshake session with the EPP server.
• The registrar’s host must provide credentials to determine proper access levels.
• The registrar’s IP address must be preregistered in the network firewalls and traffic-shapers.

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

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

The SRS today processes over 30 million EPP transactions daily. 

Database
The database is the third core components of the SRS. The primary function of the SRS database is to provide highly reliable, persistent storage for all registry information required for domain registration services. The database is highly secure, with access limited to transactions from authenticated registrars, trusted application-server processes, and highly restricted access by the registry database administrators. A full description of the database can be found in response to Question 33.
Figure 24-1 depicts the overall SRS architecture including network components.
  
Number of Servers
As depicted in the SRS architecture diagram above Neustar operates a high availability architecture where at each level of the stack there are no single points of failures. Each of the network level devices run with dual pairs as do the databases. For the .book registry, the SRS will operate with 8 protocol servers and 6 policy engine servers. These expand horizontally as volume increases due to additional TLDs, increased load, and through organic growth. In addition to the SRS servers described above, there are multiple backend servers for services such as DNS and WHOIS. These are discussed in detail within those respective response sections. 

Description of Interconnectivity with Other Registry Systems

The core SRS service interfaces with other external systems via Neustar’s external systems layer. The services that the SRS interfaces with include:
• WHOIS 
• DNS 
• Billing
• Data Warehouse (Reporting and Data Escrow). 

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

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

The following are the standard three external notifiers used the SRS: 

WHOIS External Notifier

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

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

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

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

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

Synchronization Scheme (e.g., hot standby, cold standby) 
Neustar operates two hot databases within the data center that is operating in primary mode. These two databases are kept in sync via synchronous replication. Additionally, there are two databases in the secondary data center. These databases are updated real time through asynchronous replication. This model allows for high performance while also ensuring protection of data. See response to Question 33 for greater detail. 
Compliance with Specification 6 Section 1.2

The SRS implementation for .book is fully compliant with Specification 6, including section 1.2. EPP Standards are described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. Extensible Provisioning Protocol or EPP is defined by a core set of RFCs that standardize the interface that make up the registry-registrar model. The SRS interface supports EPP 1.0 as defined in the following RFCs shown in Table 24-1. 
 
Additional information on the EPP implementation and compliance with RFCs can be found in the response to Question 25.

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

To properly measure the technical performance and progress of TLDs, Neustar collects data on key essential operating metrics. These measurements are key indicators of the performance and health of the registry. Neustar’s current .biz SLA commitments are among the most stringent in the industry today, and exceed the requirements for new TLDs. Table 24-2 compares the current SRS performance levels compared to the requirements for new TLDs, and clearly demonstrates the ability of the SRS to exceed those requirements.
 
Their ability to commit and meet such high performance standards is a direct result of their philosophy towards operational excellence. See response to Question 31 for a full description of their philosophy for building and managing for performance.

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

• Development⁄Engineering
• Database Administration
• Systems Administration
• Network Engineering.

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

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

Development⁄Engineering – 19 employees
Database Administration- 10 employees
Systems Administration – 24 employees
Network Engineering – 5 employees
The resources are more than adequate to support the SRS needs of all the TLDs operated by Neustar, including the .book registry. 

25.1 Introduction
DotBook’s back-end registry operator, Neustar, has over 10 years of experience operating EPP based registries. They deployed one of the first EPP registries in 2001 with the launch of .biz. In 2004, they were the first gTLD to implement EPP 1.0. Over the last ten years Neustar has implemented numerous extensions to meet various unique TLD requirements. Neustar will leverage its extensive experience to ensure DotBook is provided with an unparalleled EPP based registry. The following discussion explains the EPP interface which will be used for the .book registry. This interface exists within the protocol farm layer as described in Question 24 and is depicted in Figure 25-1.
 
25.2 EPP Interface
Registrars are provided with two different interfaces for interacting with the registry. Both are EPP based, and both contain all the functionality necessary to provision and manage domain names. The primary mechanism is an EPP interface to connect directly with the registry. This is the interface registrars will use for most of their interactions with the registry. However, an alternative web GUI (Registry Administration Tool) that can also be used to perform EPP transactions will be provided. The primary use of the Registry Administration Tool is for performing administrative or customer support tasks. The main features of the EPP implementation are: 

• Standards Compliance: The EPP XML interface is compliant to the EPP RFCs. As future EPP RFCs are published or existing RFCs are updated, Neustar makes changes to the implementation keeping in mind of any backward compatibility issues.
• Scalability: The system is deployed keeping in mind that it may be required to grow and shrink the footprint of the Registry system for a particular TLD. 
• Fault-tolerance: The EPP servers are deployed in two geographically separate data centers to provide for quick failover capability in case of a major outage in a particular data center. The EPP servers adhere to strict availability requirements defined in the SLAs.
• Configurability: The EPP extensions are built in a way that they can be easily configured to turn on or off for a particular TLD.
• Extensibility: The software is built ground up using object oriented design. This allows for easy extensibility of the software without risking the possibility of the change rippling through the whole application. 
• Auditable: The system stores detailed information about EPP transactions from provisioning to DNS and WHOIS publishing. In case of a dispute regarding a name registration, the Registry can provide comprehensive audit information on EPP transactions.
• Security: The system provides IP address based access control, client credential-based authorization test, digital certificate exchange, and connection limiting to the protocol layer. 

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

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

Neustar has a long history of providing exceptional service that exceeds all performance specifications. The SRS and EPP interface have been designed to exceed the EPP specifications defined in Specification 10 of the Registry Agreement and profiled in Table 25-2. Evidence of Neustar’s ability to perform at these levels can be found in the .biz monthly progress reports found on the ICANN website.
 
EPP Toolkits
Toolkits, under open source licensing, are freely provided to registrars for interfacing with the SRS. Both Java and C++ toolkits will be provided, along with the accompanying documentation. The Registrar Tool Kit (RTK) is a software development kit (SDK) that supports the development of a registrar software system for registering domain names in the registry using EPP. The SDK consists of software and documentation as described below.

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

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

25.3 Proprietary EPP Extensions
The .book registry will not include proprietary EPP extensions. Neustar has implemented various EPP extensions for both internal and external use in other TLD registries. These extensions use the standard EPP extension framework described in RFC 5730. Table 25-3 provides a list of extensions developed for other TLDs. Should the .book registry require an EPP extension at some point in the future, the extension will be implemented in compliance with all RFC specifications including RFC 3735.
 
The full EPP schema to be used in the .book registry is attached in the document titled “EPP Schema.”

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

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

Development⁄Engineering – 19 employees
Quality Assurance - 7 employees.
These resources are more than adequate to support any EPP modification needs of the .book registry.

26.1 Introduction

For the .book TLD, DotBook, LLC (“DotBook”) recognizes the importance of an accurate, reliable, and up-to-date WHOIS database to governments, law enforcement, intellectual property holders and the public as a whole and is firmly committed to complying with all of the applicable WHOIS specifications for data objects, bulk access, and lookups as defined in Specifications 4 and 10 to the Registry Agreement. DotBook’s back-end registry services provider, Neustar, has extensive experience providing ICANN and RFC-compliant WHOIS services for each of the TLDs that it operates both as a Registry Operator for gTLDs, ccTLDs and back-end registry services provider. As one of the first “thick” registry operators in the gTLD space, Neustar’s WHOIS service has been designed from the ground up to display as much information as required by the .book TLD and respond to a very stringent availability and performance requirement.

Some of the key features of .book TLD’s solution include: 

• Fully compliant with all relevant RFCs including 3912
• Production proven, highly flexible, and scalable with a track record of 100% availability over the past 10 years
• Exceeds current and proposed performance specifications 
• Supports dynamic updates with the capability of doing bulk updates 
• Geographically distributed sites to provide greater stability and performance
• In addition, .book’s thick-WHOIS solution also provides for additional search capabilities and mechanisms to mitigate potential forms of abuse as discussed below. (e.g., IDN, registrant data).

26.2 Software Components
The WHOIS architecture comprises the following components:

• An in-memory database local to each WHOIS node: To provide for the performance needs, the WHOIS data is served from an in-memory database indexed by searchable keys. 
• Redundant servers: To provide for redundancy, the WHOIS updates are propagated to a cluster of WHOIS servers that maintain an independent copy of the database. 
• Attack resistant: To ensure that the WHOIS system cannot be abused using malicious queries or DOS attacks, the WHOIS server is only allowed to query the local database and rate limits on queries based on IPs and IP ranges can be readily applied.
• Accuracy auditor: To ensure the accuracy of the information served by the WHOIS servers, a daily audit is done between the SRS information and the WHOIS responses for the domain names which are updated during the last 24-hour period. Any discrepancies are resolved proactively.
• Modular design: The WHOIS system allows for filtering and translation of data elements between the SRS and the WHOIS database to allow for customizations.
• Scalable architecture: The WHOIS system is scalable and has a very small footprint. Depending on the query volume, the deployment size can grow and shrink quickly.
• Flexible: It is flexible enough to accommodate thin, thick, or modified thick models and can accommodate any future ICANN policy, such as different information display levels based on user categorization.
• SRS master database: The SRS database is the main persistent store of the Registry information. The Update Agent computes what WHOIS updates need to be pushed out. A publish-subscribe mechanism then takes these incremental updates and pushes to all the WHOIS slaves that answer queries.

26.3 Compliance with RFC and Specifications 4 and 10
Neustar has been running thick-WHOIS Services for over 10+ years in full compliance with RFC 3912 and with Specifications 4 and 10 of the Registry Agreement.RFC 3912 is a simple text based protocol over TCP that describes the interaction between the server and client on port 43. Neustar built a home-grown solution for this service. It processes millions of WHOIS queries per day.
Table 26-1 describes Neustar’s compliance with Specifications 4 and 10.
 

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

26.4 High-level WHOIS System Description

26.4.1 WHOIS Service (port 43)
The WHOIS service is responsible for handling port 43 queries. Our WHOIS is optimized for speed using an in-memory database and master-slave architecture between the SRS and WHOIS slaves.
The WHOIS service also has built-in support for IDN. If the domain name being queried is an IDN, the returned results include the language of the domain name, the domain name’s UTF-8 encoded representation along with the Unicode code page.

26.4.2 Web Page for WHOIS queries
In addition to the WHOIS Service on port 43, Neustar provides a web based WHOIS application (www.whois..book). It is an intuitive and easy to use application for the general public to use. WHOIS web application provides all of the features available in the port 43 WHOIS. This includes full and partial search on:
• Domain names
• Nameservers
• Registrant, Technical and Administrative Contacts
• Registrars

It also provides features not available on the port 43 service. These include:

1. Redemption Grace Period calculation: Based on the registry’s policy, domains in pendingDelete can be restorable or scheduled for release depending on the date⁄time the domain went into pendingDelete. 

For these domains, the web based WHOIS displays “Restorable” or “Scheduled for Release” to clearly show this additional status to the user.

2. Extensive support for international domain names (IDN)
3. Ability to perform WHOIS lookups on the actual Unicode IDN
4. Display of the actual Unicode IDN in addition to the ACE-encoded name
5. A Unicode to Punycode and Punycode to Unicode translator
6. An extensive FAQ
7. A list of upcoming domain deletions

26.5 IT and Infrastructure Resources
As described above the WHOIS architecture uses a workflow that decouples the update process from the SRS. This ensures SRS performance is not adversely affected by the load requirements of dynamic updates. It is also decoupled from the WHOIS lookup agent to ensure the WHOIS service is always available and performing well for users. Each of Neustar’s geographically diverse WHOIS sites use:

• Firewalls, to protect this sensitive data 
• Dedicated servers for MQ Series, to ensure guaranteed delivery of WHOIS updates 
• Packetshaper for source IP address-based bandwidth limiting 
• Load balancers to distribute query load 
• Multiple WHOIS servers for maximizing the performance of WHOIS service.

The WHOIS service uses HP BL 460C servers, each with 2 X Quad Core CPU and a 64GB of RAM. The existing infrastructure has 6 servers, but is designed to be easily scaled with additional servers should it be needed.
Figure 26-1 depicts the different components of the WHOIS architecture.

 
26.6 Interconnectivity with Other Registry System
As described in Question 24 about the SRS and further in response to Question 31, “Technical Overview”, when an update is made by a registrar that impacts WHOIS data, a trigger is sent to the WHOIS system by the external notifier layer. The update agent processes these updates, transforms the data if necessary and then uses messaging oriented middleware to publish all updates to each WHOIS slave. The local update agent accepts the update and applies it to the local in-memory database. A separate auditor compares the data in WHOIS and the SRS daily and monthly to ensure accuracy of the published data.

26.7 Frequency of Synchronization between Servers
Updates from the SRS, through the external notifiers, to the constellation of independent WHOIS slaves happens in real-time via an asynchronous publish⁄subscribe messaging architecture. The updates are guaranteed to be updated in each slave within the required SLA of 95% ≤ 60 minutes. Please note that Neustar’s current architecture is built towards the stricter SLAs (95% ≤ 15 minutes) of .BIZ. The vast majority of updates tend to happen within 2-3 minutes.

26.8 Provision for Searchable WHOIS Capabilities
Neustar will create a new web-based service to address the new search features based on requirements specified in Specification 4 Section 1.8. The application will enable users to search the WHOIS directory using any one or more of the following fields: 

• Domain name
• Registrar ID
• Contacts and registrant’s name
• Contact and registrant’s postal address, including all the sub-fields described in EPP (e.g., street, city, state or province, etc.)
• The system will also allow search using non-Latin character sets which are compliant with IDNA specification.

The user will choose one or more search criteria, combine them by Boolean operators (AND, OR, NOT) and provide partial or exact match regular expressions for each of the criterion name-value pairs. The domain names matching the search criteria will be returned to the user.

Figure 26-2 shows an architectural depiction of the new service. 

To mitigate the risk of this powerful search service being abused by unscrupulous data miners, a layer of security will be built around the query engine which will allow the registry to identify rogue activities and then take appropriate measures. Potential abuses include, but are not limited to:

• Data Mining
• Unauthorized Access
• Excessive Querying
• Denial of Service Attacks

To mitigate the abuses noted above, Neustar will implement any or all of these mechanisms as appropriate:
• Username-password based authentication 
• Certificate based authentication
• Data encryption
• CAPTCHA mechanism to prevent robo invocation of Web query
• Fee-based advanced query capabilities for premium customers.

The searchable WHOIS application will adhere to all privacy laws and policies of the .book registry.

26.9 Resourcing Plans 
As with the SRS, the development, customization, and on-going support of the WHOIS service is the responsibility of a combination of technical and operational teams. The primary groups responsible for managing the service include:

• Development⁄Engineering – 19 employees
• Database Administration – 10 employees
• Systems Administration – 24 employees
• Network Engineering – 5 employees 

Additionally, if customization or modifications are required, the Product Management and Quality Assurance teams will also be involved. Finally, the Network Operations and Information Security play an important role in ensuring the systems involved are operating securely and reliably. The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. Neustar’s WHOIS implementation is very mature, and has been in production for over 10 years. As such, very little new development will be required to support the implementation of the .book registry. The resources are more than adequate to support the WHOIS needs of all the TLDs operated by Neustar, including the .book registry. 

27.1 Registration Life Cycle

Introduction

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

Domain Lifecycle - Description

The registry will use the EPP 1.0 standard for provisioning domain names, contacts and hosts. Each domain record is comprised of three registry object types: domain, contacts, and hosts 
Domains, contacts and hosts may be assigned various EPP defined statuses indicating either a particular state or restriction placed on the object. Some statuses may be applied by the Registrar; other statuses may only be applied by the Registry. Statuses are an integral part of the domain lifecycle and serve the dual purpose of indicating the particular state of the domain and indicating any restrictions placed on the domain. The EPP standard defines 17 statuses, however only 14 of these statuses will be used in the .book TLD registry per the defined .book TLD business rules.

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

• OK – Default status applied by the Registry.
• Inactive – Default status applied by the Registry if the domain has less than 2 nameservers.
• PendingCreate – Status applied by the Registry upon processing a successful Create command, and indicates further action is pending. This status will not be used in the .book TLD registry.
• PendingTransfer – Status applied by the Registry upon processing a successful Transfer request command, and indicates further action is pending.
• PendingDelete – Status applied by the Registry upon processing a successful Delete command that does not result in the immediate deletion of the domain, and indicates further action is pending.
• PendingRenew – Status applied by the Registry upon processing a successful Renew command that does not result in the immediate renewal of the domain, and indicates further action is pending. This status will not be used in the .book TLD registry.
• PendingUpdate – Status applied by the Registry if an additional action is expected to complete the update, and indicates further action is pending. This status will not be used in the .book TLD registry.
• Hold – Removes the domain from the DNS zone.
• UpdateProhibted – Prevents the object from being modified by an Update command.
• TransferProhibted – Prevents the object from being transferred to another Registrar by the Transfer command.
• RenewProhibted – Prevents a domain from being renewed by a Renew command.
• DeleteProhibted – Prevents the object from being deleted by a Delete command. 

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

• Domain may be updated
• Domain may be deleted, either within or after the add-grace period
• Domain may be renewed at anytime during the term
• Domain may be auto-renewed by the Registry
• Domain may be transferred to another registrar. 

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

27.1.1 Registration States

Domain Lifecycle – Registration States

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

• Active 
• Inactive
• Locked
• Pending Transfer
• Pending Delete.

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

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

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

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

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

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

27.1.2 Typical Registration Lifecycle Activities

Domain Creation Process

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

1. Contact objects are created in the SRS database. The same contact object may be used for each contact type, or they may all be different. If the contacts already exist in the database this step may be skipped.
2. Nameservers are created in the SRS database. Nameservers are not required to complete the registration process; however any domain with less than 2 name servers will not be resolvable.
3. The domain is created using the each of the objects created in the previous steps. In addition, the term and any client statuses may be assigned at the time of creation.

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

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

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

• Domain statuses
• Registrant ID
• Administrative Contact ID
• Billing Contact ID
• Technical Contact ID
• Nameservers
• AuthInfo
• Additional Registrar provided fields.

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

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

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

• Initiate a domain transfer
• Cancel a domain transfer
• Approve a domain transfer
• Reject a domain transfer.

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

1. The gaining (new) Registrar submits a Transfer command, which includes the AuthInfo code of the domain name.
2. If the AuthInfo code is valid and the domain is not in a status that does not allow transfers the domain is placed into pendingTransfer status
3. A poll message notifying the losing Registrar of the pending transfer is sent to the Registrar’s message queue
4. The domain remains in pendingTransfer status for up to 120 hours, or until the losing (current) Registrar Acks (approves) or Nack (rejects) the transfer request
5. If the losing Registrar has not Acked or Nacked the transfer request within the 120 hour timeframe, the Registry auto-approves the transfer
6. The requesting Registrar may cancel the original request up until the transfer has been completed.

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

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

27.1.3 Applicable Time Elements
The following section explains the time elements that are involved. 

Grace Periods

There are six grace periods:

• Add-Delete Grace Period (AGP)
• Renew-Delete Grace Period
• Transfer-Delete Grace Period
• Auto-Renew-Delete Grace Period
• Auto-Renew Grace Period
• Redemption Grace Period (RGP). 

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

The following describes each of these grace periods in detail.

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

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

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

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

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

Redemption Grace Period 
The RGP is a special grace period that enables Registrars to restore domains that have been inadvertently deleted but are still in pendingDelete status within the Redemption Grace Period. All domains enter the RGP except those deleted during the AGP. The RGP period is 30 days, during which time the domain may be restored using the EPP RenewDomain command as described below. Following the 30day RGP period the domain will remain in pendingDelete status for an additional five days, during which time the domain may NOT be restored. The domain is released from the SRS, at the end of the 5 day non-restore period. A restore fee applies and is detailed in the Billing Section. A renewal fee will be automatically applied for any domain past expiration.
Neustar has created a unique restoration process that uses the EPP Renew transaction to restore the domain and fulfill all the reporting obligations required under ICANN policy. The following describes the restoration process.

27.2 State Diagram
Figure 27-1 provides a description of the registration lifecycle. 
 
The different states of the lifecycle are active, inactive, locked, pending transfer, and pending delete. Please refer to section 27.1.1 for detail description of each of these states. The lines between the states represent triggers that transition a domain from one state to another. 

The details of each trigger are described below:

• Create: Registry receives a create domain EPP command.
• WithNS: The domain has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
• WithOutNS: The domain has not met the minimum number of nameservers required by registry policy. The domain will not be in the DNS zone.
• Remove Nameservers: Domainʹs nameserver(s) is removed as part of an update domain EPP command. The total nameserver is below the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
• Add Nameservers: Nameserver(s) has been added to domain as part of an update domain EPP command. The total number of nameservers has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
• Delete: Registry receives a delete domain EPP command.
• DeleteAfterGrace: Domain deletion does not fall within the add grace period.
• DeleteWithinAddGrace: Domain deletion falls within add grace period.
• Restore: Domain is restored. Domain goes back to its original state prior to the delete command.
• Transfer: Transfer request EPP command is received.
• Transfer Approve⁄Cancel⁄Reject: Transfer requested is approved or cancel or rejected.
• TransferProhibited: The domain is in clientTransferProhibited and⁄or serverTranferProhibited status. This will cause the transfer request to fail. The domain goes back to its original state.
• DeleteProhibited: The domain is in clientDeleteProhibited and⁄or serverDeleteProhibited status. This will cause the delete command to fail. The domain goes back to its original state.

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

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

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

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

Development⁄Engineering – 19 employees
Registry Product Management – 4 employees
These resources are more than adequate to support the development needs of all the TLDs operated by Neustar, including the .book TLD registry. 

28.1 Abuse Prevention and Mitigation

Strong abuse prevention of a new gTLD is an important benefit to the internet community. DotBook, LLC (“DotBook”) and its registry operator and back-end registry services provider, Neustar, agree that a registry must not only aim for the highest standards of technical and operational competence, but also needs to act as a steward of the space on behalf of the Internet community and ICANN in promoting the public interest. Neustar brings extensive experience establishing and implementing registration policies. This experience will be leveraged to help the .book TLD combat abusive and malicious domain activity within the new gTLD space.
One of those public interest functions for a responsible domain name registry includes working towards the eradication of abusive domain name registrations, including, but not limited to, those resulting from:

• Illegal or fraudulent actions 
• Spam
• Phishing
• Pharming 
• Distribution of malware 
• Fast flux hosting 
• Botnets 
• Distribution of child pornography 
• Online sale or distribution of illegal pharmaceuticals.

More specifically, although traditionally botnets have used Internet Relay Chat (IRC) servers to control registry and the compromised PCs, or bots, for DDoS attacks and the theft of personal information, an increasingly popular technique, known as fast-flux DNS, allows botnets to use a multitude of servers to hide a key host or to create a highly-available control network. This ability to shift the attacker’s infrastructure over a multitude of servers in various countries creates an obstacle for law enforcement and security researchers to mitigate the effects of these botnets. But a point of weakness in this scheme is its dependence on DNS for its translation services. By taking an active role in researching and monitoring these sorts of botnets, Applicant’s partner, Neustar, has developed the ability to efficiently work with various law enforcement and security communities to begin a new phase of mitigation of these types of threats.

Policies and Procedures to Minimize Abusive Registrations

A Registry must have the policies, resources, personnel, and expertise in place to combat such abusive DNS practices. As DotBook’s registry provider for the .book TLD, Neustar is at the forefront of the prevention of such abusive practices and is one of the few registry operators to have actually developed and implemented an active “domain takedown” policy. We also believe that a strong program is essential given that registrants have a reasonable expectation that they are in control of the data associated with their domains, especially its presence in the DNS zone. Because domain names are sometimes used as a mechanism to enable various illegitimate activities on the Internet often the best preventative measure to thwart these attacks is to remove the names completely from the DNS before they can impart harm, not only to the domain name registrant, but also to millions of unsuspecting Internet users.

Removing the domain name from the zone has the effect of shutting down all activity associated with the domain name, including the use of all websites and e-mail. The use of this technique should not be entered into lightly. DotBook has an extensive, defined, and documented process for taking the necessary action of removing a domain from the zone when its presence in the zone poses a threat to the security and stability of the infrastructure of the Internet or the registry. 

Abuse Point of Contact 
As required by the Registry Agreement, DotBook, LLC (“DotBook”) will establish and publish on its website a single abuse point of contact responsible for addressing inquiries from law enforcement and the public related to malicious and abusive conduct. DotBook will also provide such information to ICANN prior to the delegation of any domain names in the .book TLD. This information shall consist of, at a minimum, a valid e-mail address dedicated solely to the handling of malicious conduct complaints, and a telephone number and mailing address for the primary contact. We will ensure that this information will be kept accurate and up to date and will be provided to ICANN if and when changes are made. In addition, with respect to inquiries from ICANN-Accredited registrars, our registry services provider, Neustar, shall have an additional point of contact, as it does today, handling requests by registrars related to abusive domain name practices. 

28.2 Policies Regarding Abuse Complaints
One of the key policies each new gTLD registry will need to have is an Acceptable Use Policy that clearly delineates the types of activities that constitute “abuse” and the repercussions associated with an abusive domain name registration. In addition, the policy will be incorporated into the applicable Registry-Registrar Agreement and reserve the right for the registry to take the appropriate actions based on the type of abuse. This willinclude locking down the domain name preventing any changes to the contact and nameserver information associated with the domain name, placing the domain name “on hold” rendering the domain name non-resolvable, transferring to the domain name to another registrar, and⁄or in cases in which the domain name is associated with an existing law enforcement investigation, substituting name servers to collect information about the DNS queries to assist the investigation. 

DotBook will adopt an Acceptable Use Policy for the .book TLD that clearly defines the types of activities that will not be permitted in the TLD and reserves the right of the Applicant to lock, cancel, transfer or otherwise suspend or take down domain names violating the Acceptable Use Policy and allow the Registry where and when appropriate to share information with law enforcement. Each ICANN-Accredited Registrar must agree to pass through the Acceptable Use Policy to its Resellers (if applicable) and ultimately to the .book registrants. Below is the Registry’s initial Acceptable Use Policy that we will use in connection with the .book TLD


DotBook (.book) Acceptable Use Policy
This Acceptable Use Policy gives the Registry the ability to quickly lock, cancel, transfer or take ownership of any .book domain name, either temporarily or permanently, if the domain name is being used in a manner that appears to threaten the stability, integrity or security of the Registry, or any of its registrar partners – and⁄or that may put the safety and security of any registrant or user at risk. The process also allows the Registry to take preventive measures to avoid any such criminal or security threats.
The Acceptable Use Policy may be triggered through a variety of channels, including, among other things, private complaint, public alert, government or enforcement agency outreach, and the on-going monitoring by the Registry or its partners. In all cases, the Registry or its designees will alert Registry’s registrar partners about any identified threats, and will work closely with them to bring offending sites into compliance.

The following are some (but not all) activities that may be subject to rapid domain compliance:
• Phishing: the attempt to acquire personally identifiable information by masquerading as a website other than .book.
• Pharming: the redirection of Internet users to websites other than those the user intends to visit, usually through unauthorized changes to the Hosts file on a victim’s computer or DNS records in DNS servers.
• Dissemination of Malware: the intentional creation and distribution of ʺmaliciousʺ software designed to infiltrate a computer system without the owner’s consent, including, without limitation, computer viruses, worms, key loggers, and Trojans.
• Fast Flux Hosting: a technique used to shelter Phishing, Pharming and Malware sites and networks from detection and to frustrate methods employed to defend against such practices, whereby the IP address associated with fraudulent websites are changed rapidly so as to make the true location of the sites difficult to find.
• Botnetting: the development and use of a command, agent, motor, service, or software which is implemented: (1) to remotely control the computer or computer system of an Internet user without their knowledge or consent, (2) to generate direct denial of service (DDOS) attacks.
• Malicious Hacking: the attempt to gain unauthorized access (or exceed the level of authorized access) to a computer, information system, user account or profile, database, or security system.
• Child Pornography: the storage, publication, display and⁄or dissemination of pornographic materials depicting individuals under the age of majority in the relevant jurisdiction.

The Registry reserves the right, in its sole discretion, to take any administrative and operational actions necessary, including the use of computer forensics and information security technological services, among other things, in order to implement the Acceptable Use Policy. In addition, the Registry reserves the right to deny, cancel or transfer any registration or transaction, or place any domain name(s) on registry lock, hold or similar status, that it deems necessary, in its discretion; (1) to protect the integrity and stability of the registry; (2) to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of Registry as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement or (5) to correct mistakes made by the Registry or any Registrar in connection with a domain name registration. Registry also reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a dispute. 

Monitoring for Malicious Activity
DotBook’s back end registry partner, Neustar is at the forefront of the prevention of abusive DNS practices. Neustar is one of only a few registry operators to have actually developed and implemented an active “domain takedown” policy in which the registry itself takes down abusive domain names. Neustar’s approach is quite different from a number of other gTLD Registries and the results have been unmatched. Neustar targets verified abusive domain names and removes them within 12 hours regardless of whether or not there is cooperation from the domain name registrar. This is because Neustar has determined that the interest in removing such threats from the consumer outweighs any potential damage to the registrar⁄registrant relationship. 

Neustar’s active prevention policies stem from the notion that registrants in the .book TLD have a reasonable expectation that they are in control of the data associated with their domains, especially its presence in the DNS zone. Because domain names are sometimes used as a mechanism to enable various illegitimate activities on the Internet, including malware, bot command and control, pharming, and phishing, the best preventative measure to thwart these attacks is often to remove the names completely from the DNS before they can impart harm, not only to the domain name registrant, but also to millions of unsuspecting Internet users.

Rapid Takedown Process
Since implementing the program, Neustar has developed two basic variations of the process. The more common process variation is a light-weight process that is triggered by “typical” notices. The less-common variation is the full process that is triggered by unusual notices. These notices tend to involve the need for accelerated action by the registry in the event that a complaint is received by Neustar which alleges that a domain name is being used to threaten the stability and security of the .book TLD, or is part of a real-time investigation by law enforcement or security researchers. These processes are described below:

Lightweight Process 
In addition to having an active Information Security group that, on its own initiatives, seeks out abusive practices in the .book TLD, Neustar is an active member in a number of security organizations that have the expertise and experience in receiving and investigating reports of abusive DNS practices, including but not limited to, the Anti-Phishing Working Group, Castle Cops, NSP-SEC, the Registration Infrastucture Safety Group and others. Each of these sources are well-known security organizations that have developed a reputation for the prevention of harmful agents affecting the Internet. Aside from these organizations, Neustar also actively participates in privately run security associations whose basis of trust and anonymity makes it much easier to obtain information regarding abusive DNS activity.

Once a complaint is received from a trusted source, third-party, or detected by Neustar’s internal security group, information about the abusive practice is forwarded to an internal mail distribution list that includes members of the operations, legal, support, engineering, and security teams for immediate response (“CERT Team”). Although the impacted URL is included in the notification e-mail, the CERT Team is trained not to investigate the URLs themselves since often times the URLs in Question have scripts, bugs, etc. that can compromise the individual’s own computer and the network safety. Rather, the investigation is done by a few members of the CERT team that are able to access the URLs in a laboratory environment so as to not compromise the Neustar network. The lab environment is designed specifically for these types of tests and is 
scrubbed on a regular basis to ensure that none of Neustar’s internal or external network elements are harmed in any fashion.Once the complaint has been reviewed and the alleged abusive domain name activity is verified to the best of the ability of the CERT Team, the sponsoring registrar is given 12 hours to investigate the activity and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hNeustar’s period (i.e., is unresponsive to the request or refuses to take action), Neustar places the domain on “ServerHold”. Although this action removes the domain name from the .book TLD zone, the domain name record still appears in the .book TLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved.

Full Process. In the event that DotBook and⁄or Neustar receives a complaint which claims that a domain name is being used to threaten the stability and security of the .book TLD or is a part of a real-time investigation by law enforcement or security researchers, Neustar follows a slightly different course of action.Upon initiation of this process, members of the CERT Team are paged and a teleconference bridge is immediately opened up for the CERT Team to assess whether the activity warrants immediate action. If the CERT Team determines the incident is not an immediate threat to the security and the stability of critical internet infrastructure, they provide documentation to the Neustar Network Operations Center to clearly capture the rationale for the decision and either refers the incident to the Lightweight process set forth above. If no abusive practice is discovered, the incident is closed. 

However, if the CERT TEAM determines there is a reasonable likelihood that the incident warrants immediate action as described above, a determination is made to immediately remove the domain from the zone. As such, Customer Support contacts the responsible registrar immediately to communicate that there is a domain involved in a security and stability issue. The registrar is provided only the domain name in Question and the broadly stated type of incident. Given the sensitivity of the associated security concerns, it may be important that the registrar not be given explicit or descriptive information in regards to data that has been collected (evidence) or the source of the complaint. The need for security is to fully protect the chain of custody for evidence and the source of the data that originated the complaint. 

Coordination with Law Enforcement & Industry Groups
One of the reasons for which Neustar was selected to serve as the back-end registry services provider by DotBook for the .book TLD is Neustar’s extensive experience with its industry-leading abusive domain name and malicious monitoring program and its close working relationship with a number of law enforcement agencies, both in the United States and internationally. For example, in the United States, Neustar is in constant communication with the Federal Bureau of Investigation, US CERT, Homeland Security, the Food and Drug Administration, and the National Center for Missing and Exploited Children. Neustar is also a participant in a number of industry groups aimed at sharing information amongst key industry players about the abusive registration and use of domain names. These groups include the Anti-Phishing Working Group and the Registration Infrastructure Safety Group (where Neustar served for several years as on the Board of Directors). Through these organizations and others, Neustar shares information with other registries, registrars, ccTLDs, law enforcement, security professionals, etc. not only on abusive domain name registrations within its own TLDs, but also provides information uncovered with respect to domain names in other registries’ TLDs. Neustar has often found that rarely are abuses found only in the TLDs for which it manages, but also within other TLDs, such as .com and .info. Neustar routinely provides this information to the other registries so that it can take the appropriate action.

With the assistance of Neustar as its back-end registry services provider, DotBook can meet its obligations under Section 2.8 of the Registry Agreement where required to take reasonable steps to investigate and respond to reports from law enforcement and governmental and quasi-governmental agencies of illegal conduct in connection with the use of its TLD. DotBook and⁄or Neustar will respond to legitimate law enforcement inquiries within one business day from receiving the request. Such response shall include, at a minimum, an acknowledgement of receipt of the request, Questions or comments concerning the request, and an outline of the next steps to be taken by DotBook and⁄or Neustar for rapid resolution of the request. 

In the event such request involves any of the activities which can be validated by DotBook and⁄or Neustar and involves the type of activity set forth in the Acceptable Use Policy, the sponsoring registrar is then given 12 hours to investigate the activity further and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), Neustar places the domain on “serverHold”. 

28.3 Measures for Removal of Orphan Glue Records
As the Security and Stability Advisory Committee of ICANN (SSAC) rightly acknowledges, although orphaned glue records may be used for abusive or malicious purposes, the “dominant use of orphaned glue supports the correct and ordinary operation of the DNS.” See http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf. 
While orphan glue often support correct and ordinary operation of the DNS, we understand that such glue records can be used maliciously to point to name servers that host domains used in illegal phishing, bot-nets, malware, and other abusive behaviors. Problems occur when the parent domain of the glue record is deleted but its children glue records still remain in DNS. Therefore, when the .book TLD Registry has written evidence of actual abuse of orphaned glue, the Registry will take action to remove those records from the zone to mitigate such malicious conduct. 
Neustar run a daily audit of entries in its DNS systems and compares those with its provisioning system. This serves as an umbrella protection to make sure that items in the DNS zone are valid. Any DNS record that shows up in the DNS zone but not in the provisioning system will be flagged for investigation and removed if necessary. This daily DNS audit serves to not only prevent orphaned hosts but also other records that should not be in the zone. In addition, if either DotBook or Neustar become aware of actual abuse on orphaned glue after receiving written notification by a third party through its Abuse Contact or through its customer support, such glue records will be removed from the zone. 

28.4 Measures to Promote WHOIS Accuracy

DotBook acknowledges that ICANN has developed a number of mechanisms over the past decade that are intended to address the issue of inaccurate WHOIS information. Such measures alone have not proven to be sufficient and DotBook will offer a mechanism whereby third parties can submit complaints directly to the Applicant (as opposed to ICANN or the sponsoring Registrar) about inaccurate or incomplete WHOIS data. Such information shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Thirty days after forwarding the complaint to the registrar, DotBook will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, Applicant reserves the right to suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies. In addition, DotBook shall on its own initiative, no less than twice per year, perform a manual review of a random sampling of .book domain names to test the accuracy of the WHOIS information. Although this will not include verifying the actual information in the WHOIS record, DotBook will be examining the WHOIS data for prima facie evidence of inaccuracies. In the event that such evidence exists, it shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Thirty days after forwarding the complaint to the registrar, the Applicant will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, DotBook reserves the right to suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.

28.4.2 Monitoring of Registration Data (Option)
Regular monitoring of registration data for accuracy and completeness, employing authentication methods, and establishing policies and procedures to address domain names with inaccurate or incomplete WHOIS data. 

28.5 Resourcing Plans 
Responsibility for abuse mitigation rests with a variety of functional groups. The Abuse Monitoring team is primarily responsible for providing analysis and conducting investigations of reports of abuse. The customer service team also plays an important role in assisting with the investigations, responded to customers, and notifying registrars of abusive domains. Finally, the Policy⁄Legal team is responsible for developing the relevant policies and procedures. The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:

Customer Support – 12 employees
Policy⁄Legal – 2 employees
The resources are more than adequate to support the abuse mitigation procedures of the .book registry. 

29.1. Rights Protection Mechanisms

DotBook, LLC (“DotBook”) is firmly committed to the protection of Intellectual Property rights and to implementing the mandatory rights protection mechanisms for the .book TLD as contained in the Applicant Guidebook and detailed in Specification 7 of the Registry Agreement. DotBook recognizes that although the New gTLD program includes significant protections beyond those that were mandatory for a number of the current TLDs, a key motivator for DotBook’s selection of Neustar as its registry services provider is Neustar’s experience in successfully launching a number of TLDs with diverse rights protection mechanisms, including many the ones required in the Applicant Guidebook. More specifically, DotBook will implement the following rights protection mechanisms in accordance with the Applicant Guidebook as further described below:

• Trademark Clearinghouse: a one-stop shop so that trademark holders can protect their trademarks with a single registration.
• Sunrise and Trademark Claims processes for the TLD.
• Implementation of the Uniform Dispute Resolution Policy to address domain names that have been registered and used in bad faith in the TLD.
• Uniform Rapid Suspension: A quicker, more efficient and cheaper alternative to the Uniform Dispute Resolution Policy to deal with clear cut cases of cybersquatting.
• Implementation of a Thick WHOIS making it easier for rights holders to identify and locate infringing parties

A. Trademark Clearinghouse Including Sunrise and Trademark Claims
The first mandatory rights protection mechanism (“RPM”) required to be implemented by each new gTLD Registry is support for, and interaction with, the trademark clearinghouse. The trademark clearinghouse is intended to serve as a central repository for information to be authenticated, stored and disseminated pertaining to the rights of trademark holders. The data maintained in the clearinghouse will support and facilitate other RPMs, including the mandatory Sunrise Period and Trademark Claims service. Although many of the details of how the trademark clearinghouse will interact with each registry operator and registrars, DotBook is actively monitoring the developments of the Implementation Assistance Group (“IAG”) designed to assist ICANN staff in firming up the rules and procedures associated with the policies and technical requirements for the trademark clearinghouse. In addition, DotBook’s back-end registry services provider is actively participating in the IAG to ensure that the protections afforded by the clearinghouse and associated RPMs are feasible and implementable.Utilizing the trademark clearinghouse, all operators of new gTLDs must offer: (i) a sunrise registration service for at least 30 days during the pre-launch phase giving eligible trademark owners an early opportunity to register second-level domains in new gTLDs; and (ii) a trademark claims service for at least the first 60 days that second-level registrations are open. The trademark claim service is intended to provide clear noticeʺ to a potential registrant of the rights of a trademark owner whose trademark is registered in the clearinghouse. DotBook’s registry service provider for the .book, Neustar, has already implemented Sunrise and⁄or Trademark Claims programs for numerous TLDs including .biz, .us, .travel, .tel and .co and will implement the both of these services on behalf of the .book TLD. 

Neustar’s Experience in Implementing Sunrise and Trademark Claims Processes
In early 2002, Neustar became the first registry operator to launch a successful authenticated Sunrise process. This process permitted qualified trademark owners to pre-register their trademarks as domain names in the .us TLD space prior to the opening of the space to the general public. Unlike any other “Sunrise” plans implemented (or proposed before that time), Neustar validated the authenticity of Trademark applications and registrations with the United States Patent and Trademark Office (USPTO). Subsequently, as the back-end registry operator for the .tel gTLD and the .co ccTLD, Neustar launched validated Sunrise programs employing processes. These programs are very similar to those that are to be employed by the Trademark Clearinghouse for new gTLDs. Below is a high level overview of the implementation of the .co Sunrise period that demonstrates Neustar’s experience and ability to provide a Sunrise service and an overview of Neustar’s experience in implementing a Trademark Claims program to trademark owners for the launch of .BIZ. Neustar’s experience in each of these rights protection mechanisms will enable it to seamlessly provide these services on behalf of DotBook and the .book TLD as required by ICANN. 

a) Sunrise and .co

The Sunrise process for .co was divided into two sub-phases: 
• Local Sunrise giving holders of eligible trademarks that have obtained registered status from the Colombian trademark office the opportunity apply for the .CO domain names corresponding with their marks 
• Global Sunrise program giving holders of eligible registered trademarks of national effect, that have obtained a registered status in any country of the world the opportunity apply for the .CO domain names corresponding with their marks for a period of time before registration is open to the public at large. 

Like the new gTLD process set forth in the Applicant Guidebook, trademark owners had to have their rights validated by a Clearinghouse provider prior to the registration being accepted by the Registry. The Clearinghouse used a defined process for checking the eligibility of the legal rights claimed as the basis of each Sunrise application using official national trademark databases and submitted documentary evidence. 
Applicants and⁄or their designated agents had the option of interacting directly with the Clearinghouse to ensure their applications were accurate and complete prior to submitting them to the Registry pursuant to an optional “Pre-validation Process”. Whether or not an applicant was “pre-validated”, the applicant had to submit its corresponding domain name application through an accredited registrar. When the Applicant was pre-validated through the Clearinghouse, each was given an associated approval number that it had to supply the registry. If they were not pre-validated, applicants were required to submit the required trademark information through their registrar to the Registry.As the registry level, Neustar, subsequently either delivered the: 

• Approval number and domain name registration information to the Clearinghouse
• When there was no approval number, trademark information and the domain name registration information was provided to the Clearinghouse through EPP (as is currently required under the Applicant Guidebook). 

Information was then used by the Clearinghouse as either further validation of those pre-validated applications, or initial validation of those that did not go through pre-validation. If the applicant was validated and their trademark matched the domain name applied-for, the Clearinghouse communicated that fact to the Registry via EPP. When there was only one validated sunrise application, the application proceeded to registration when the .co launched. If there were multiple validated applications (recognizing that there could be multiple trademark owners sharing the same trademark), those were included in the .co Sunrise auction process. Neustar tracked all of the information it received and the status of each application and posted that status on a secure Website to enable trademark owners to view the status of its Sunrise application. Although the exact process for the Sunrise program and its interaction between the trademark owner, Registry, Registrar, and IP Clearinghouse is not completely defined in the Applicant Guidebook and is dependent on the current RFI issued by ICANN in its selection of a Trademark Clearinghouse provider, Neustar’s expertise in launching multiple Sunrise processes and its established software will implement a smooth and compliant Sunrise process for the new gTLDs.

b) Trademark Claims Service Experience
With Neustar’s biz TLD launched in 2001, Neustar became the first TLD with a Trademark Claims service. Neustar developed the Trademark Claim Service by enabling companies to stake claims to domain names prior to the commencement of live .biz domain registrations. During the Trademark Claim process, Neustar received over 80,000 Trademark Claims from entities around the world. Recognizing that multiple intellectual property owners could have trademark rights in a particular mark, multiple Trademark Claims for the same string were accepted. All applications were logged into a Trademark Claims database managed by Neustar. 

The Trademark Claimant was required to provide various information about their trademark rights, including the:
• Particular trademark or service mark relied on for the trademark Claim
• Date a trademark application on the mark was filed, if any, on the string of the domain name
• Country where the mark was filed, if applicable
• Registration date, if applicable
• Class or classes of goods and services for which the trademark or service mark was registered
• Name of a contact person with whom to discuss the claimed trademark rights. 

Once all Trademark Claims and domain name applications were collected, Neustar then compared the claims contained within the Trademark Claims database with its database of collected domain name applications (DNAs). In the event of a match between a Trademark Claim and a domain name application, an e-mail message was sent to the domain name applicant notifying the applicant of the existing Trademark Claim. The e-mail also stressed that if the applicant chose to continue the application process and was ultimately selected as the registrant, the applicant would be subject to Neustar’s dispute proceedings if challenged by the Trademark Claimant for that particular domain name. The domain name applicant had the option to proceed with the application or cancel the application. Proceeding on an application meant that the applicant wanted to go forward and have the application proceed to registration despite having been notified of an existing Trademark Claim. By choosing to “cancel,” the applicant made a decision in light of an existing Trademark Claim notification to not proceed. If the applicant did not respond to the e-mail notification from Neustar, or elected to cancel the application, the application was not processed. This resulted in making the applicant ineligible to register the actual domain name. If the applicant affirmatively elected to continue the application process after being notified of the claimant’s (or claimants’) alleged trademark rights to the desired domain name, Neustar processed the application. This process is very similar to the one ultimately adopted by ICANN and incorporated in the latest version of the Applicant Guidebook. Although the collection of Trademark Claims for new gTLDs will be by the Trademark Clearinghouse, many of the aspects of Neustar’s Trademark Claims process in 2001 are similar to those in the Applicant Guidebook. This makes Neustar uniquely qualified to implement the new gTLD Trademark Claims process.
. 
B. Uniform Dispute Resolution Policy (UDRP) and Uniform Rapid Suspension (URS)

UDRP
Prior to joining Neustar, Mr. Neuman was a key contributor to the development of the Uniform Dispute Resolution Policy (“UDRP”) in 1998. This became the first “Consensus Policy” of ICANN and has been required to be implemented by all domain name registries since that time. The UDRP is intended as an alternative dispute resolution process to transfer domain names from those that have registered and used domain names in bad faith. Although there is not much of an active role that the domain name registry plays in the implementation of the UDRP, Neustar has closely monitored UDRP decisions that have involved the TLDs for which it supports and ensures that the decisions are implemented by the registrars supporting its TLDs. When alerted by trademark owners of failures to implement UDRP decisions by its registrars, Neustar either proactively implements the decisions itself or reminds the offending registrar of its obligations to implement the decision. 

URS
In response to complaints by trademark owners that the UDRP was too cost prohibitive and slow, and the fact that more than 70 percent of UDRP cases were “clear cut” cases of cybersquatting, ICANN adopted the IRT’s recommendation that all new gTLD registries be required, pursuant to their contracts with ICANN, to take part in a Uniform Rapid Suspension System (“URS”). The purpose of the URS is to provide a more cost effective and timely mechanism for brand owners than the UDRP to protect their trademarks and to promote consumer protection on the Internet. The URS is not meant to address Questionable cases of alleged infringement (e.g., use of terms in a generic sense) or for anti-competitive purposes or denial of free speech, but rather for those cases in which there is no genuine contestable issue as to the infringement and abuse that is taking place. 
Unlike the UDRP which requires little involvement of gTLD registries, the URS envisages much more of an active role at the registry-level. For example, rather than requiring the registrar to lock down a domain name subject to a UDRP dispute, it is the registry under the URS that must lock the domain within 24hours of receipt of the complaint from the URS Provider to restrict all changes to the registration data, including transfer and deletion of the domain names. In addition, in the event of a determination in favor of the complainant, the registry is required to suspend the domain name. This suspension remains for the balance of the registration period and would not resolve the original website. Rather, the nameservers would be redirected to an informational web page provided by the URS Provider about the URS. Additionally, the WHOIS reflects that the domain name will not be able to be transferred, deleted, or modified for the life of the registration. Finally, there is an option for a successful complainant to extend the registration period for one additional year at commercial rates. DotBook is fully aware of each of these requirements and will have the capability to implement these requirements for the .book TLDs. In fact, during the IRT’s development of the URS, Neustar began examining the implications of the URS on its registry operations and provided the IRT with feedback on whether the recommendations from the IRT would be feasible for registries to implement. Although there have been a few changes to the URS since the IRT recommendations, Neustar continued to participate in the development of the URS by providing comments to ICANN, many of which were adopted. As a result, Neustar is committed to supporting the URS for all of the registries that it provides back-end registry services.

C. Implementation of Thick WHOIS
The .book TLD registry will include a thick WHOIS database as required in Specification 4 of the Registry agreement. A thick WHOIS provides numerous advantages including a centralized location of registrant information, the ability to more easily manage and control the accuracy of data, and a consistent user experience. 

D. Policies Handling Complaints Regarding Abuse
In addition the Rights Protection mechanisms addressed above, DotBook will implement a number of measures to handle complaints regarding the abusive registration of domain names in the .book TLD as described in DotBook’s response to Question 28.

Registry Acceptable Use Policy
One of the key policies each new gTLD registry is the need to have is an Acceptable Use Policy that clearly delineates the types of activities that constitute “abuse” and the repercussions associated with an abusive domain name registration. The policy must be incorporated into the applicable Registry-Registrar Agreement and reserve the right for the registry to take the appropriate actions based on the type of abuse. This may include locking down the domain name preventing any changes to the contact and nameserver information associated with the domain name, placing the domain name “on hold” rendering the domain name non-resolvable, transferring to the domain name to another registrar, and⁄or in cases in which the domain name is associated with an existing law enforcement investigation, substituting name servers to collect information about the DNS queries to assist the investigation. DotBook’s Acceptable Use Policy, set forth in our response to Question 28, will include prohibitions on phishing, pharming, dissemination of malware, fast flux hosting, hacking, child pornography, or the illicit promotion or sale of harmful substances. In addition, the policy will include the right of the registry to take action necessary to deny, cancel, suspend, lock, or transfer any registration in violation of the policy.

Monitoring for Malicious Activity 
DotBook is committed to ensuring that those domain names associated with abuse or malicious conduct in violation of the Acceptable Use Policy are dealt with in a timely and decisive manner. These include taking action against those domain names that are being used to threaten the stability and security of the .book TLD, or is part of a real-time investigation by law enforcement. Once a complaint is received from a trusted source, third-party, or detected by the Registry, the Registry will use commercially reasonable efforts to verify the information in the complaint. If that information can be verified to the best of the ability of the Registry, the sponsoring registrar will be notified and be given 12 hours to investigate the activity and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the Registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), the Registry will place the domain on “ServerHold”. Although this action removes the domain name from the .book TLD zone, the domain name record still appears in the .book TLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved.

29.2 Safeguards Against Unqualified Registrations
The DotBook registryʹs mission is to establish .book as the most preferred top level domain for global book industry stakeholders and the book consumers that purchase from them. To ensure our success in this endeavor, it is vital that publisher and author registrants be safeguarded from abusive registrations, even in a non-trademark capacity, that might be used to promote unauthorized access to copyrighted text and image based works legally assigned to such stakeholders. DotBook will provide both a Trademark Claims and a Sunrise Service as part of its registry operations to mitigate unqualified registrations. The illegal copying of books remains fairly common, especially for purposes of education. While statistics are difficult to determine precisely, a 2007 estimate by Video Business stated that $18.2 billion had potentially been lost over the prior decade due to piracy activities in the United States alone, although that number also includes music and movies. Copyright protection of text-based works, while not directly related to this TLD, is of primary concern in the context of registrations since most book titles cannot be trademarked. A lack of safeguards against unqualified registrations could result in situations where title-based domains for books (TheDaVinciCode.book) that are not in the public domain could be secured by registrants who do not have legal rights to distribute them. For most companies, a trademark is more than just a name or symbol used in identification of products and services. It represents the value of the brand in the marketplace. For publisher and author registrants, often the most easily recognized brand is not the publisher or imprint name, or even the author - names which can usually be trademarked. It is, in fact, the title of the book itself, which in most cases, is not subject to trademark protection. And so while the internet can become a highly effective tool for promoting and extending book brands, it also has the potential to provide numerous opportunities for unscrupulous parties to steal brand equity or sell unauthorized copies in the global market. 

The USPTO (United States Patent and Trademark Office) classifies books in the class of “paper goods,ʺ although it is questionable whether this classification represents an accurate definition of a book in the 21st century. Nevertheless, this class is one of the most challenged in qualifying for trademark protection. The applicant has to be using the “mark”—that is, the book title—for at least three different products in that class. There could be a series of books under a common title (Chicken Soup for The Soul, Twilight, Harry Potter), or three different products: a book, a workbook, and a supplement to the book all under the same title. But there is no real way to protect the title of a single book, either through trademark or through copyright. To address the potential for unqualified registrations around individual titles, DotBook will create a safeguard clearinghouse mechanism to pre-validate that book titles are assigned to the appropriate party during the Sunrise period. In anticipation of such risks, DotBook will be implementing specific and targeted preventive IP protection mechanisms that will greatly reduce the risk of new .book applicants capturing title domains and turning them into cybersquatting channels. DotBook will implement a credible, legitimate and cost-effective process for protecting content IP owners as well as trademark owners, and thus preserve the legitimacy and credibility of the entire domain. 

Safeguards for Title Domains: The principles of our safeguard clearinghouse for title domains will be as follows:

• To assign title domains with a current registered electronic rights holder to that person or entity if the rights holder submits an application in the sunrise period.
• To assign title domains without a registered electronic rights holder to either the publisher or author in an auction process if applications are submitted in the same phase, or on a first-come, first-serve basis, if only one party submits an application in the sunrise period.
• To assign title domains for titles shared by more than one party in an auction process if the applications are submitted in the same phase, to the first rights holder on a first-come, first-serve basis if only one application is submitted in the sunrise period. 
• To assign title domains for public domain works in an auction process if more than one publisher who has previously published the work submit applications in the same phase, or on a first-come, first-serve basis if only one publisher submits an application during the sunrise period.

The Sunrise Service: The objective of the sunrise period will be as follows:
• To ensure trademark protection across all book industry stakeholders.
• To ensure electronic copyright verification for IP rights holders who want to secure title domains
• To give ample time to publishers and authors to identify their domain needs and collect the necessary contractual documentation that establishes their IP rights as part of a pre-validation service
• To implement a fair and equitable auction process in circumstances where a title name is common to more than one party, or in cases where both author and publisher have applied for the domain and electronic rights to the underlying work have not been legally established.
• To ensure the protection of first level geographic names (France.book) and their assignment to each countryʹs authoritative representative and publisher of their Books In Print country catalog.
• To avoid legal disputes related to multiple claims on single titles, and on abusive or unqualified registration risks.

Pre-Validation Eligibility: As a prerequisite to the clearinghouse mechanism, authors and publishers of record will be granted up to 24 months (or less based on a phased approach) to submit applications for titles that have already been assigned ISBNs (International Standard Book Numbers) and that can identify their status as either publisher or author. The International Standard Book Number is a 10-digit or 13-digit coding system allowing publishers, libraries, and booksellers to identify individual books and to associate these specific books with their rightful publishers and authors. Each ISBN is unique to a specific book and is typically found over or under the bar code on the bookʹs back cover and on the title or copyright page. For titles that have already been published, we will establish a pre-validation process during the sunrise period. For books published after 1970 when ISBNs were first established, this process will match the applicant with the publisher or author of record for a given ISBN identifier number. For works published prior to the issuance of the ISBN, or in the absence of an assigned ISBN, DotBook will request validating documentation from the applicant that can be verified with other third party verification sources. For the duration of the sunrise period, no applications will be accepted for title domains for already published works from anyone other than the publisher or author of record.

Publishers and authors using pre-verification in the sunrise period will be given a validation code, which can be used to alert the registrar that the application is accepted. By using ISBNs as an eligibility validation requirement and by offering an extended sunrise period, we anticipate that any eligible author or publisher interested in securing a .book domain for their book title will be able to do so prior to the Landrush phase. In the event of competing validated parties (say, both author and publisher where no electronic IP owners are specified or two authors who have used identical titles for their books) the registry will utilize an auction process during the sunrise phase. Following the sunrise phase, all such assignments will be made on a first-come, first-serve basis.

To help insure accuracy in our domain registration process during the sunrise phase, DotBook will also work in close collaboration with The International Federation of Reproduction Rights Organizations (IFRRO), an independent organization established on the basis of the fundamental international copyright principles embodied in the Berne and Universal Copyright Conventions. Its purpose is to facilitate, on an international basis, the collective management of reproduction and other rights relevant to copyrighted works through the co-operation of national Reproduction Rights Organizations (RROs) around the world. To accomplish its mission, IFRRO fosters the development of information-exchange systems and effective methods for conveyance of rights and fees among rightsholders and users. IFRRO facilitates co-operation among RROs as well as with and among creators, publishers and their associations. 

Whether or not a book is in the public domain or has a legal IP rights holder can be a tricky legal question for some works but not for the vast majority of them. A public domain work is a creative work that is not protected by copyright and which may be freely used by everyone. Reasons why the work is not protected could include: (1) the term of copyright for the work has expired; (2) the author failed to satisfy statutory formalities to perfect the copyright or (3) the work is a work of the U.S. Government. For books already in the public domain that no longer have rights holders, applications will be accepted throughout the sunrise period on a first-come, first-serve basis from any publisher who has previously published the work, unless two publishers submit applications at the same time. Following the sunrise period, all public domain works (PrideAndPrejudice.book) and related author names (JaneAustin.book) will be made available to all applicants on a first-come, first-serve basis.

Despite some exceptions, there is minor ambiguity over which publishers have rights to which titles that are not in the public domain as these rights are usually spelled out in contractual agreements between publishers and authors, as well as among publishers. In some cases, however, the work is not yet in the public domain but the name of the author or copyright owner cannot be firmly established. These works are called orphan works. Attempts will not be made in the sunrise period to register orphan works unless a legitimate copyright owner can be firmly established. As part of the pre-validation eligibility process, DotBook will require a legal contract stating electronic rights be submitted along with the application. These pre-verification mechanisms, while not expensive or onerous, will lengthen the processing time for the acceptance of applications but will ultimately increase stakeholder adoption and ensure confidence in the legitimacy of the .book domain.

In addition to IP rights, there are also publishing rights which must be considered as well in the allocation of .book domains. For example, a publisher in one country might contract with multiple publishers in other countries to license a work to representatives who understand the local market. Many of these agreements, often referred to as ʺterritorial rightsʺ in publishing jargon, are part of a print-centric legacy supply chain model that did not envision the global distribution potential of the internet. In the past year there has been ample discussion about the abolishment of territorial rights for books and it is possible to imagine the future of publishing involving global deals, global e-rights and one universal book cover. Richard Charkin, executive director of London-based Bloomsbury recently said he felt territorial restrictions based on countries is ʺobsolete.ʺ But while momentum is building in that direction, unraveling the legacy network of complex territorial rights to books which govern where they can be marketed and displayed will take time. Some publishers already have worldwide rights but others may only have rights in a limited number of countries, or might otherwise have worldwide rights with a couple of notable exceptions. Throughout the sunrise period and afterwards, all competing applications for title domains from more than one publisher with legitimate territory rights will be awarded on a first-come, first-serve basis unless they are submitted during the same phase, in which case an auction will be conducted.

For all of the reasons stated above, DotBook has determined that an effective sunrise period must be of a sufficient duration to allow for the processing of these applications in an accurate manner, for time to process pre-validation eligibility, and for the unraveling of legacy contractual agreements that we expect will be phased out over time. As such, we have determined that an effective sunrise period might need to last up to two years. We fully expect that initial adoption of the .book domains will be slow throughout this period as publishers adjust to a direct marketing orientation and begin to take ownership over their growing relationship with customers. 

Two Year Sunrise Period: The .book domain must secure the support of publishers and authors in order to realize its full potential as a community service capable of bestowing economic benefits to its registrants. The ubiquitous industry adoption of .book domains is a paramount objective of DotBook LLC. Full industry support will maximize the sustainable value of the .book domain to each of its customers because it will result in a resetting of expectations with consumers around how they should search for books. Higher adoption rates will yield marketing efficiencies for all industry participants trying to bring new books to market , as well as those trying to extend the marketability of books already in print.Numerous publishers and authors are already accustomed to marketing and selling books directly on the internet. These companies and individuals will likely serve as early adopters in the space. Publishers like F+W Media and OʹReilly Media, for example, have already embraced a direct sales channel and are now deriving over half of their revenues from digital editions sold directly through their website. Virtually all of the professional and academic publishers make their content available online and have experienced the cost advantages first hand. But the trade publishing market, which currently represents over 50 percent of the publishing output, has been slow to embrace the internet, mainly for contractual reasons.

Given these industry dynamics, DotBook will be implementing a lengthy sunrise period with specific safeguard mechanisms that will be deployed through each phase to ensure potential abuses are mitigated.
The goal of DotBookʹs sunrise period is to ensure that all book stakeholders are able to successfully leverage the brand recognition and value established from their works in the context of the new .book domain assignments, if they choose to do so. We recognize that trademarks are an important business asset for book industry stakeholders and as such, we will be implementing a pre-launch Rights Protection Mechanism (RPM) that will involve a phased sunrise period to fully support the needs of book industry stakeholders and their trademarked brands. Non-trademarked brands will also receive special outreach.
This approach to protecting both trademarked and non-trademarked names is necessitated by the fact that many of the most recognizable ʺbrandsʺ in book publishing are the actual titles of books, which for the most part are not subject to trademark protection. We trust such extra community-oriented measures will greatly reduce the risk of title domains being registered by applicants that do not have the rights to distribute or sell the book, including any portion of its content. Publisher and authors have a tremendous amount of goodwill attached to certain titles that cannot be formally assigned trademark protection. But consumer trust and full stakeholder adoption will be enhanced if consumers can rely on the fact that when they visit a .book domain to purchase a particular title, that seller has the legal distribution rights.The Sunrise period will be in effect for up to two years, with different phases running both concurrently and in succession. All applicants arriving within the timeframe of a given phase will be considered to have arrived at the same time. The longer timeframe is being implemented in support of both authors and publishers. Ultimately, our objective is to allocate desirable terms such as popular title names, semantic subject terms and trademarks fairly and appropriately between eligible claimants from across jurisdictions and to avoid disputes wherever possible. 

The Sunrise period (SP) will consist of 4 distinct phases:

SP1: Phase 1 is intended for the submission of applications by book industry stakeholders who are owners of current registered trademarks and can provide such proof in writing via a trademark registration number, a grant date and the country of registration. Potential registrant categories: publishers, publisher imprints, authors, distributors, booksellers, literary agents, libraries, illustrators, photographers, associations, bibliographic agencies, self-publishers and device manufacturers.This phase will also be applied towards the protection of first level geographic names for individual countries and their authoritative representatives. Over 160 countries currently have an official country representative for the assignment of international standard book numbers (ISBN). The International Standard Book Number was approved as an International Organization for Standardization (ISO) standard number 2108 in 1970. ISO is the worldʹs largest developer and publisher of international standards. Today these agencies serve as the official book registration authorities for their representative countries and maintain the full listing of each countryʹs Books In Print catalog. As such, those representatives will be invited to secure first level geographic names for their countries, names such as Italy.book, and China.book, so that each country can expose the National heritage of its books to its citizens. Potential registrant categories: National ISBN agencies.

SP2: Phase 2 is intended for the submission of applications by book industry stakeholders who are current holders of electronic rights for any and all books published prior to December 31, 2010 (the backlist). Applications will be accepted for book titles where the rights holder can clearly provide written validation of their electronic book rights to the already published title. In this phase, an exact match is required between the title and the domain applied for. Potential registrant categories: publishers, authors, self-publishers.This phase will also be used to accept applications from interested National, State and Academic Libraries, as well as book industry organizations representing key book industry stakeholders ( for example, the Book Industry Study Group, Bowker, Association of American Publishers in the U.S.; the Book Industry Communications and Nielsen in the UK). Potential registrant categories: libraries, associations.

SP3: Phase 3 is intended for the submission of applications by owners of documented electronic rights for book titles published since January 1st 2011 or soon to be published in any jurisdiction (the frontlist). Applications will be accepted for book titles where the rights holder can clearly provide written validation of their electronic book rights to the already published title. In this phase, an exact match is required between the title and the domain applied for. Potential registrant categories: publishers, authors, self-publishers.

SP4: for all other book titles where electronic rights have not been established, including books in the public domain but excluding known orphan works, as well as all other qualified applicants from earlier phases who did not yet submit. Applications which would otherwise have qualified to be submitted in earlier sunrise phases will be processed in this phase on a first come, first serve basis. Potential registrant categories: publishers, self-publishers, authors.

29.3 Resourcing Plans
The rights protection mechanisms described in the response above involve a wide range of tasks, procedures, and systems. The responsibility for each mechanism varies based on the specific requirements. In general the development of applications such as sunrise and IP claims is the responsibility of the Engineering team, with guidance from the Product Management team. Customer Support and Legal play a critical role in 
enforcing certain policies such as the rapid suspension process. These teams have years of experience implementing these or similar processes. The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:

Development⁄Engineering – 19 employees
Product Management- 4 employees
Customer Support – 12 employees
The resources are more than adequate to support the rights protection mechanisms of the .book TLD

Response to Question 30a - Security

DotBook, LLC (“DotBook”) and our back-end operator, Neustar, recognize the vital need to secure the systems and the integrity of the data in commercial solutions. The .book TLD registry solution will leverage industry-best security practices including the consideration of physical, network, server, and application elements. 
Neustar’s approach to information security starts with comprehensive information security policies. These are based on the industry best practices for security including SANS (SysAdmin, Audit, Network, Security) Institute, NIST (National Institute of Standards and Technology), and Center for Internet Security (CIS). Policies are reviewed annually by Neustar’s information security team.

The following is a summary of the security policies that will be used in the .book TLD registry, including:
1. Summary of the security policies used in the registry operations
2. Description of independent security assessments
3. Description of security features that are appropriate for .book
4. List of commitments made to registrants regarding security levels

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

30.(a).1 Summary of Security Policies 

Neustar, Inc. has developed a comprehensive Information Security Program in order to create effective administrative, technical, and physical safeguards for the protection of its information assets, and to comply with Neustarʹs obligations under applicable law, regulations, and contracts. This Program establishes Neustarʹs policies for accessing, collecting, storing, using, transmitting, and protecting electronic, paper, and other records containing sensitive information.
The Program defines:
• The policies for internal users and our clients to ensure the safe, organized and fair use of information resources.
• The rights that can be expected with that use. 
• The standards that must be met to effectively comply with policy.
• The responsibilities of the owners, maintainers, and users of Neustar’s information resources.
• Rules and principles used at Neustar to approach information security issues

The following policies are included in the Program:
1. Acceptable Use Policy

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

2. Information Risk Management Policy

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

3. Data Protection Policy 

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

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

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

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

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

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

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

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

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

12. Mobile Device Security Policy

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

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

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

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

30. (a).2 Independent Assessment Reports
Neustar IT Operations is subject to yearly Sarbanes-Oxley (SOX), Statement on Auditing Standards #70 (SAS70) and ISO audits. Testing of controls implemented by Neustar management in the areas of access to programs and data, change management and IT Operations are subject to testing by both internal and external SOX and SAS70 audit groups. Audit Findings are communicated to process owners, Quality Management Group and Executive Management. Actions are taken to make process adjustments where required and remediation of issues is monitored by internal audit and QM groups.
External Penetration Test is conducted by a third party on a yearly basis. As authorized by Neustar, the third party performs an external Penetration Test to review potential security weaknesses of network devices and hosts and demonstrate the impact to the environment. The assessment is conducted remotely from the Internet with testing divided into four phases:

• A network survey is performed in order to gain a better knowledge of the network that was being tested
• Vulnerability scanning is initiated with all the hosts that are discovered in the previous phase
• Identification of key systems for further exploitation is conducted
• Exploitation of the identified systems is attempted.

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

30.(a).3 Augmented Security Levels and Capabilities
There are no increased security levels specific for .book TLD. However, Neustar will provide the same high level of security provided across all of the registries it manages. 

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

• Include annual independent review of information security practices 
• Include annual external penetration tests by a third party 
• Conform to the ISO 9001 standard (Part of Neustar’s ISO-based Quality Management System)
• Are aligned to Information Technology Infrastructure Library (ITIL) and CoBIT best practices 
• Are aligned with all aspects of ISO IEC 17799
• Are in compliance with Sarbanes-Oxley (SOX) requirements (audited annually)
• Are focused on continuous process improvement (metrics driven with product scorecards reviewed monthly).

A summary view to Neustar’s security policy in alignment with ISO 17799 can be found in section 30.(a).4 below.

30.(a).4 Commitments and Security Levels 

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

Compliance with High Security Standards

• Security procedures and practices that are in alignment with ISO 17799
• Annual SOC 2 Audits on all critical registry systems
• Annual 3rd Party Penetration Tests 
• Annual Sarbanes Oxley Audits

Highly Developed and Document Security Policies
• Compliance with all provisions described in section 30.(a).4 below and in the attached security policy document.
• Resources necessary for providing information security
• Fully documented security policies
• Annual security training for all operations personnel

High Levels of Registry Security
• Multiple redundant data centers
• High Availability Design
• Architecture that includes multiple layers of security
• Diversified firewall and networking hardware vendors
• Multi-factor authentication for accessing registry systems
• Physical security access controls
• A 24x7 manned Network Operations Center that monitors all systems and applications
• A 24x7 manned Security Operations Center that monitors and mitigates DDoS attacks
• DDoS mitigation using traffic scrubbing technologies