Application number: 1-2047-17293 for IG Group Holdings PLC

IG Group Holdings PLC

CANNON BRIDGE HOUSE
25 DOWGATE HILL
London EC4R 2YA
GB

+44 20 7896 0011

+44 207 896 0010

http:⁄⁄www.iggroup.com

Sharon Harris

Head Of Online

+44 20 7573 0329

+44 207 896 0010

sharon6@ngtld.webcentral.com.au

Alastair Hine

Chief Information Office and Marketing Director

+44 20 7573 0410

+44 207 896 0010

Alastair.hine@iggroup.com

Public Limited Company and constituent of FTSE250 .

Incorporated in England and Wales, with registered number 04677092.

Not Available

London_Stock_Exchange

Andrew Mackay
Director of Corporate Strategy
David Currie
Non-Executive Director
Jonathan Davie
Non-Executive Chairman
Martin Jackson
Non-Executive Director
Nat le Roux
Non-Executive Deputy Chairman
Roger Yates
Senior Independent Non-Executive Director
Stephen Hill
Non-Executive Director

Bridget Messer
Company Secretary (officer)
Christopher Hill
Chief Financial Officer
Peter Hetherington
Chief Operating Officer
Tim Howkins
Chief Executive Officer

trading

Not Available

The .trading string and A-Label were developed in line with and checked against the eligibility, stability and policy criteria as stated in the ICANN Applicant Guidebook - version 2012-01-11. The results of those checks are as follows:
- The string has less than 63 characters;
- The string in ASCII is composed of three or more visually distinct characters;
- The ASCII label consists entirely of letters;
- The string is not a reserved name as shown in section 2.2.1.2.1 - Reserved Names of the ICANN Applicant Guidebook - version 2012-01-11; and
- .trading is not identical or similar to any of the top 10 invalid TLD’s responsible for the majority of DNS pollution, as referenced in the Security and Stability Advisory Committee (SSAC)’s report on this topic at http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac045.pdf. It is likely that the .trading has not already been queried with meaningful frequency at the root. Therefore, it is unlikely that .trading will inherit significant invalid query traffic.
Due to the positive results of these checks, IG Group Holdings PLC does not believe that the .trading gTLD will be subject to any operational or rendering problems.

THE MISSION AND PURPOSE OF THE NEW RESTRICTED .TRADING GTLD IS TO BENEFIT INTERNET USERS BY ENSURING INCREASED TRUST, USER CONFIDENCE AND UTILITY THROUGH PROVIDING BETTER KNOWLEDGE AND THE ELIMINATION OF USER CONFUSION.

The .trading gTLD will create a new generation gTLD serving the interests of end users by providing an authoritative Internet space for information, services and resources regarding online financial derivatives trading via IG Group Holdings plc (IG Group). .trading will facilitate IG Group to offer its customers easy access to Pure Deal, its multiple-award-winning, browser-based dealer platform to trade quickly and securely online. The majority of the anticipated domain name registrations in the .trading gTLD will be used in the promotion and communication of the diverse trading options (such as contracts for the difference (CFDs) trading and market trading) offered by IG Group, its affiliates and partners.  A subset of domain names has the potential to be created and used for communication and marketing purposes, with internet users assured of the legitimacy of the trading options and products offered by IG Group. 

IG Group was established in 1974, has its headquarters in London and operates globally with 14 global offices in several European countries, Japan, Singapore and Australia. IG Group is listed on the London Stock Exchange, is a member of the FTSE 250 and has a market capital value of £ 1.7 billion (as at October 2011). IG Group is a world-leading provider of financial derivativesIn the year to May 2011, IG Group achieved a turnover of £320.4 million, and generated a record adjusted profit before tax of £163.0 million. IG Group’s online trading platform (IG Trader⁄Pure Deal) was named Best CFD Platform in 2008 and 2009 by the readers of Spanish weekly financial magazine Mi Cartera de Inversión. The .trading gTLD will increase customers’ trust in trading in financial derivatives via IG Group as a transparent and viable investment opportunity offered in a secure and easily accessible environment by a world-leading provider. The .trading gTLD will allow IG Group to provide strading resources and potential services to online customers in a secure, interactive and authoritative internet space. 

New trading opportunities are increasingly offered over the internet, presenting customers with a wider choice of easy and accessible investment products. As a result, both businesses and end users can benefit from ease of interaction and a wider range of choices with lower transaction costs. However, the development in this arena in the current domain name system has exposed both businesses consumers to confusion in an often crowded and bewildering marketplace and increased criminal activities over the internet, including data breach, hacking and phishing. These sophisticated criminal activities cause reputational damage to businesses as internet users lose consumer confidence and trust with the businesses targeted by such criminal activities. The .trading gTLD will facilitate greater trust and assurance from internet users, potentially offering trading services and reliable educational content relating to financial trading in a secure online environment provided by IG Group, whilst still allowing convenient and efficient interaction. 

IG Group’s mission and purpose of the proposed new gTLD share ICANN’s initiatives to promote public interest. IG Group is committed to contribute towards achieving such initiatives in line with ICANN’s Affirmation of Commitments, which includes:

 - consumer trust: the .trading gTLD registry will be operated in a centralised manner with a restrictive registration policy. Registration of domain names will only be available to IG Group and its affiliate entities, at this stage, which will provide added consumer reassurance that .trading domain names are trustworthy, offering consumer confidence in service delivery via a trusted provider in the market. As .trading domain names are subject to registration standards, policies and procedures under IG Group’s control, this eliminates the possibility of malicious conduct within the .trading domain space;

 - competition: the proposed new gTLD is not directly intended to instigate competition and consumer choice at the level of registration of domain names. Instead it is anticipated to contribute to ICANN’s initiatives to promote public interest through its operation focused on promoting consumer trust. Increased trust in .trading gTLD will drive existing and new top level domain (TLD) registry operators to make improvements in mechanisms to improve consumer trust of their TLDs; and

 - consumer choice: the proposed new gTLD will enable user-driven improvements and innovations assisting IG Group’s efforts to inform consumers on safe and secure trading through its ability to create new second and third level domain names on demand. These names will provide the consumers with more informed choices for trading and interacting with IG Group as well as providing an opportunity to IG Group to communicate with customers on a more personal level through intuitive and user friendly domain names. As IG Group has effective control over the registration and use of domain names under .trading domain space, this will also contribute towards general service innovations on the internet as a new outlet for improved services.


Given the restricted nature of the .trading gTLD, the projected number of registration is likely to be limited. It is anticipated that only about 5 – 15 domain names will be registered in the first few years. However, over the next few years, the number of registrations is likely to increase as IG Group develops and implements new services and marketing campaigns. 

As the new .trading gTLD expands and evolves, IG Group may consider offering the use of second level domain names to its core customers to login and use IG Group’s trading tools and trading platforms to trade in a secure environment at a later date. In this endeavour, IG Group will continue to comply with all operational, technical and policy requirements, as well as maintaining consumer trust and the stability of the internet. IG Group will keep ICANN reasonably informed of any material developments relating to .trading gTLD including compliance with the continued operations instrument obligations as set out in Specification 8 of the Registry Agreement.

IG Group intends to create relevant domain names for use including brand, services and sub types in the second or third level domain names. In accordance with registration policies and the proposed measures for protection of geographic names as outlined in response to Question 22, IG Group will possibly use geographic names to localise its websites in the countries in which it operates (currently 15 countries). The use of geographic names is intended to:

 - connect internet users with relevant information as applicable to the territory; and

 - comply with required rules and regulations in the national territory.


Further, IG Group has existing domain names containing the word “trading” in the following spaces:

 - gTLDs: cfdtradingguide.com, ebinaryoptionstrading.com, 

 - ccTLDs: igcommoditytrading.com.au, igforextrading.com.au, igindextrading.com.au


IG Group believes that the .trading gTLD is unlikely to cause confusion with either a generic term or any existing TLDs. IG Group has used the term “trading” in conjunction with its core business for over 35 years since its establishment. IG Group is a global leader in online financial derivatives trading with significant reputation in the financial industry. 

18(B)I. WHAT IS THE GOAL OF YOUR PROPOSED gTLD IN TERMS OF AREAS OF SPECIALTY, SERVICE LEVELS OR REPUTATION?

The key goals of the proposed new .trading gTLD are in line with ICANN’s Affirmation of Commitments: to promote consumer trust, competition and consumer choice. IG Group also seeks to foster and further strengthen its reputation as pioneer of secure online financial derivatives trading and provide an authoritative internet space through which IG Group is able to communicate with its customers directly and effectively and inform potential customers concerning its online trading options. The ability to create domain names on demand related to specific marketing, specialty service and product development supports these goals. Strengthened security measures, service levels and more effective functionality will provide a trusted and positive user experience.


18(B)II. WHAT DO YOU ANTICIPATE YOUR PROPOSED gTLD WILL ADD TO THE CURRENT SPACE, IN TERMS OF COMPETITION, DIFFERENTIATION, OR INNOVATION?

It is anticipated that the proposed .trading gTLD will make positive contributions to the wider internet community by providing:


DIFFERENTIATION (INCREASED TRUST):

The .trading gTLD will simplify how internet users trade and interact with IG Group as a viable and secure provider of financial derivatives by providing a distinctive domain space. Internet users will be able to directly navigate to .trading gTLD site, saving time and resources searching for an official IG Group site offering online trading in financial derivatives. The current domain name system has shown that it is vulnerable to malicious abuses due to registration of domain names which seek to exploit consumer confusion and offer fraudulent trading opportunities. IG Group can address some of these vulnerabilities by maintaining complete control over the domain names registered under the .trading domain space thus assuring customers that the offered trading options are secure and reliable. Together with consumer trust, internet users will be able to rely on the authoritativeness of the domain names under .trading domain space, which will differentiate interaction between internet users and IG Group.


COMPETITION: 

The differentiation of .trading gTLD as a trusted site for trading in financial derivatives via IG Group will drive existing and new TLD registry operators to make improvements in mechanisms to improve consumer trust of their TLDs. Internets users will be encouraged to interact with domain names under .trading domain space. As a result, .trading will have a flow on effect to enable increased competition. Therefore, the benefits of the proposed .trading will be distributed not only to its direct customers, but to the internet community at large forcing improved services and competitive pricing in the market place.


INNOVATION:

With the expansion of the internet community, the existing TLD structure presents limitations, not only in the availability of domain names for registrants, but also to businesses offering an online product to meet their evolving business needs. It is often difficult to register a domain name in existing domain space due to unavailability of the desired name. This problem is amplified for organisations like IG Group who work across many different jurisdictions and geographical markets. Even when the desired domain name is available, it may come with a high price tag associated with a purchase of such desired name from a third party. IG Group has the ability to create second or third level domain names including the use of geographic names which are relevant to its customer base and will enhance effective trading in financial derivatives. Domain names under the .trading gTLD will provide a business developme topportunity for IG Group to communicate with its customer base by presenting reliable information in a timely and user friendly manner through the use of easy to remember domain names. IG Group will be able to combine its use of the domain space with innovative user focused information and services to address the currently unmet needs in the existing domain name system providing greater consumer choice and security.


18(B)III. WHAT GOALS DOES YOUR PROPOSED gTLD HAVE IN TERMS OF USER EXPERIENCE?
The proposed .trading will provide a positive user experience, which meets the changing and growing needs of the global internet community. IG Group will maintain control in the registration and use of domain names and will ensure that the new gTLD will only be used for purposes authorised by IG Group. Therefore, .trading gTLD will:

 - provide an easy, secure and intuitive reference and access point for internet users;

 - represent authenticity thus promoting user confidence;

 - direct internet users to transparent and relevant information in a timely manner by creating short domain names on demand;

 - use geographic names to localise its websites to connect with internet users in the relevant regions and to comply with local laws;

 - enhance security and minimise security risks by implementing necessary technical and policy measures; 

 - strengthen category knowledge and user confidence by eliminating user confusion; and

 - prevent potential abuses in the registration process reducing overall costs to businesses and users.


.trading should address the concerns that the current domain name system is open to potential malicious abuse and user confusion in the registration processes. Although the current system allows an eligible party to lodge a claim through existing Uniform Domain Name Dispute Resolution Policy (UDRP) or other dispute resolution processes, the .trading gTLD will reduce potential abuses in the registration processes and overall costs to internet users. User confidence in the domain name system will be strengthened, which will ultimately contribute towards promoting ICANN’s core values in benefiting the public interest.


18(B)IV. PROVIDE A COMPLETE DESCRIPTION OF THE APPLICANTʹS INTENDED REGISTRATION POLICIES IN SUPPORT OF THE GOALS LISTED ABOVE.

The proposed registration policy is attached in response to Question 28.

Only affiliate entities of IG Group will be eligible to register domain names in .trading at this stage. The domain name registration processes will address the requirements mandated by ICANN, including rights abuse prevention measures. As the use of the .trading gTLD expands and evolves, IG Group may consider expanding the use of .trading gTLD’s at a later date. Such expansion processes will comply with all policy, operational and technical requirements and will adhere to applicable measures to protect customer trust and the stability of the internet. 


18(B)V. WILL YOUR PROPOSED gTLD IMPOSE ANY MEASURES FOR PROTECTING THE PRIVACY OR CONFIDENTIAL INFORMATION OF REGISTRANTS OR USERS? IF SO, PLEASE DESCRIBE ANY SUCH MEASURES.

IG Group is committed to protection of privacy and confidential information in accordance with its objective of increasing consumer trust and providing a safe and legitimate internet space for internet users. Privacy and confidential information will be protected in accordance with all applicable laws and regulations relating to internet security, privacy and user’s confidential information, including the Data Protection Act 1998 (UK). IG Group complies with all relevant requirements and standards for the trading (in financial derivatives) industry including the Directive 2006⁄73⁄EC (EC) for compliance with Markets in Financial Instruments Directive (MiFID) and all applicable regulations and requirements goverened by the Financial Service Authority (UK) as the regulator of the financial services industry in the UK. 

IG Group has also implemented its own privacy policy to demonstrate its commitment to the protection of user privacy and confidential information. The IG Group Privacy Policy is available on its website and contains provisions reflecting IG Group’s respect for confidential information and personal privacy. IG Group’s privacy policy includes provisions regarding:

 - collection of information;

 - use and disclosure of information;

 - storage of information collected;

 - access to information help by IG Group.


Privacy is of fundamental concern to most of IG Group’s customers as the interaction between IG Group and its customers may involve transaction of large sums of money. As such IG Group has a strong interest in ensuring a high level of privacy protection for its customers. 

As the .trading gTLD will only be available to affiliate entities of IG Group, initially, the amount of personal data that will be collected for the purposes of operating the gTLD and made publicly available in the WHOIS database will be very limited. IG Group will provide a publicly available and searchable WHOIS look up facility, where information about the domain name status, registrant information including administrative and technical contact details can be found in accordance with Specification 4 of the Registry Agreement. In order to prevent misuse of the WHOIS look up facility, IG Group will utilise measures including a requirement where any person submitting a WHOIS database query is required to read and agree to the terms and conditions in accordance with the registration policy. This will include the terms of use that the WHOIS database is provided for information purposes only and that the user agrees not to use the information for any other purposes such as allowing or enabling the transmission of unsolicited commercial advertising or other communication. 

IG Group will deploy Domain Name System Security Extensions (DNSSEC) which is intended to benefit both IG Group and its users interacting with IG Group online. DNSSEC provides additional security by validating information in the transmission, therefore it is intended to benefit those who publish information in the domain name system (DNS) and the users who retrieve information from the new .trading gTLD. IG Group already implements measures to protect privacy or confidential information of its users against misuse, loss, alteration and unauthorised access. Such measures include a combination of secure computer storage facilities and paper-based files and other records.

IG Group will continue to apply all security measures currently implemented and will comply with all other policies and practices required by ICANN in the Registry Agreement and any relevant Consensus Policy for protecting the privacy and confidential information of registrants and users in the new .trading domain space. 


18(B)VI. DESCRIBE WHETHER AND IN WHAT WAYS OUTREACH AND COMMUNICATIONS WILL HELP TO ACHIEVE YOUR PROJECTED BENEFITS.
The proposed new gTLD will be publicised by a media plan to promote recognition of the new gTLD within the internet community to be a trusted site and as a sign of authenticity. 

During the initial stage of the operation of the proposed new gTLD, it is anticipated that internet users will be re-directed to current websites. However, over time, it is foreseen that communication to the internet community of the existence of the proposed new gTLD and encouragement to utilise the trusted site will contribute towards minimising malicious abuses and protecting internet users. 

As a restricted gTLD, registration will only be open to internal users (affiliate entities) at this stage and no third parties will be able to register domain names under .trading domain space. Therefore, it is not anticipated that third parties will incur costs in relation to the .trading gTLD. The affiliate entities wishing to register domain names must ensure that all the policy requirements for registration are satisfied. 

No unaffiliated third party will be permitted to register domain names at this stage. It is estimated that time and money spent by consumers who have been targeted by malicious abuse in utilising trading platforms on the internet will reduce over time as a result of the new, trusted .trading gTLD.


18(C)I. HOW WILL MULTIPLE APPLICATIONS FOR A PARTICULAR DOMAIN NAME BE RESOLVED, FOR EXAMPLE, BY AUCTION OR ON A FIRST-COME⁄FIRST-SERVE BASIS?

The initial use of the proposed new gTLD will be restricted to internal business use and IG Group and affiliate entities are intended to be the registrants under the .trading gTLD. Therefore conflicts between multiple applications are not anticipated to occur.


18(C)II. EXPLAIN ANY COST BENEFITS FOR REGISTRANTS YOU INTEND TO IMPLEMENT (E.G., ADVANTAGEOUS PRICING, INTRODUCTORY DISCOUNTS, BULK REGISTRATION DISCOUNTS).

This gTLD will be used for internal purposes only, at this stage, so pricing incentives are not applicable or relevant.


18(C)III. NOTE THAT THE REGISTRY AGREEMENT REQUIRES THAT REGISTRARS BE OFFERED THE OPTION TO OBTAIN INITIAL DOMAIN NAME REGISTRATIONS FOR PERIODS OF ONE TO TEN YEARS AT THE DISCRETION OF THE REGISTRAR, BUT NO GREATER THAN TEN YEARS. ADDITIONALLY, THE REGISTRY AGREEMENT REQUIRES ADVANCE WRITTEN NOTICE OF PRICE INCREASES. DO YOU INTEND TO MAKE CONTRACTUAL COMMITMENTS TO REGISTRANTS REGARDING THE MAGNITUDE OF PRICE ESCALATION? IF SO, PLEASE DESCRIBE YOUR PLAN.

This gTLD will be used for internal purposes only, at this stage, so pricing incentives or pricing increases are not applicable or relevant as no additional fees are to be charged.

No

Not Available

No

IG Group Holdings PLC is not currently planning to utilise geographic names at the second and other levels in the applied-for gTLD. However, and notwithstanding the absence of geographic names in IG Group Holdings PLC’s forward planning and use intentions, IG Group Holdings PLC has considered the requirements necessary should it, at a later date, seek to obtain ICANN approval for the use of geographic names as follows:


REGISTRY AGREEMENT - SPECIFICATION 5 CRITERIA 

§2 The reservation of two-character label string may be released to the extent that Registry Operator reaches agreement with the government and the country-code manager. The Registry Operator may also propose release of these reservations based on its implementation of measures to avoid confusion with the corresponding country names. 

§5 the reservation of specific country and territory names may be released to the extent that the Registry Operator reaches agreement with the applicable government(s), provided, further, that Registry Operator may also propose release of these reservations, subject to review by ICANN’s Governmental Advisory Committee and approval by ICANN. 


DRAFT RESPONSE FOR .TRADING TLD (2011-11-18)

IG Group Holdings PLC generally respects and abides by the GAC’s Principles regarding New gTLDs, dated March 28, 2007. In order to comply with the requirements of the Registry Agreement, Specification 5, all Two-character labels (§2) and Country and Territory Names (§5) will be initially reserved. 

However, IG Group Holdings PLC believes that the use of geographic terms can provide great benefit and simplicity to internet users because these terms are intuitive ways to resolve to content that may be specifically relevant and targeted to users in the particular geographic region or users with an interest in the particular geographic region. IG Group Holdings PLC intends to use any Two-character label and⁄or Country or Territory Name domains, and to participate in or implement a process by which any Government may reasonably object to that use. IG Group Holdings PLC envisions a number of possible scenarios for ensuring Government agreement to the use of Country and Territory names. These will be explored in detail with ICANN and the Governmental Advisory Committee to ensure a mutually agreeable solution. Scenarios range from at a minimum; IG Group Holdings PLC informing the Chair of the Governmental Advisory Committee (GAC) to ICANN in writing of its proposed use of geographic terms and provide Governments who wish to do so with an opportunity to block the use of their relevant name in the .trading TLD. Other plausible scenarios would include; 


SCENARIO 1 (LETTER TO GAC)

In advance of any use of geographical names IG Group Holdings PLC will send a letter to the chair of the Governmental Advisory Committee (GAC) informing the GAC of its intention to use geographical names in the .trading TLD. The letter will outline the reasons for using geographical names and provide Governments with the opportunity to contact IG Group Holdings PLC within 90 days to reserve their respective geographical name from use in the TLD. Should a Government inform IG Group Holdings PLC that it wishes to reserve the use of their respective geographical name, the name will remain reserved for the duration of IG Group Holdings PLC’s registry agreement with ICANN. The opportunity to reserve a name will be offered to Governments free of charge. 


SCENARIO 2 (LETTER INFORMING INDIVIDUAL GOVERNMENTS)

In advance of any use of geographical names IG Group Holdings PLC will send a letter to the Government concerned and inform it of IG Group Holdings PLC’s intention to use geographical names in the .trading TLD. The letter will outline the reasons for using geographical names and provide the Government with the opportunity to contact IG Group Holdings PLC within 90 days to reserve its respective geographical name from use in the TLD. Should the Government inform IG Group Holdings PLC that it wishes to reserve the use of its respective geographical name, the name will remain reserved for the duration of IG Group Holdings PLC’s registry agreement with ICANN. The opportunity to reserve a name will be offered to the Government free of charge.


SCENARIO 3 (LETTER REQUESTING PERMISSION FROM INDIVIDUAL GOVERNMENT)

In advance of any use of geographical names IG Group Holdings PLC will send a letter to the Government concerned and inform it of IG Group Holdings PLC’s intention to use geographical names in the .trading TLD. The letter will outline the reasons for using geographical names and request the Government’s approval or non-objection to the proposed use of the geographical name. Should the Government not respond to the IG Group Holdings PLC within 90 days, IG Group Holdings PLC will understand this to mean that the Government does not object to IG Group Holdings PLC’s proposed use of the geographical name. However should the Government at a later stage contact IG Group Holdings PLC and request that the geographical name no longer be used, IG Group Holdings PLC will work in good faith with the Government to try to find a mutually agreeable solution. 

Alternatively, however, should the Government at a later stage contact IG Group Holdings PLC and request that the geographical name no longer be used, IG Group Holdings PLC will work in good faith with the Government to try to find a mutually agreeable solution. If such a solution cannot be found IG Group Holdings PLC will respect the Government’s wishes and reserve the name from use without cost to the Government concerned. 

IG Group Holdings PLC will not use geographic names until ICANN has approved such use.

23 REGISTRY SERVICES


1 CUSTOMARY REGISTRY SERVICES

IG Group Holdings plc (IG Group) has engaged Melbourne IT Limited and its affiliate entities (Melbourne IT) as a service provider to assist IG Group with this application and on-going management of its .trading gTLD, should this application be successful.  Melbourne IT’s managed services incorporate the management and oversight of IG Group’s selected backend registry services provider, Verisign Inc (Verisign), as well as other third party service providers.

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

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

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

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

Registry services defined by this application are not intended to be offered in a manner unique to the new generic top-level domain (gTLD) nor are any proposed services unique to this application’s registry. 

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



1.1 CRITICAL OPERATIONS OF THE REGISTRY 


i. RECEIPT OF DATA FROM REGISTRARS CONCERNING REGISTRATION OF DOMAIN NAMES AND NAME SERVERS 

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



ii. PROVISION TO REGISTRARS STATUS INFORMATION RELATING TO THE ZONE SERVERS

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



iii. DISSEMINATION OF TLD ZONE FILES

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



iv. OPERATION OF THE REGISTRY ZONE SERVERS

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



v. DISSEMINATION OF CONTACT AND OTHER INFORMATION CONCERNING DOMAIN NAME SERVER REGISTRATIONS

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



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

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



2.1 INTER-REGISTRAR TRANSFER POLICY (IRTP)


TECHNICAL COMPONENT: 

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

 - Allows the losing registrar to proactively ‘ACK’ or acknowledge a transfer prior to the expiration of the five-day Transfer grace period

 - Allows the losing registrar to proactively ‘NACK’ or not acknowledge a transfer prior to the expiration of the five-day Transfer grace period 

 - Allows the system to automatically ACK the transfer request once the five-day Transfer grace period has passed if the losing registrar has not proactively ACK’d or NACK’d the transfer request.



BUSINESS COMPONENT: 

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


SECURITY AND STABILITY CONCERNS: 

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


ICANN PRIOR APPROVAL: 

Verisign has been in compliance with the IRTP since November 2004 and is available to support IG Group in a consulting capacity as needed. 



UNIQUE TO THE TLD: 

This service is not provided in a manner unique to the .trading TLD.



2.2 ADD GRACE PERIOD (AGP) LIMITS POLICY


TECHNICAL COMPONENT: 

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

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



BUSINESS COMPONENT: 

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

 - During any given month, an operator may not offer any refund to an ICANN-accredited registrar for any domain names deleted during the AGP that exceed (i) 10% of that registrarʹs net new registrations (calculated as the total number of net adds of one-year through ten-year registrations as defined in the monthly reporting requirement of Operator Agreements) in that month, or (ii) fifty (50) domain names, whichever is greater, unless an exemption has been granted by an operator. 

 - Upon the documented demonstration of extraordinary circumstances, a registrar may seek from an operator an exemption from such restrictions in a specific month. The registrar must confirm in writing to the operator how, at the time the names were deleted, these extraordinary circumstances were not known, reasonably could not have been known, and were outside the registrarʹs control. Acceptance of any exemption will be at the sole and reasonable discretion of the operator; however ʺextraordinary circumstancesʺ that reoccur regularly for the same registrar will not be deemed extraordinary. 

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



SECURITY AND STABILITY CONCERNS: 

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



ICANN PRIOR APPROVAL: 

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



UNIQUE TO THE TLD: 

This service is not provided in a manner unique to the .trading TLD.



2.3 REGISTRY SERVICES EVALUATION POLICY (RSEP)


TECHNICAL COMPONENT: 

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



BUSINESS COMPONENT: 

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



SECURITY AND STABILITY CONCERNS: 

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



ICANN PRIOR APPROVAL: 

Not applicable.



UNIQUE TO THE TLD: 

gTLD RSEP procedures are not implemented in a manner unique to the .trading TLD.



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

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

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



3.1 TWO-FACTOR AUTHENTICATION SERVICE


TECHNICAL COMPONENT: 

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

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



BUSINESS COMPONENT: 

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



SECURITY AND STABILITY CONCERNS: 

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



ICANN PRIOR APPROVAL: 

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



UNIQUE TO THE TLD: 

This service is not provided in a manner unique to the .trading TLD.

24 SHARED REGISTRATION SYSTEM (SRS) PERFORMANCE


1 ROBUST PLAN FOR OPERATING A RELIABLE SRS


1.1 HIGH-LEVEL SHARED REGISTRATION SYSTEM (SRS) SYSTEM DESCRIPTION

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


The SRS components include:

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

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

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


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


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

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

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

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

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


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

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

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

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



SCALABILITY AND PERFORMANCE. 

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

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



1.2 REPRESENTATIVE NETWORK DIAGRAMS

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



1.3 NUMBER OF SERVERS

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

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

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

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



1.4 DESCRIPTION OF INTERCONNECTIVITY WITH OTHER REGISTRY SYSTEMS

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



1.5 FREQUENCY OF SYNCHRONIZATION BETWEEN SERVERS

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



1.6 SYNCHRONIZATION SCHEME

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



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

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

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



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

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

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

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

 - Application Engineers: 19

 - Database Administrators: 8
 
 - Database Engineers: 3

 - Network Administrators: 11 

 - Network Architects: 4 

 - Project Managers: 25

 - Quality Assurance Engineers: 11 

 - SRS System Administrators: 13 
 
 - Storage Administrators: 4

 - Systems Architects: 9


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

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



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


SECTION 1.2 (EPP) OF SPECIFICATION 6, REGISTRY INTEROPERABILITY AND CONTINUITY SPECIFICATIONS.

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



SPECIFICATION 10, EPP REGISTRY PERFORMANCE SPECIFICATIONS. 

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

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

 - EPP service availability: ≤ 864 minutes of downtime (≈98%)

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

 - EPP query-command RTT: ≤2000 ms, for at least 90 percent of the commands

 - EPP transform-command RTT: ≤4000 ms, for at least 90 percent of the commands

25 EXTENSIBLE PROVISIONING PROTOCOL (EPP)


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

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

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

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

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



1.1 EPP INTERFACE WITH REGISTRARS

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

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



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

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

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



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

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

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

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

 - Application Engineers: 19 

 - Database Engineers: 3 

 - Quality Assurance Engineers: 11 

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

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



4 ABILITY TO COMPLY WITH RELEVANT RFCS 

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

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

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

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

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

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

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

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

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



5 PROPRIETARY EPP EXTENSIONS

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

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

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

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

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

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

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

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



5.1 EPP TEMPLATES AND SCHEMAS

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




XML TEMPLATES⁄SCHEMA FOR IDNLANG-1.0

 - Template: The templates for idnLang-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄idn-language-tag.pdf. 

 - Schema is set out in Figure 25-2
This schema describes the extension mapping for the IDN language tag. The mapping extends the EPP domain name mapping to provide additional features required for the provisioning of IDN domain name registrations.




XML TEMPLATES⁄SCHEMA FOR RGP-POLL-1.0

 - Template: The templates for rgp-poll-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄rgp-poll-mapping.pdf.

 - Schema is set out in Figure 25-3: 
This schema describes the extension mapping for poll notifications. The mapping extends the EPP base mapping to provide additional features for registry grace period (RGP) poll notifications.




XML TEMPLATES⁄SCHEMA FOR WHOISINF-1.0

 - Template: The templates for whoisInf-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄whois-info-extension.pdf.

 - Schema is set out in Figure 25-4: 
This schema describes the extension mapping for the Whois Info extension. The mapping extends the EPP domain name mapping to provide additional features for returning additional information needed for transfers.




XML TEMPLATES⁄SCHEMA FOR SYNC-1.0 (CONSOLIDATE)

 - Template: The templates for sync-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄consolidate-mapping.txt.

 - Schema is set out in Figure 25-5: 
This schema describes the extension mapping for the synchronization of domain name registration period expiration dates. This service is known as ʺConsoliDate.ʺ The mapping extends the EPP domain name mapping to provide features that allow a protocol client to end a domain name registration period on a specific month and day.




XML TEMPLATES⁄SCHEMA FOR NAMESTOREEXT-1.1

 - Template: The templates for namestoreExt-1.1 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄namestore-extension.pdf.

 - Schema is set out in Figure 25-6: 
This schema describes the extension mapping for the routing with an EPP intelligent gateway to a pluggable set of backend products and services. The mapping extends the EPP domain name and host mapping to provide a sub-product identifier to identify the target sub-product that the EPP operation is intended for.




XML TEMPLATES⁄SCHEMA FOR LOWBALANCE-POLL-1.0

 - Template: The templates for lowbalance-poll-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄low-balance-mapping.pdf.

 - Schema is set out in Figure 25-7: 
This schema describes the extension mapping for the account low balance notification. The mapping extends the EPP base mapping so an account holder can be notified via EPP poll messages whenever the available credit for an account reaches or goes below the credit threshold.




6 PROPRIETARY EPP EXTENSION CONSISTENCY WITH REGISTRATION LIFECYCLE 

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

26 WHOIS


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

Verisign, IG Group’s selected backend registry services provider, has operated the Whois lookup service for the gTLDs and ccTLDs it manages since 1991, and will provide these proven services for the .trading gTLD registry. In addition, it continues to work with the Internet community to improve the utility of Whois data, while thwarting its application for abusive uses.



1.1 HIGH-LEVEL WHOIS SYSTEM DESCRIPTION

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

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

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

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

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

Verisign currently operates both thin and thick Whois systems. 

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



PROVIDED FUNCTIONALITIES FOR USER INTERFACE

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

 - For domain name: whois EXAMPLE.TLD

 - For registrar: whois ʺregistrar Example Registrar, Inc.ʺ

 - For name server: whois ʺNS1.EXAMPLE.TLDʺ or whois ʺname server (IP address)ʺ

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

 - Go to http:⁄⁄whois.nic.〈TLD〉

 - Click on the appropriate button (Domain, Registrar, or Name Server)

 - Enter the applicable parameter:

 - Domain name, including the TLD (e.g., EXAMPLE.TLD)

 - Full name of the registrar, including punctuation (e.g., Example Registrar, Inc.)

 - Full host name or the IP address (e.g., NS1.EXAMPLE.TLD or 198.41.3.39)

 - Click on the Submit button.



PROVISIONS TO ENSURE THAT ACCESS IS LIMITED TO LEGITIMATE AUTHORIZED USERS AND IS IN COMPLIANCE WITH APPLICABLE PRIVACY LAWS OR POLICIES

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

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



1.2 RELEVANT NETWORK DIAGRAMS

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



1.3 IT AND INFRASTRUCTURE RESOURCES

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



1.4 DESCRIPTION OF INTERCONNECTIVITY WITH OTHER REGISTRY SYSTEMS

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


1.5 FREQUENCY OF SYNCHRONIZATION BETWEEN SERVERS

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



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

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

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



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

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

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

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

 - Application Engineers: 19

 - Database Engineers: 3

 - Quality Assurance Engineers: 11

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

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



4 COMPLIANCE WITH RELEVANT RFC

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



5 COMPLIANCE WITH SPECIFICATIONS 4 AND 10 OF REGISTRY AGREEMENT

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

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

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



BULK ACCESS MODE. 

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

The data is provided in three files:

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

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



LOOKUP MODE. 

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



5.1 SPECIFICATION 10, RDDS REGISTRY PERFORMANCE SPECIFICATIONS

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

In accordance with RDDS registry performance specifications detailed in Specification 10, Verisignʹs Whois service meets the following proven performance attributes:
 - RDDS availability: less than or equal to 864 min of downtime (is approximately equal to 98%)

 - RDDS query RTT: less than or equal to 2000 ms, for at least 95% of the queries

 - RDDS update time: less than or equal to 60 min, for at least 95% of the probes



6 SEARCHABLE WHOIS

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


Features of the Verisign searchable Whois function include:

 - Provision of a web-based searchable directory service

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

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

 - Ability to perform Boolean search supporting, at least, the following logical operators to join a set of search criteria: AND, OR, NOT
 
 - Search results that include domain names that match the selected search criteria

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

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

 - Account access is granted by the IG Group’s defined .trading gTLD admin user.



POTENTIAL FORMS OF ABUSE AND RELATED RISK MITIGATION. 

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

27 REGISTRATION LIFECYCLE


1 COMPLETE KNOWLEDGE AND UNDERSTANDING OF REGISTRATION LIFECYCLES AND STATES

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



1.1 REGISTRATION LIFECYCLE OF CREATE⁄UPDATE⁄DELETE

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



CREATE PROCESS.

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



PROCESS CHARACTERIZATION. 

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


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

 - A domain name that meets the string restrictions.

 - A domain name that does not already exist.

 - The registrar is authorized to create a domain name in .trading.

 - The registrar has available credit.

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

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

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

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



RENEWAL PROCESS. 

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

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

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



PROCESS CHARACTERIZATION. 

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


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

 - A domain name that exists and is sponsored by the requesting registrar.

 - The registrar is authorized to renew a domain name in .trading.

 - The registrar has available credit.

 - The passed current expiration date matches the domain name’s expiration date.

 - A period in units of years with a maximum value of 10 (default period is one year). A domain name expiry past ten years is not allowed.



REGISTRAR TRANSFER PROCEDURES. 

A registrant may transfer his⁄her domain name from his⁄her current registrar to another registrar. The database system allows a transfer as long as the transfer is not within the initial 60 days, per industry standard, of the original registration date. 
The registrar transfer process goes through many process states, which are described in detail below, unless it has any form of Pending Delete, Pending Transfer, or Transfer Prohibited.
A transfer can only be initiated when the appropriate Auth-Info is supplied. The Auth-Info for transfer is only available to the current registrar. Any other registrar requesting to initiate a transfer on behalf of a registrant must obtain the Auth-Info from the registrant.

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

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

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


The domain name transfer consists of five separate operations:

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

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

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

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

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

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



DELETE PROCESS. 

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



PROCESS CHARACTERIZATION. 

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

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

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



UPDATE PROCESS.

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

 - Auth-Info

 - Name servers

 - Contacts (i.e., registrant, administrative contact, technical contact, and billing contact)

 - Statuses (e.g., Client Delete Prohibited, Client Hold, Client Renew Prohibited, Client Transfer Prohibited, Client Update Prohibited)



PROCESS CHARACTERIZATION. 

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

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


1.2 PENDING, LOCKED, EXPIRED, AND TRANSFERRED 

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



DELETE GRACE PERIOD. 

After the five-day Pending Delete grace period expires, the domain name enters the Redemption Pending state and then is deleted by the system. The registrant can restore the domain name at any time during the Redemption Pending state.

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

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

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

 - clientHold

 - clientRenewProhibited

 - clientTransferProhibited

 - clientUpdateProhibited

 - clientDeleteProhibited

 - serverHold

 - serverRenewProhibited

 - serverTransferProhibited

 - serverUpdateProhibited

 - serverDeleteProhibited 



1.3 ADD GRACE PERIOD, REDEMPTION GRACE PERIOD, AND NOTICE PERIODS FOR RENEWALS OR TRANSFERS

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

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

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

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

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



1.4 ASPECTS OF THE REGISTRATION LIFECYCLE NOT COVERED BY STANDARD EPP RFCS

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



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

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

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



3 COMPLIANCE WITH RELEVANT RFCS

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


In addition, in accordance with RFCs 5732 and 5733, the Verisign registration system enforces the following domain name registration constraints:
 - Uniqueness⁄Multiplicity: A second-level domain name is unique in the .trading database. Two identical second-level domain names cannot simultaneously exist in .trading. Further, a second-level domain name cannot be created if it conflicts with a reserved domain name.

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

 - Registrant

 - Administrative contact

 - Technical contact

 - Billing contact

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

 - A maximum of 13 hosts, which are created and managed independently according to RFC 5732

 - An Auth-Info, which is used to authorize certain operations on the object

 - Status(es), which are used to describe the domain name’s status in the registry

 - A created date, updated date, and expiry date



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

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

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

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

 - Application Engineers: 19 

 - Customer Support Personnel: 36 

 - Database Administrators: 8 

 - Database Engineers: 3 

 - Quality Assurance Engineers: 11 

 - SRS System Administrators: 13 

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

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

A. ABUSE PREVENTION AND MITIGATION TO BE IMPLEMENTED BY IG GROUP


IG Group’s proposed use for .trading should, by its very nature, preclude abusive registrations from occurring, as all domains names may only be registered in the name of IG Group and its affiliates (for the purposes of this response, “affiliates” means in relation to a party any corporation or other business entity controlling, controlled by, or under common control of that party and for the purposes of this definition, a corporation or other business entity shall be deemed to control another corporation or business entity if it owns directly or indirectly (i) fifty percent (50%) or more of the voting securities or voting interest in any such corporation or other entity; or (ii) fifty percent (50%) or more of the interest in the profit or income in the case of a business entity other than a corporation; or (iii) in the case of a partnership, any other compatible interest equal to at least a fifty percent (50%) share in the general partner).

IG Group is intending to operate .trading for the benefit of Internet users that have an interest in finding information on products and services related to .trading. There is no incentive for IG Group to confuse Internet users, nor otherwise use domain names in bad faith since IG Group intends to utilize the .trading to benefit internet users by ensuring increased trust, user confidence and utility allowing for better product knowledge and the elimination of user confusion. Furthermore it will be well known that the IG Group is the corporate entity behind the .trading and IG Group wishes to avoid negative press or loss of goodwill.

Notwithstanding the above, IG Group understands and agrees that it must comply with the different rights protection mechanisms such as the Uniform Domain Name Dispute Resolution Policy (UDRP) and the Uniform Rapid Suspension System (URS) as described in the gTLD Applicant Guidebook (as may be later amended via Consensus Policy) and the Registry Agreement. The aforementioned policies provide a strong incentive to ensure that relevant and effective checks are in place to ensure that all .trading domain names are only registered and used in an appropriate manner so as to benefit Internet users rather than in any manner that may be deemed inappropriate or in bad faith. 

IG Group will implement a clear written policy which requires the relevant corporate authorization and approvals to be procured and evidenced in order for any .trading domain name to be registered for IG Group’s use. In the event that IG Group resolves to permit third parties (other than affiliates) that have a relationship with either IG Group or its business, to register (or license) and use domain names within the top level domain (TLD), then additional corporate authorizations and approvals may be required to ensure internal responsibility for permitting and enforcing the terms of use of the .trading domain. In addition to these safeguards, all registered domain names in the TLD will be regularly monitored for abusive use.


B. .trading ANTI-ABUSE POLICIES

Although domain names will only be registered to IG Group and its affiliates, all domain names will be subject to specific internal registration policy for .trading domain. The registration policy will set out in writing a methodology for corporate authorization, approval and evidence in order for any domain name to be registered for IG Group’s use. This will prohibit any abusive use of a domain name. These policies include not only the required URS, but also the supplemental Anti-Phishing Takedown Process, IG Group’s Acceptable Use Policy, and IG Group’s strict controls on registration. 


C. DEFINITION OF ABUSE

IG Group defines abuse as an action that causes actual and substantial harm, or is a material predicate of such harm, and is illegal, illegitimate, or otherwise contrary to registration policy. Abuse includes, without limitation, the following: 

 - Content or actions that attempt to defraud members of the public in any way (for example, ʺphishingʺ sites);

 - Content that is hateful, defamatory, derogatory or bigoted based on racial, ethnic, political grounds or which otherwise may cause or incite injury, damage or harm of any kind to any person or entity;

 - Content that is threatening or invades another personʹs privacy or property rights or is otherwise in breach of any duty owed to a third party;

 - Content or actions that infringe the trademark, copyright, patent rights, trade secret or other intellectual property rights, or any other legal rights of IG Group or any third party;

 - Content or actions that violate any applicable local, state, national or international law or regulation;

 - Content or actions that promote, are involved in or assist in, the conduct of illegal activity of any kind or promote business opportunities or investments that are not permitted under applicable law;

 - Content that advertises or offers for sale any goods or services that are unlawful or in breach of any national or international law or regulation; or

 - Content or actions associated with the sale or distribution of prescription medication without a valid prescription;

 - Content that depicts minors engaged in any activity of a sexual nature or which may otherwise harm minors;

 - Activities that mislead or deceive minors into viewing sexually explicit material;

 - Spam: The use of electronic messaging systems to send unsolicited bulk messages. The term applies to e-mail spam and similar abuses such as instant messaging spam, mobile messaging spam, and the spamming of Web sites and Internet forums. An example, for purposes of illustration, would be the use of email in denial-of-service attacks;

 - Phishing: The use of counterfeit Web pages that are designed to trick recipients into divulging sensitive data such as usernames, passwords, or financial data;

 - Pharming: The redirecting of unknowing users to fraudulent sites or services, typically through Domain Name System (DNS) hijacking or poisoning;

 - Willful distribution of malware: The dissemination of software designed to infiltrate or damage a computer system without the ownerʹs informed consent.

 - Examples include, without limitation, computer viruses, worms, keyloggers, and trojan horses;

 - Botnet command and control: Services run on a domain namethat are used to control a collection of

 - illegally compromised computers or ʺzombies,ʺ or to direct denial-of-service attacks (DDoS attacks); and

 - Illegal Access to Other Computers or Networks: Illegally accessing computers, accounts, or networks belonging to another party, or attempting to penetrate security measures of another individualʹs system (often known as ʺhackingʺ). Also, any activity that might be used as a precursor to an attempted system penetration (e.g., port scan, stealth scan, or other information gathering activity).


As stated in response to Question 18, IG Group’s registration policy will address the minimum requirements mandated by ICANN including rights abuse prevention measures. IG Group will implement the following as means of abuse prevention and mitigation:


1) IG Group‘s draft registration policy ** see end of document 


2) IG Group’s draft procedure for management of trademark infringement claims *** see end of document 


Any employee found to have violated any of IG Group’s policies may be subject to disciplinary action, up to and including termination of employment.

Every IG Group employee should be aware that the data they create on the corporate systems, including on any domain name hosted in .trading, remains the property of IG Group. For security and network maintenance purposes, authorized individuals within IG Group may monitor equipment, systems and network traffic at any time. IG Group reserves the right to audit networks and systems on a periodic basis to ensure compliance with this policy.

IG Group recognizes that, notwithstanding all of IG Group’s internal policies having been meticulously followed by all employees and affiliates, the Internet remains an open and ubiquitous system that provides access and anonymity to participants around the world. This is one of the Internet’s strengths and also a source of difficulty as malicious or criminal perpetrators exploit these characteristics for their own benefit. The frequency of activities such as phishing, pharming, spam and DDoS attacks have increased dramatically on the Internet and there is strong evidence to suggest this will continue.

IG Group has resolved to ensure that abusive use of the .trading domain names will not be permitted nor tolerated. The nature of such abuses creates security and stability issues for IG Group, as well as for users of the Internet in general, and particularly those who wish to interact with IG Group in a secure and reliable manner. The nature of such abuses also inherently creates negative publicity and loss of goodwill and, therefore, any such abuse must be swiftly and effectively addressed, and systems must continue to evolve in accordance with evolving threats.


SCANNING TO IDENTIFY MALICIOUS OR ABUSIVE BEHAVIOR

IG Group currently invests in and utilizes third party anti-phishing and abuse solutions to monitor potentially malicious conduct over the Internet, against IG Group’s websites, brands and other online business areas. IG Group fully intends to continue its support and deployment of these solutions to monitor the .trading domain on an on-going basis. These solutions include:

 - All computer systems accessible through .trading shall be continually executing approved virus-scanning software with a current virus database, unless overridden by departmental or group policy for legitimate business reason; 

 - IG Group will conduct automated and regular scanning for malware of all computer systems accessible via domain names in the Registry through its selected back end Registry services provider, Verisign. Registrants are often unknowing victims of malware exploits. Verisign has developed proprietary code to help identify malware in the zones it manages, which in turn helps registrars by identifying malicious code hidden in their domain names. Verisign’s malware scanning service helps prevent websites from infecting other websites by scanning web pages for embedded malicious content that will infect visitors’ websites. Verisign’s malware scanning technology uses a combination of in-depth malware behavioral analysis, anti-virus results, detailed malware patterns, and network analysis to discover known exploits for the particular scanned zone. If malware is detected, the service sends the registrar a report that contains the number of malicious domains found and details about malicious content within its TLD zone
 . Reports with remediation instructions are provided to help registrars and registrants eliminate the identified malware from the registrant’s website; 

 - IG Group will establish and act upon the results of a regular poll against one or more trusted databases for phishing sites operating (in second level or subordinate domain names) within the TLD. Phishing activity most often occurs through a subordinate domain names, rather than a directly registered second level domain names. 


D. ADDITIONAL PROCESSES TO ADDRESS ABUSIVE USE OF REGISTERED DOMAIN NAMES


SUSPENSION PROCESSES CONDUCTED BY BACKEND REGISTRY SERVICES PROVIDER.

In the case of domain name abuse, IG Group or IG Group’s approved registrar(s) will determine whether to take down the subject domain name. Verisign, IG Group’s selected backend registry services provider, will follow the auditable processes to comply with the suspension request as set out Diagram 1 of the Attachment.


VERISIGN SUSPENSION NOTIFICATION.

IG Group or IG Group’s approved registrar(s) submits the suspension request to Verisign for processing, documented by:

 - Threat domain name

 - Registry incident number 

 - Incident narrative, threat analytics, screen shots to depict abuse, and⁄or other evidence

 - Threat classification 
 
 - Threat urgency description

 - Recommended timeframe for suspension⁄takedown 

 - Technical details (e.g., Whois records, IP addresses, hash values, anti-virus detection results⁄nomenclature, name servers, domain name status that are relevant to the suspension) 

 - Incident response, including surge capacity 


VERISIGN NOTIFICATION VERIFICATION

When Verisign receives a suspension request from IG Group or IG Group’s approved registrar(s), it performs the following verification procedures:

 - Validate that all the required data appears in the notification

 - Validate that the request for suspension is for a registered domain name

 - Return a case number for tracking purposes


SUSPENSION REJECTION

 - If required data is missing from the suspension request, or the domain name is not registered, the request will be rejected and returned to IG Group or IG Group’s approved registrar(s) with the following information:

 - Threat domain name

 - Registry incident number 

 - Verisign case number

 - Error reason


IG Group will notify the registrar of record in relation to a complaint. 


E. ABUSE POINT OF CONTACT AND PROCESS FOR ADDRESSING COMPLAINTS 

IG Group will act as the primary abuse point of contact for the gTLD. IG Group may use its third party registrar(s) or its selected back end registry services provider, Verisign, to perform some or all of the functions associated with handling inquiries relating to malicious conduct in the gTLD. Contact details (including at least a valid email and mailing address) for the abuse primary contact will be displayed prominently on IG Group’s main website. The primary contact will investigate and respond to all complaints and incidents within a reasonable time and be empowered to take effective action within well-defined written criteria to guide those actions. Action will be taken in line with what is set out in this answer and the registration policy for the .trading domain. Changes to contact details will be clearly and effectively communicated to ICANN and prominently displayed on IG Group’s website.

The above mentioned email address will be set up to receive complaints for any potential malicious conduct in the TLD. Furthermore, the email address will be routinely monitored over a 24 hour period, 365 days a year. Complainants will be provided with a written email response communication containing an auditable tracking or case number. IG Group will investigate all reasonable complaints and take any reasonably necessary and appropriate action. Verified law enforcement requests will be addressed in no more than twenty-four hours from verified receipt. All other requests will be addressed in no more than seventy-two hours from receipt. 

Abuse complaint metrics will be tracked, and adequate resources will be expended to ensure appropriate trending of those metrics by providing the abuse point of contact with sufficient resources. The complaint metrics will be gathered by the registrar(s) and regularly forwarded to IG Group for the purposes of identifying gaps in the Registry’s current policies and areas of improvement. Given IG Group’s belief that infrastructure protection, rights protection and user security are paramount goals of operating the TLD, IG Group intends to engage a third party registrar(s), who will be required to ensure that sufficient resources are provided to satisfy this critical requirement, and to do whatever is reasonably necessary to ensure a secure and trusted zone. 

IG Group will have strict controls over the registration and use of the .trading domain names. IG Group will devise and document strict criteria and authority levels which will need to be satisfied before a domain name can be registered for use. To ensure independence of this function, a third party registrar will be responsible for ensuring strict compliance with the criteria and authority levels designated. Only authorized personnel within IG Group organization will be permitted to request and⁄or authorize DNS changes to be made either by the third party registrar or the registry services provider. IG Group’s documented criteria and authority levels for registering a domain name ensure multiple, unique points of contact are needed to request and⁄ or approve, update, transfer and⁄ or deal with deletion requests, and will require notification of multiple unique points of contact when a domain name has been updated, transferred, or deleted.


F. ORPHAN GLUE RECORDS

IG Group will ensure proper attention is paid to orphan glue records. While orphan glue often supports correct and ordinary operation of the DNS, IG Group understands that it will be required, via Specification 6 of the Registry Agreement, to take action to remove orphan glue records when provided with evidence in written form that such records are present in connection with malicious conduct. IG Group’s robust controls on registration and use, and ongoing monitoring of the .trading zone, should ensure that this is not an area of concern. Furthermore, IG Group’s selected backend registry services provider’s (Verisign’s), registration system is specifically designed to not allow orphan glue records. Registrars are required to delete⁄move all dependent DNS records before they are allowed to delete the parent domain. To prevent orphan glue records, Verisign performs the following checks before removing a domain or name server:
 

Checks during domain delete: 

 - Parent domain delete is not allowed if any other domain in the zone refers to the child name server 

 - If the parent domain is the only domain using the child name server, then both the domain and the glue record are removed from the zone


Check during explicit name server delete:

 - Verisign confirms that the current name server is not referenced by any domain name (in-zone) before deleting the name server


Zone-file impact:

 - If the parent domain references the child name server AND if other domains in the zone also reference it AND if the parent domain nameis assigned a serverHold status, then the parent domain goes out of the zone but the name server glue record does not

 - If no domains reference a name server, then the zone file removes the glue record


CONTROLS ON NEW REGISTRATIONS OF DOMAIN NAMES

IG Group will adopt and impose strict controls over the registration and use of .trading domain names. IG Group will devise and document strict criteria and authority levels which will need to be satisfied before a domain name can be registered for IG Group’s use. To ensure appropriate verification of this function, third party registrar(s) will be appointed to perform the administrative aspects of the registration of domain names in strict compliance with the defined criteria and designated authority levels. The registry services provider will be provided with the defined criteria and will be required to ensure that only domains which comply with the criteria are registered. Only authorized personnel within IG Group organization will be able to request and⁄or authorize DNS changes to be made either by the third party registrar(s) or the registry services provider. IG Group’s documented criteria and authority levels for domain name registration will ensure multiple, unique points of contact are needed to request and⁄ or approve, update, transfer and⁄ or deal with deletion requests, and will require notification of multiple unique points of contact when a domain name has been updated, transferred, or deleted.
 
IG Group confirms that it will meet the standards set out in the Registry Agreement, with respect to the Sunrise and Trademark claims process for any domain names registered. 


G. ENSURING WHOIS ACCURACY

A complete and accurate Whois database promotes the prevention of identity theft, fraud and other on-line crime, promotes the public’s ability to police its rights against unlawful copyright and trademark infringement, and minimizes technical errors. IG Group has a compelling interest in accounting to itself and the public for the use of Applicant assets, and in ensuring those assets are only used by persons or entities authorized by IG Group. That interest is especially strong with respect to the .trading and all domain names registered or used therein, since it is a core component of IG Group’s online presence and technological platform. Since IG Group and its affiliates are the only registrants in the .trading gTLD Whois data will be accurate. 

IG Group will enforce the Whois data accuracy provisions in ICANN’s Registry Agreement, Registrar Accreditation Agreement and all relevant Consensus Policies. Those agreements generally require all registrants to provide accurate and reliable contact details and promptly update any changes made during the registration term. IG Group’s registrars must present to the registrant the current Whois information, and remind the registrant that provision of false Whois information can be grounds for cancellation of the domain name registration. IG Group and⁄or its affiliates (as defined in this response) will be listed as the sole registrant of all domains within the .trading. IG Group’s clear written policy which requires the relevant corporate authorisation and approvals to be procured and evidenced for any .trading domain name to be registered for IG Group’s use, and the subsequent verification through a registrar will ensure thorough pre-verification of all Whois data. Therefore, all Whois information will be complete and accurate at the time of registration. In the event of any change in the Whois contact information for a domain name, that change will be promptly updated in the Whois database.

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


REGISTRAR SELF CERTIFICATION

The self-certification program consists, in part, of evaluations applied equally to all operational ICANN accredited registrars and conducted from time to time throughout the year. Process steps are as follows:

 - Verisign sends an email notification to the ICANN primary registrar contact, requesting that the contact go to a designated URL, log in with his⁄her Web ID and password, and complete and submit the online form. The contact must submit the form within 15 business days of receipt of the notification;

 - When the form is submitted, Verisign sends the registrar an automated email confirming that the form was successfully submitted;

 - Verisign reviews the submitted form to ensure the certifications are compliant;

 - Verisign sends the registrar an email notification if the registrar is found to be compliant in all areas;

 - If a review of the response indicates that the registrar is out of compliance or if Verisign has follow-up questions, the registrar has 10 days to respond to the inquiry;

 - If the registrar does not respond within 15 business days of receiving the original notification, or if it does not respond to the request for additional information, Verisign sends the registrar a Breach Notice and gives the registrar 30 days to cure the breach;

 - If the registrar does not cure the breach, Verisign terminates the Registry-Registrar Agreement (RRA). 


WHOIS DATA REMINDER PROCESS

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


H. RESOURCE PLANNING

IG Group has effectively mitigated the risk of abuse in the gTLD and foresees dedicating a member of staff to act as the primary points of contact for handling inquiries relating to malicious or abusive conduct in the TLD. IG Group is committed to ensuring that sufficient resources are made available at all times. IG Group may engage its third party registrar(s) and its selected back end registry services provider, Verisign, to perform some or all of the tasks associated with abuse issues. This will ensure that highly skilled, specialized and scalable resources are on hand to address any possible abuse issues both during the startup phase of the TLD and continually during operations of the TLD.

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

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

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

 - Application Engineers: 19

 - Business Continuity Personnel: 3

 - Customer Affairs Organization: 9

 - Customer Support Personnel: 36

 - Information Security Engineers: 11

 - Network Administrators: 11

 - Network Architects: 4

 - Network Operations Center (NOC) Engineers: 33

 - Project Managers: 25

 - Quality Assurance Engineers: 11

 - Systems Architects: 9


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

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



I. CONCLUSION

The approach outlined in this answer clearly shows that the risk of abuse in the .trading TLD has been extensively mitigated and as a direct result is very low. IG Group is committed to ensuring that abuse will not be tolerated. The proposed policies and methods for addressing any abuse exceed the standard outline in the gTLD Applicant Guidebook and is more than commensurate with the risks identified, IG Group is, therefore, entitled to a score of two points for its response to Question 28.




** IG Group’S DRAFT REGISTRATION POLICY


1. Domain Name Licences

Upon registration of a Domain Name, the Registrant holds a licence to use the Domain Name for a specified period of time in accordance with the Registry Rules. Domain Names may be registered and renewed for 1, 2, 3, 4, 5, 6, 7, 8, 9 or 10 years.


2. Selection of Registrars

Registrars eligible to register domain names must meet the following non-discriminatory criteria (in compliance with clause 2.9 (a) of the Registry Agreement):

 (i) be an accredited ICANN Registrar;

 (ii) demonstrate a level of understanding of the Domain Name registration policies of the Registry;

 (iii) have experience of managing the Domain Names of major corporations;

 (iv) have proven tools for domain name portfolio management; 

 (v) have business processes to perform automated validation (and any additional human checks as required by the Registry) of the eligibility of the domain name for registration according to the Domain Name policies of IG Group;

 (vi) demonstrate a sufficient level of security to protect against unauthorised access to the Domain Name records;

 (vii) demonstrate experience and have appropriate resources in managing abuse prevention, mitigation and responses; 

 (viii) provide multi-language support for the registration of IDNs; 

 (ix) comply with any re-validation of its Registry-Registrar agreement at such regular intervals as are determined by the Registry or as required by ICANN from time to time;

 (x) meet applicable technical requirements of IG Group; and

 (xi) comply with all conditions, dependencies, policies and other requirements reasonably imposed by IG Group, including maintenance of suitable systems and applications that are capable of interacting with the Registry system.


3. Eligible Registrants

The Registrant must be:

 (i) an Affiliate entity of IG Group; or

 (ii) an organisation explicitly authorised by IG Group; or

 (iii) a natural person explicitly authorised by IG Group.


If the Registrant does not meet one of the above eligibility criteria, there is no entitlement to register a Domain Name under the .trading gTLD. If the Registrant ceases to be eligible at any time in the future, the Registry may cancel or suspend the licence to use the Domain Name immediately.


4. Registry approval requirement

Registration of Domain Names under the .trading gTLD must be approved by IG Group in addition to meeting all requirements under the Registry Rules. IG Group’s approval for a complete and validly submitted application will be authorised by: 

 (i) Mike Clark, Head of IT Production (“Authorisation Provider”); or

 (ii) an authorised person as nominated by IG Group (“Authorised Person”) and notified to the Registrar from time to time. 


The Authorisation Provider will notify the Registrar of its decision.


5. Required criteria for Domain Name registration

An application for Domain Name registration must meet all the following criteria: 

 (i) availability;

 a. the Domain Name is not already registered;

 b. it is not reserved or blocked by the Registry; or

 c. it meets all Registry’s technical requirements.


 (ii) technical requirements;

 a. a maximum of 63 characters (after its conversion into the ASCII for IDNs);

 b. use of characters selected from the list of supported characters as nominated by the Registry; and

 c. any additional technical requirements as required by the Registry from time to time.


 (iii) the Domain Name must be consistent with the mission and purposes of the gTLD and consistent with the Domain Name registration policy of IG Group, and include but not be limited to:

 a. product name;

 b. service name;

 c. marketing term;

 d. geographic identifier; or

 e. any relevant name or term as approved by Authorisation Provider or Authorised Person. 


 (iv) compliance with all requirements under the Registry Rules: the Registrant must comply with all provisions contained in the Registry Rules.


6. Obligation of Registrants

The Registrant must enter into an agreement with the Registrar for Domain Name registration under which the Registrant will be bound by the Registry Rules specified through the Registry-Registrar agreement as amended by the Registry from time to time. 

The Registrant must also agree to be bound by the minimum requirements in clause 3.7.7 of ICANNʹs Registrar accreditation agreement.

The Registrant must represent and warrant that:

 (i) it meets, and will continue to meet, the eligibility criteria at all times and must notify the Registrar if it ceases to meet such criteria;

 (ii) the registration, renewal and use of the Domain Name does not violate any third party intellectual property rights, applicable laws or regulation; 

 (iii) it is entitled to register the Domain Name; 

 (iv) the registration and use of the Domain Name is made in good faith and for a lawful purpose; 

 (v) if the use of registered Domain Name is licensed to a third party, 

 a. the Registrant must have a licencing agreement with the licensee for the use of the Domain Name that is not less onerous than the obligation of the Registrant contained in the Registry Rules; and 

 b. where there is a breach of any provisions contained in the Registry Rules by the licensee of the Domain Name, Registry may revoke the Domain Name at its sole discretion.

 (vi) it owns or otherwise has the right to provide all registration data (including personal information) for each Domain Name registered and provision of such registrant data complies with all applicable data protection laws and regulations; and

 (vii) It has appropriate consent and licences to allow for publication of registration data in the WHOIS database.


7. Registrant contact information

The Registrant must provide complete and accurate contact information of the Registrant (in accordance with clause 3.7.7.1 of the ICANN’s Registrar accreditation agreement), including but not limited to the following;

 (i) if the Registrant is a company or organisation:

 a. name of a company or organisation;

 b. registered office and principal place of business; and

 c. contact details of the Registrant including e-mail address and telephone number;

 (ii) if the Registrant is a natural person:

 a. full name of the Registrant;

 b. address of the Registrant; and

 c. contact details of the Registrant including e-mail address and telephone number.


All Registrant contact information must be complete and accurate. Any changes to such Registrant information must be promptly notified to the Registrar, and no later than one (1) month of such change. 


8. Revocation of Domain Names

The Registrant acknowledges that the Registry may revoke a Domain Name immediately at its sole discretion: 

 (i) in the event the Registrant breaches any Registry Rules;

 (ii) to comply with applicable law, court order, government rule or under any dispute resolution processes; 

 (iii) where such Domain Name is used for any of the following prohibited activities (Prohibited Activities): 

 a. spamming; 

 b. intellectual property and privacy violations; 

 c. obscene speech or materials; 

 d. defamatory or abusive language; 

 e. forging headers, return addresses and internet protocol addresses;

 f. illegal or unauthorised access to other computers or networks;

 g. distribution of internet viruses, worms, Trojan horses or other destructive activities; and 

 h. any other illegal or prohibited activities as determined by the Registry. 

 (iv) in order to protect the integrity and stability of the domain name system and the Registry;

 (v) where such Domain Name is placed under reserved names list at any time; and

 (vi) where Registrant fails to make payment to the Registrar for registration, renewal or any other relevant services.


9. Use of second or third level IDNs

In addition to meeting all required criteria for registration of domain names above, an application for an IDN Domain Name must:

 (i) comply with any additional registration policy on IDNs for each language; 

 (ii) meet all technical requirement for the applicable IDN; 

 (iii) comply with the IDN tables used by the Registry as amended from time to time; and

 (iv) meet any other additional technical requirements as required by the Registry.

10. Use of Geographic names

All two-character labels and country and territory names will be initially reserved in accordance with specification 5 of the Registry Agreement. 
Upon approval from ICANN and any other guidelines by applicable governments and ICANN’s Governmental Advisory Committee, the Registry may release the two-character labels and country and territory names in accordance with IG Group’s response to Question 22 Geographic Names.


11. Reserved Names

The Registry may place certain names in its reserved list from time to time where: 

 (i) the Registry believes in its sole discretion that use of such names may pose a risk to the operational stability or integrity of the Registry; 

 (ii) in accordance with ICANN’s specifications contained in the Registry Agreement, guidelines or recommendations;

 (iii) there is a risk of trademark infringement or where the name otherwise may cause confusion taking into consideration the mission and purpose of the gTLD; or

 (iv) the Registry in its sole discretion decides certain names to be reserved for any reason.


12. Allocation of Domain Name

The Registry will register Domain Names on a first-come, first-served basis in accordance with the Registry Rules. The Registry does not provide pre-registration or reservation of Domain Names. 


13. Limitation on registration ⁄ Domain Name licences

There is no restriction on the number of Domain Names any Registrant may hold. The Registrant may further licence the use of the Domain Name to any third parties provided that the Registrant enters into an agreement with such third parties on the terms not less onerous than its obligations under the Registry Rules. 


14. Protection of third party intellectual property rights

The Registry will implement all rights protection measures as required by ICANN in clause 2.8 of the Registry Agreement, including the use of the Uniform Rapid Suspension (URS) procedure, and Uniform Domain Name Dispute Resolution Policy (UDRP). 


15. Term of registration ⁄ renewal

Initial term of registration: 

A Domain Name can be registered for a period between one (1) to ten (10) years. 

Renewal of registration:

 (i) The term may be extended at any time for a period between one (1) to ten (10) years, provided that the total aggregate term of the Domain Name does not exceed ten (10) years at any time. 

 (ii) Upon change of sponsorship of the Domain Name from one Registrar to another, according to Part A of the ICANN Policy on Transfer of Registrations between Registrars, the term of registration of the registered Domain Name will be extended by one year, provided that the maximum term of registration at any time does not exceed ten (10) years.

 (iii) The change of sponsorship of the registration of a Domain Name from one Registrar to another, accordingly to Part B of the ICANN Policy on Transfer of Registrations between Registrars will not result in the extension of the term of registration. 


Cancellation of registration:

The Registrant may cancel a Domain Name registration at any time by submitting its request in writing with the Registrar. 


Auto-renewal: 

Upon expiry of the Domain Name, the Registry will auto-renew the Domain Name for a one year term (1) year term unless the Registrant submits its intention not to renew the Domain Name. 

The Registry will implement the business rules for the renewal of Domain Names documented in appendix 7 of the .com Registry Agreement.


16. Transfer of Domain Names between registrants

Any transfer of a Domain Name between Registrants must be approved by the Registry through the Registrar. The legal heirs of the Registrant or purchaser of the Registrant may request the transfer provided that they meet the eligibility criteria for registration under the .trading gTLD. If the Registrant becomes subject to insolvency or any other proceeding, the administrator may request the transfer. The transferee must provide appropriate documentation as required by the Registry to approve such transfer. 


17. Change of Registrar

If the agreement between the Registry and the Registrar is terminated and if the Registrar has not transferred its Domain Name portfolio to another Registrar, the Registry will notify affected Registrants. The Registrants must select a new Registrar within one (1) month following such notice from the Registry. If the Registrant fails to appoint a new Registrar within the timeframe set out above, the Registry may suspend the Domain Name. 

If the Registrant wishes to change the Registrar, the Registrant must obtain the auth-info code from the Registrantʹs current Registrar, and request a transfer through the gaining Registrar in compliance with ICANNʹs Inter-Registrar transfer policy.


18. Privacy and Data Protection

By registering a Domain Name, the registrant authorises the Registry to process personal information and other data required for the operation of the .trading gTLD. The Registry will only use the data for the operation of the Registry including but not limited to its internal use, communication with the Registrant, and provision of WHOIS look-up facility.

The Registry may only transfer the data to third parties:
 
 (i) with the Registrant’s consent;

 (ii) in order to comply with laws, regulations or orders by a competent public authority and any Alternative Dispute Resolution (ADR) providers; or

 (iii) for a publicly available and searchable WHOIS look-up facility, in accordance with specification 4 of the Registry Agreement. 


19. WHOIS

The Registry provides a publicly available and searchable WHOIS look up facility, where information about the Domain Nameʹs status (including creation and expiry dates), and registrant, administrative and the technical contact administering the Domain Name can be found, in accordance with specification 4 of the Registry Agreement.

In order to prevent misuse of the WHOIS look up facility, the Registry requires that any person submitting a WHOIS database query will be required to read and agree to the terms and conditions, which will provide that: 

 (i) the WHOIS database is provided for information purposes only; and

 (ii) the user agrees not to use the WHOIS information to allow or enable the transmission of unsolicited commercial advertising or other communication via email or other methods to the Registrants. 


20. Pricing ⁄ Payment

The new gTLD does not charge a separate fee for the Registrar to register domain names, as the gTLD is used only for the specified mission and purpose of IG Group. IG Group shall bear the cost of operating the Registry.

The Registry will provide Registrars with 30 days’ notice of any price change for new registrations, and 180 days advance notice of any price change for renewals in accordance with clause 2.10 of the Registry Agreement.


21. Dispute Resolution

The Registrant agrees to be bound by ICANN’s Dispute Resolution Policies in respect of all disputes in connection with the Domain Name. 


22. Compliance with Consensus and Temporary Policies

The Registrant agrees to be bound by all applicable consensus and temporary policies as required and mandated by ICANN.


23. Definitions

Affiliate means in relation to a party any corporation or other business entity controlling, controlled by, or under common control of that party and for the purposes of this definition, a corporation or other business entity shall be deemed to control another corporation or business entity if it owns directly or indirectly: 

 (i) fifty percent (50%) or more of the voting securities or voting interest in any such corporation or other entity; or

 (ii) fifty percent (50%) or more of the interest in the profit or income in the case of a business entity other than a corporation; or 

 (iii) in the case of a partnership, any other compatible interest equal to at least a fifty percent (50%) share in the general partner.


Domain Name means a domain name registered directly under the .trading gTLD or for which a request or application for registration has been filed with the Registry;

ICANN’s Dispute Policy means the dispute policy currently known as the Uniform Domain Name Dispute Resolution Policy (UDRP) issued and as may be updated from time to time by the Internet Corporation of Assigned Names and Number (ICANN) and the Uniform Rapid Suspension (URS) (see Specification 7 of the Registry Agreement).

Registrar means an ICANN accredited registrar which enters into and is in compliance with the registry-registrar agreement for the TLD, and which provides domain name registration services to Registrants; 

Registry means IG Group Holdings plc (IG Group);

Registry Agreement means the agreement between IG Group and ICANN;

Registry Rules mean:

 (i) Registration terms and conditions agreed between the Registry and Registrant for registration of a Domain Name; and

 (ii) Registration policies provided and amended by the Registry from time to time.


Registrant means a natural person, company or organisation who holds a Domain Name registration or who has requested or applied for the registration of a Domain Name. 




*** DRAFT PROCEDURE FOR MANAGEMENT OIF TRADEMARK INFRINGEMENT CLAIMS:

It is almost impossible to devise a standard response⁄process for all claims made of trademark infringement, as the seemingly small individual differences between each complaint and between each domain name registration make the course of action potentially different in each case. This draft procedure is a guide to the general approach required, but thought should be given to the appropriateness of any action in each case, with assistance from designated senior manager where appropriate.



(a) Domain name itself is claimed to be an infringement of a party’s trademark rights:

 i. Actions

 - Determine if the name is being used for any “visible” fraudulent activity such as phishing. If so, follow the phishing process.

 - If no fraudulent content , send “invalid whois” notice to the registrant of the domain name



 ii Formulating a response to complainant

 - It is outside of a registrar’s scope to determine if a domain name infringes a party’s rights

 - Cannot transfer or delete a domain name based on complaint alone – will need to be issued with copies of relevant court orders or other appropriate documentation

 - Outline invalid whois process and inform complainant that a notice has already been sent to the registrant in respect of this

 - If applicable, inform the complainant that the complaint has also been forwarded to the reseller who may be able to take action.

 - Suggest Uniform Dispute Resolution Policy action 




(b) Website located at the domain name contains logos or text which are claimed to infringe another parties rights:


 i. Actions (where the Registrar is not the host)

 - Determine if the name is being used for any “visible” fraudulent activity such as phishing. If so, follow the phishing process.

 - If no fraudulent content , send “invalid whois” notice to the registrant of the domain name



 ii Formulating a response to complainant (where Registrar is not the host):

 - Inform complainant that the Registrar is not hosting the content, and therefore has no ability to access, modify or delete the content.

 - Outline who the host is, and, if able to determine, steps to contact them.

 - Outline invalid whois process and inform complainant that a notice has already been sent to the registrant in respect of this (use prepared template)

 - If applicable, inform the complainant that the complaint has also been forwarded to the relevant third party Registrar



 iii. Where Registrar is the host:

 - Review, formulate a proposed course of action based on the circumstances and applicable policies,

 - Discuss proposed course of action with designated senior manager and base response to complainant around this.

A. RIGHTS PROTECTION MECHANISMS TO BE IMPLEMENTED BY IG GROUP


IG Group’s core purpose in operating the .trading domain is to ensure better rights protection for IG Group, as well as for all Internet users. In particular, IG Group seeks to establish and operate a trusted and reliable platform for the benefit of Internet users who wish find information on products and services related to .trading. There is no incentive for IG Group to confuse Internet users, nor otherwise use domain names in bad faith since IG Group intends to utilize the .trading to benefit internet users by ensuring increased trust, user confidence and utility, thus allowing for better product knowledge and the elimination of user confusion. Furthermore it will be well known that the IG Group is the corporate entity behind the .trading and IG Group wishes to avoid negative press or loss of goodwill.

Therefore, IG Group has extremely strong interest in ensuring that all of its aforementioned policies are implemented and continually enforced. IG Group’s proposed use of the .trading gTLD should, of itself, preclude any abusive registrations from occurring, since all domain names may only be registered in the name of IG Group and its affiliates in the manner outlined in the response to Question 28. Notwithstanding the above, IG Group understands the importance of ensuring safeguards are implemented which protect against unqualified registrations. Therefore, IG Group has resolved to implement the following:

Firstly, IG Group will have absolute control over the registration and use of .trading domain names. Only authorized personnel will be able to register a second level domain name for corporate use and only authorized personnel will be permitted to make Domain Name System (DNS) changes. IG Group will require multiple, unique points of contact to request and⁄ or approve, update, transfer and⁄ or deal with deletion requests, and will require notification of multiple unique points of contact when a domain name has been updated, transferred, or deleted. In other words, IG Group will have an identifiable and delineated process in place from pre-verification to eventual deletion of a domain name. This process will apply to IG Group and also to any subsidiaries or affiliates (as defined in the response to Question 28 above). Compliance with the policy will be ensured by the appointed Registrar(s). This, in conjunction with IG Group’s resolution to ensure that abusive use of .trading domain names will not be permitted nor tolerated, means that the scope for abusive use will be very limited. 

Secondly, where IG Group intends to permit certain entities who are affiliated with IG Group’s business to register second level domain names within the .trading domain, IG Group will ensure that the registration is limited to legitimate uses of the allocated domain name (such use being consistent with the mission and purpose of the .trading), and subject always to the registrant’s continuing compliance with all policies in place during that time and those mandated thereafter to ensure compliance with on-going ICANN requirements wherever reasonable. Any registrants must warrant they will not assign, license or otherwise permit any other third party to use or link to the subdomain. 

Thirdly, IG Group will regularly monitor the .trading zone, for viruses⁄ malware, illegitimate use and for inappropriate content. Abuses and complaints will be quickly addressed in the manner set forth in response to Question 28.

Fourthly, IG Group will participate in, and comply with, the required Rights Protection Mechanisms set forth in the gTLD Applicant Guidebook and Registry Agreement, including the Uniform Domain Name Dispute Resolution Policy (UDRP), the Uniform Rapid Suspension (URS) and the Trademark Claims and Sunrise processes. In the unlikely event that third parties perceive that their rights have been infringed, they will have a speedy right of recourse open to them. Given that IG Group has resolved to ensure that abusive use of .trading domain names will not be permitted nor tolerated and the risk that such abuses inherently create negative publicity and loss of goodwill, IG Group is committed to ensuring that any abuse will be swiftly and effectively addressed, and that systems are in place to mitigate rights protection issues.

Fifth, IG Group will go beyond the required rights protection mechanisms defined in Specification 7 of the Registry Agreement by also participating in anti-phishing and abuse solutions to monitor potentially malicious conduct over the Internet as outlined below and in the answer to Question 28. This may occur via private contracts with a qualified anti-phishing solutions vendor who will both monitor the .trading zone for abuse and take action to remedy the abuse, and⁄ or this may occur via participation in a broader program such as the Abusive Domain Name Resolution Suspension Process (ADNRS) in development by the Anti-Phishing Working Group. These measures will be available at time of registration and include:

 - Rapid Takedown or Suspension Based on Court Orders: IG Group or IG Group’s approved registrar(s) complies promptly with any order from a court of competent jurisdiction that directs it to take any action on a domain name that is within its technical capabilities as a gTLD registry. These orders may be issued when abusive content, such as child pornography, counterfeit goods, or illegal pharmaceuticals, is associated with the domain name;

 - Anti-Abuse Process: IG Group or IG Group’s approved registrar(s) implements an anti-abuse process that is executed based on the type of domain name takedown requested. The anti-abuse process is for malicious exploitation of the DNS infrastructure, such as phishing, botnets, and malware; 

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

 - Malware Code Identification: This safeguard reduces opportunities for abusive behaviours that use registered domain names in the gTLD. Registrants are often unknowing victims of malware exploits. As IG Group’s backend registry services provider, Verisign has developed proprietary code to help identify malware in the zones it manages, which in turn helps registrars by identifying malicious code hidden in the computer systems accessible through domain names;

 - DNSSEC Signing Service: Domain Name System Security Extensions (DNSSEC) helps mitigate pharming attacks that use cache poisoning to redirect unsuspecting users to fraudulent websites or addresses. It uses public key cryptography to digitally sign DNS data when it comes into the system and then validate it at its destination. The .trading gTLD is DNSSEC-enabled as part of Verisign’s core backend registry services. 


Lastly, IG Group will also ensure in all cases that its approved Registrar(s) will adopt appropriate anti-abuse mechanisms, respond to abuse processes and third party rights protection mechanisms and processes, in dealing with any domain name registrations, renewals and use, on behalf of IG Group. This will ensure that highly skilled, specialized and scalable resources are on hand to address any possible rights protection issues both during the startup phase of the TLD and continually during operations of the TLD. An example of the type of processes that Registrar(s) will be required to have in place for managing e.g. a UDRP claim is described at the end of the response to Question 29*** (see end of document). IG Group will ensure that Registrar(s) are contractually bound to provide high quality and responsive management of rights protection queries. 


B. REGISTRY OPERATOR PROVIDED RIGHTS PROTECTION MECHANISMS


IG Group has engaged Verisign to provide certain registry operation services, amongst which, are the technical functions required to implement the mechanisms outlined below in respect of sunrise periods, trademark claims periods and the interaction with the Trademark Clearinghouse. The manner in which these elements will be addressed by the various parties is set out in this section. It should be noted that because ICANN, as of the time of this application submission, has not issued final guidance with respect to the Trademark Clearinghouse, IG Group cannot fully detail the specific implementation of the Trademark Clearinghouse within this application. IG Group will adhere to all processes and procedures to comply with ICANN guidance once this guidance is finalized.


SUNRISE SERVICES 

IG Group acknowledges that, although the .trading domain is intended to be limited exclusively to registrations by IG Group and its affiliates as defined in the response to Question 28, the gTLD Applicant Guidebook provides that all new gTLDs must provide a sunrise period before general registration of domain names. 

IG Group confirms that it will implement a sunrise service pre-registration procedure for domain names for 30 days prior to the launch of the general registration of domain names. Prior to the Sunrise Period commencing, IG Group will establish and then notify its registry service provider of the sunrise eligibility requirements for the gTLD. IG Group may register domain names which meet the sunrise eligibility requirements. The registrant of any registrations of domain names during this period must agree to be subject to the Sunrise Dispute Resolution Policy (SDRP) consistent with Section 6 of the Trademark Clearinghouse Rules as set forth by ICANN. During this period, IG Group, and its approved registrar(s), will verify whether or not a particular domain name is eligible to be registered on an individual case by case basis before adding the necessary command to the Shared Registry Service (SRS) to register the applicable domain name.


TRADEMARK CLAIMS SERVICE

In respect of the .trading domain, IG Group will provide a trademark claims service for a minimum of sixty (60) days after it has permitted general registration of domain names in the .trading domain. During this period, IG Group (or its approved registrars on its behalf) shall validate each request for registration of a domain name against trademarks registered in the Trademark Clearinghouse and shall (where applicable) provide notice to each prospective Registrant of a domain name that it is an identical match (as defined in the gTLD Applicant Guidebook) to the mark holder validated in the Trademark Clearinghouse, in the form required by ICANN. The Approved Registrar(s) will then require each registrant to provide the warranties set out in the gTLD Applicant Guidebook before registration of the particular domain name. Those warranties will include receipt and understanding of the Trademark Claims Notice and confirmation that registration and use of said domain name will not infringe on the trademark rights of the mark holders listed. Without receipt of said warranties, IG Group or IG Group’s approved Registrar(s) will not process the domain name registration.

IG Group and⁄or its approved Registrar(s) (as applicable) will be responsible for determining whether a domain name is eligible to be registered and will do so for each domain name before submitting an add command to the gTLD Shared Registry Service to register the applicable domain name.

Following the registration of a domain name, the holders of trademarks that have been previously validated by the Trademark Clearinghouse as an identical match, will receive a notice of the domain name registration by IG Group or IG Group’s approved Registrar (as applicable), in the form required by ICANN.


GENERAL REGISTRATION PERIOD

Following the expiry of the trademark claims service, IG Group (through its appointed registrar(s)) may nevertheless continue to require potential domain names in the .trading domain to be validated against trademarks registered in the Trademark Clearinghouse as part of its internal approval process prior to the registration being approved. This will be subject to the final rules for the Trademark Clearinghouse, and reasonable commercial terms for the on-going use of the Trademark Clearinghouse for this purpose. 

IG Group will implement processes to enable Internet users or third parties to lodge complaints about any domain names in the .trading which the complainant claims is infringing a third party’s intellectual property rights in some way. These processes will include mechanisms for rapid suspension of an infringing domain name (including but not limited to via ICANN’s URS system). The abuse point of contact resources described in the response to Question 28 above will also be tasked with responding to complaints in relation to rights protection. 


C. DISPUTE RESOLUTION

IG Group will comply with the dispute resolution mechanisms required by ICANN including the Trademark Post-Delegation Dispute Resolution Procedure (PDDRP), the Registration Restriction Dispute Resolution Procedure (RRDRP), the URS, and the UDRP. All registrations of domain names will be subject to compliance with the above procedures and policies, should any relevant disputes occur. IG Group will act as the primary contact for handling inquiries relating to malicious conduct in the gTLD. The primary contact will investigate and respond to all complaints and incidents within a reasonable time and be empowered to take effective action within well-defined written criteria to guide those actions. Action will be taken in line with what is set out in the answers to Question 28 and 29 and the registration policy for the .trading. 


D. RESOURCE PLANNING

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

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

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

 - Customer Affairs Organization: 9

 - Customer Support Personnel: 36

 - Information Security Engineers: 11 


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

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

Resource planning specific to engaging third party registrars
IG Group has effectively mitigated the risk of abuse in the gTLD and foresees dedicating a member of staff to act as the primary points of contact for handling inquiries relating to malicious or abusive conduct in the TLD. IG Group is committed to ensuring that sufficient resources are made available at all times. IG Group may engage its third party registrar(s) and its selected back end registry services provider, Verisign to perform some or all of the tasks associated with abuse issues. This will ensure that highly skilled, specialized and scalable resources are on hand to address any possible abuse issues both during the startup phase of the TLD and continually during operations of the TLD.


E. CONCLUSION

The approach outlined in this answer clearly shows that the risk of abuse in the .trading TLD has been extensively mitigated and as a direct result is very low. IG Group is committed to ensuring that abuse will not be tolerated. The proposed policies and methods for addressing any abuse exceed the standard outlined in the gTLD Applicant Guidebook and is more than commensurate with the risks identified, IG Group is, therefore, entitled to a score of two points for its response to Question 29.




*** EXAMPLE OF A DRAFT PROCESS FOR A REGISTRARʹS HANDLING OF UDRP CLAIMS


Request for Registrar Verification

‘Request for Registrar Verification’ emails are received from the provider of UDRP, and are the official “beginning” of the UDRP case. These emails normally ask the Registrar to verify the domain name and the corresponding registrant details. The Registrar can ONLY ever lock a domain name following receipt of one of these emails. The receipt of a copy of a complaint does not indicate the beginning of a dispute.

The two most commonly used providers are the National Arbitration Forum (NAF) and the World Intellectual Property Organisation (WIPO). NAF requests will generally have the subject “Domain Name Dispute Verification Request”. WIPO requests will generally have the subject “Request for Registrar Verification”



When such a request is received, the following steps need to be taken:

 1. Update the UDRP Spreadsheet with the complaint details

 2. Create a response to UDRP Provider

 3. Send a confirmation to the complainant of receipt of complaint and inform of registrar lock and the circumstances under which the lock will expire

 4. Change domain name Registry Key

 5. Assign domain name to the ‘ABCDisputes’ account

 6. Lock domain name

 7. Advise Registrant of UDRP ⁄ create New Case

 8. Spreadsheet finalisation




When a copy of the UDRP complaint is received:

 - Make a note in the spreadsheet of where to access the complaint.




When a notice of “commencement of UDRP” received:

 - Save the domain name in the case and resolve.

 - If a copy of the complaint has been attached, follow process in above.




When a notice of “Suspension” or “Stay” of proceedings is received:

Sometimes, the parties to the UDRP may reach an agreement to settle the matter outside of the UDRP. If the parties contact the registrar directly and indicate that they (the respondent) wish to transfer the domain name to the complainant, the registrar must direct them to the UDRP provider where they must have the proceedings “stayed” (sometimes called “suspended”). The registrar may only transfer a domain name once official notice from the provider has been received.



If a notice is receive from the UDRP provider PRIOR to the registrar being contacted by the parties:

 - Respond to everyone who has been emailed a copy of the notice, with the template “UDRP – Notice of stay of proceedings. This includes instruction that the registrar require written authorisation from the respondent before releasing the domain name from registrar lock.


Once the registrar has received BOTH authorisation from the current registrant, and official notice of suspension from the provider, the domain name may be transferred to the complainant. 

Note, the registrar is only able to transfer the domain name to the complainant. The Registrar is not able to transfer the domain name to any other party.



When a UDRP decision is received:

When WIPO sends a notice of decision, the subject will be “Notification of Decision”. When NAF sends a notice of decision, the subject will be “DECISION – Complainant v Respondent”



To view the decision:

1. Locate the decision

2. Scroll to the end of the decision document and note whether the decision is for the complainant or the respondent:

 - A decision for the complainant will be described as “the domain name is ordered to be transferred from the respondent to the complainant (follow process (a), below)

 - A decision for the respondent will be described as “the complaint is denied” (follow process (b), below)



Responding to the email regarding the decision:

1. If decision is for the complainant:

 Schedule the transfer for 10 working days time:

 - Add end date to calendar

 - Open the UDRP spreadsheet and make a note that the decision is for the complainant and note the date the name is scheduled to be transferred.



2. If decision is for the respondent:

Open the UDRP spreadsheet and locate the name of the reseller account (if any) which this domain name was on prior to the UDRP, then:

 - Move the domain name from the ABCDISPUTES account

 - Unlock the domain name

 - Send the registrant the new registry key


Implementation of the decision for complainant – transfer of domain name:

 1. Copy of Complaint received? - check UDRP Spreadsheet to make sure

 2. Assigning domain name to new Channel Partner (CP) & Update domain name

 3. Unlock the domain name

 4. Change Contact Details for domain name

 5. Password Recovery 

 6. CRM case creation ⁄ Notice of Transfer of Licence

 7. Update UDRP Spreadsheet – indicate that the case is closed 

30A SECURITY POLICY – PART A


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

As advised previously, IG Group has engaged the services of Verisign as its selected backend registry services provider for .trading. Accordingly, the responses to both Questions 30a and 30b mostly describe the security policies and regime deployed by Verisign, as IG Group’s backend registry services provider. Further attachments have been provided as evidence of, and testimony to, independent third party validation of Verisign’s compliance with these requirements. Whilst IG Group does have a company-wide security policy in place, it was not provided here as it has much wider scope beyond the current application for the proposed operation of .trading gTLD. IG Group will likewise ensure equivalent security policies and controls are adhered for by its other third party services providers, including registrars.

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


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


- ARCHITECTURE

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

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

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

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

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


- ENGINEERING

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

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

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


- OPERATIONS

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

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

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

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

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

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


- GENERAL

 - Secure Password Standard: Because passwords are the most popular and, in many cases, the sole mechanism for authenticating a user to a system, great care must be taken to help ensure that passwords are “strong” and secure. The Secure Password Standard details requirements for the use and implementation of passwords.
 - Secure Anti-Virus Standard: Verisign must be protected continuously from computer viruses and other forms of malicious code. These threats can cause significant damage to the overall operation and security of the Verisign network. The Secure Anti-Virus Standard describes the requirements for minimizing the occurrence and impact of these incidents.


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

 - System and network access control (e.g., monitoring, logging, and backup) 

 - Independent assessment and periodic independent assessment reports

 - Denial of service (DoS) and distributed denial of service (DDoS) attack mitigation

 - Computer and network incident response policies, plans, and processes

 - Minimization of risk of unauthorized access to systems or tampering with registry data

 - Intrusion detection mechanisms, threat analysis, defenses, and updates 

 - Auditing of network access

 - Physical security

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



1.1 SECURITY POLICY AND PROCEDURES FOR THE PROPOSED REGISTRY

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



INDEPENDENT ASSESSMENT AND PERIODIC INDEPENDENT ASSESSMENT REPORTS. 

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



AUGMENTED SECURITY LEVELS OR CAPABILITIES. 

See Section 5 of this response. 



COMMITMENTS MADE TO REGISTRANTS CONCERNING SECURITY LEVELS. 

See Section 4 of this response.



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

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

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



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

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

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

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

 - Information Security Engineers: 11

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

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



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

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



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

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

 - American Institute of Certified Public Accountants (AICPA) and Canadian Institute of Chartered Accountants (CICA) SAS 70 

 - WebTrust⁄SysTrust for Certification Authorities (CA)