Application number: 1-2080-92776 for Vox Populi Registry Inc.

Vox Populi Registry Inc.

26 Auriga Drive
Ottawa Ontario K2E 8B7
CA

+16132252000

+16138200777

Mr. John Berard

Chief Executive Officer

+1 415 845 4388

john@voxpopregistry.com

Mr. John Sao Miguel

Chief Financial Officer

+1 613 768 5131

johns@voxpopregistry.com

Corporation

Canadian Federal

Not Available

John Berard
Chief Executive Officer
John Sao Miguel
Chief Financial Officer

John Berard
Chief Executive Officer
John Sao Miguel
Chief Financial Officer

Momentous Corporation
Not Applicable

SUCKS

Not Available

A number of operational and rendering issues may arise with the delegation, and subsequent operation and use of a new TLD. Some of these issues may be experienced just by the users of one or two particular TLDs, due to the nature or composition of the string itself; whereas other issues (such as software support) may be experienced across all new TLDs.
Evaluation of the potential operational and rendering issues for .SUCKS was delegated to ARI. ARI is experienced with:
– The operational issues of operating TLDs
– TLDs that offer registrations at the third level (eg .com.au, .net.au) and below
– The rendering and operational issues surrounding the introduction of IDNs
ARI has executed a suite of tests to evaluate any issues arising from the use of the TLD string. ARI configured a test environment that consisted of DNS software, web server software, and an email server configured for sample domains in .SUCKS. Where possible, ARI attempted to test many equivalent applications, however the number of and different versions of applications means that testing was limited to the most common environments.
The tests executed by ARI indicate that .SUCKS is subject to the same issues already experienced by TLDs in the root, which are neither new nor unique. A summary of these common issues is provided below.
- Some applications make assumptions about known valid TLDs and fail to recognize new TLDs
- Some Non-IDN aware applications require the user to provide input in A-labels
- Some IDN aware applications present the user with the domain name using A-labels instead of U-labels
- Some IDN aware applications fail to render IRIs in a manner consistent with user expectations.
To mitigate these issues, ARI will work with us to ensure that maintainers of applications are made aware of the delegation and operation of .SUCKS. When relevant, we will refer the maintainers to the verification code produced by ICANN in the area for Universal Acceptance of All Top Level Domains such that operational issues can be mitigated for other TLDs.
ARI and us will work with maintainers of applications to provide subject matter knowledge where required, and provide directions to the tools provided by third parties such as the International Components for Unicode project and other groups, that can assist the application maintainer in adding the required support. User education may be required enabling users to configure their applications for correct functioning of .SUCKS. An informational section on the TLD website will be considered to address questions raised by the Internet community.
The steps ARI will take to mitigate these issues are more than adequate. Thus, we do not believe .SUCKS raises stability concerns and there is no reason that it should be denied on an operational and rendering issues bases.

Customer relationship management is currently either narrowly defined by a toll-free telephone number and an “info@” email address or widely viewed through the lens of diverse social media and a thicket of hard-to-find, hit-or-miss, unfocused websites that cater to consumer complaints.
Ultimately, the dialog has satisfied neither the consumer who wants to be heard nor the companies anxious to respond. 
Our mission is to create a new address on the web that will give voice to the consumer and create the opportunity for closer contact between companies and their customers. 
This is no small goal.
One large, branded Internet retailer put it this way. “We have 200,000 fans on Facebook, but many of them are there to offer criticism of our service. This is good. We can learn more about our products and services from those complaints than we can from the 60 million unique visitors to our company website each month.” 
By building an easy-to-locate, “central town square” available 24 hours a day, 7 days a week, 365 days a year, the .SUCKS registry will become a recognized destination not just for that one company, but for all. It will give assurances to customers that their voice can be heard. And it can become an essential part of every company’s customer relationship management program. 
In this way, we intend for the .SUCKS top level domain to become a focal point for customer service

i) What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?
The term “sucks” resonates around the globe, its intention clear and understood. But it is now more than an epithet; it is a call to action. Whether registered by an activist or an executive, this new landscape will be devoted to encouraging an accelerated and legitimate dialog that can lead to improved customer satisfaction and market share.
In fact, ten years ago just such an idea was suggested by noted consumer advocate Ralph Nader in a letter to ICANN. He said at the time he wanted “to create several TLDs that would facilitate free speech and criticism, and enable consumers, workers and others to organize.” He concluded by saying that though the registry name might be offensive to some, he thought the “domain will be popular in the marketplace” and generate support “for the free speech rights of individuals and small organizations.”
It is our plan to create the opportunity where the marketplace does not have to rely on a single consumer advocate, but can benefit from the energy, enthusiasm and insight of all.
ii) What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?
As previously noted, the current space is idiosyncratic. 
Customer relationship management is currently either narrowly defined by a toll-free telephone number and an “info@” email address or widely viewed through the lens of diverse social media and a thicket of hard-to-find, hit-or-miss, unfocused websites that cater to consumer complaints.
Ultimately, the dialog has satisfied neither the consumer who wants to be heard nor the companies anxious to respond. 
Our mission is to create a new address on the web that will give voice to the consumer and create the opportunity for closer contact between companies their customers. 
There are few, if any, places for raw consumer commentary and corporate interests to cohere. The .SUCKS name space will enable the benefits of the dialog without dampening its usual initial vehemence. With its specific focus, it will make it even easier for consumers to find, suggest, cajole, complain and engage on specific products, services and companies.
The opportunity for registrants to innovate in support of this exchange is wide. It could come in the form of coupon or loyalty or other offers from companies and higher influencer scores (a la Klout.com) for consumers. The ability to integrate social media feeds, upload videos and store a history of the exchange and its outcome could well lead to broader media exposure for the best of the watchdogs and enhanced corporate reputations.
iii) What goals does your proposed gTLD have in terms of user experience?
There is an age-old question that asks, “If a tree falls in the woods and no one is there to hear it, does it make a sound?” Such is often the case with criticism, complaints and suggestions. The essential user experience goal is to create a name space where everyone’s voice is heard. 
There are few, if any, places for raw consumer commentary and corporate interests to cohere. The .SUCKS name space will enable the benefits of the dialog without dampening its usual initial vehemence. With its specific focus, it will make it even easier for consumers to find, suggest, cajole, complain and engage on specific products, services and companies.
It is our belief that the focused of the registry, the value of feedback in customer service and product development and the effect digital technologies have had on the expectations of consumers and companies alike all will combine to deliver a meaningful, responsive and amplified community.
By establishing certain registration policies (discussed below), it is our intent to keep registrants focused on delivering a platform for promoting an open door for companies and address for customers to “mail” their commentary.
We subscribe to the view that it is better to light a candle than curse the darkness.
iv) Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.
In introducing the registry, there will be a number of restrictions on the names that can be registered in .SUCKS. Some of these are contractual requirements from ICANN, but others are a matter of registry policy. In addition, reserved are the names of territories, distinct economies, and other geographic and geopolitical names, as required by ICANN. 
The registry also has a small list of names that it has reserved for itself. Some will be offered via an RFP process aimed at generating important services in support of the registry, some will be retained by the registry (this is a confidential list) and others will be offered to strategic partners.
As our mission is to enhance the conversation between companies and their customers, certain policies will be implemented to guard against registrants that diffuse this mission. To that end, we will have a rapid takedown procedure to deal, at least, with these three (3) potential scenarios:
Cyberbullying
If a complaint is made that any DotSUCKS site engages in cyberbullying (as defined by http:⁄⁄www.stopcyberbullying.org), and that complaint is proved, the site will be the subject of rapid takedown policies. 
Pornography
Registrants who host pornographic content will similarly be subject to rapid takedown should a complaint be filed and upheld.
Parked pages
It will be the policy of the registry to limit parked pages. If such a complaint is filed about a DotSUCKS page is made and proved, the site will be the subject of the registry’s rapid takedown policies.

The tactical approach to releasing .SUCKS names will reinforce these values and follow this path:
An RFP process will begin immediately to help establish the market for the registry’s names and services in support of it.
A Sunrise period will ensure the protection of rights holders. Each will have the opportunity to register protected names in advance of the General Availability. These names will be subject to annual renewal.
Then a Landrush will open for all. Competition for the same names in both the sunrise and landrush periods will be sent to an auction.
Finally, General Availability will open.
v) Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users? If so, please describe any such measures.
All registrants will be encouraged to balance the privacy needs of individuals and the necessary public nature of a productive back-and-forth. From the point-of-view of the registry, the sites created on .SUCKS ought to be focused on facilitating such a dialog.
The diversity of approaches to meeting that goal will likely be a wide as the range of sites created in the registry’s name space. It is our plan, by our marketing and our operating principles, to encourage registrants to make a similar commitment.
The registry’s decision to host a thick and verified WhoIs database is one instance where it will seek to lead by example. Privacy and transparency are not mutually exclusive values; each is totally appropriate. So, too is accountability. 
Describe whether and in what ways outreach and communications will help to achieve your projected benefits.
The history of consumer criticism is long and deep. It is our plan to partner with consumer groups of longstanding to accelerated public awareness of this new town square. Organizations like the Consumer Federation of America based in the U.S. can be a direct channel to the users the registry seeks to energize.
Consumer criticism and corporate marketing are persistent subjects of media reporting. The corps of reporters, editors and bloggers who follow those stories are also channels for the registry’s message.
At the same time, the direct marketing, advertising and sales functions of businesses around the world are hypersensitive to opportunities to hear what customers are saying. It is, by one company’s view, essential. 
One large, branded Internet retailer put it this way. “We have 200,000 fans on Facebook, but many of them are there to offer criticism of our service. This is good. We can learn more about our products and services from those complaints than we can from the 60 million unique visitors to our company website each month.” 
The disparate energy devoted to this task – whether by social media, consumer website or corporate URL – suggests a keen interest in hearing and understanding. A registry that can align, organize and encourage interaction will draw the attention of those players who now have no one address.

The registry will seek to create the orderly introduction of domain names in a way that is respectful of trademarks and sensitive to costs. Our approach will follow this path:
An RFP process will begin immediately to help establish the market for the registry’s names and services in support of it. This approach to certain premium names should help generate operating capital for the registry that will ensure stability for both operations and the cost of registrations generally available.
A Sunrise period will ensure the protection of rights holders. Each will have the opportunity to register protected names in advance of the General Availability. These names will be subject to annual renewal, but, as with all names, a fixed-rate, 10-year registration will be offered.
Then a Landrush will open for all. Competition for the same names in both the Sunrise and Landrush periods will be sent to an auction. An auction is the best way possible to ensure that real and vibrant sites will be built in the name space.
Finally, General Availability will open.
The registry’s decision to host a thick and verified WhoIs database is an opportunity for .SUCKS to lead by example. Privacy and transparency are not mutually exclusive values; each is totally appropriate. So, too is accountability. The result of such an approach should be to greatly reduce the chance for negative consequences and costs.

No

Not Available

No

We have engaged ARI Registry Services (ARI) to deliver services for .SUCKS. This response describes protection of geographic names as implemented by ARI.

1 PROTECTION OF GEOGRAPHIC NAMES

In accordance with Specification 5 of the New gTLD Registry Agreement, the registry operator must initially reserve all geographic names at the second level, and at all other levels within the TLD at which the registry operator provides for registrations.
ARI supports this requirement by using the following internationally recognised lists to develop a comprehensive master list of all geographic names that are initially reserved:
– The 2-letter alpha-2 code of all country and territory names contained on the ISO 3166-1 list, including all reserved and unassigned codes [http:⁄⁄www.iso.org⁄iso⁄support⁄country_codes⁄iso_3166_code_lists⁄iso-3166-1_decoding_table.htm].
– The short form (in English) of all country and territory names contained on the ISO 3166-1 list, including the European Union, which is exceptionally reserved on the ISO 3166-1 List, and its scope extended in August 1999 to any application needing to represent the name European Union [http:⁄⁄www.iso.org⁄iso⁄support⁄country_codes⁄iso_3166_code_lists⁄iso-3166-1_decoding_table.htm#EU].
– The United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardisation of Geographical Names, Part III Names of Countries of the World. This lists the names of 193 independent States generally recognised by the international community in the language or languages used in an official capacity within each country and is current as of August 2006 [http:⁄⁄unstats.un.org⁄unsd⁄geoinfo⁄ungegn%20tech%20ref%20manual_M87_combined.pdf].
– The list of UN member states in six official UN languages prepared by the Working Group on Country Names of the United Nations Conference on the standardisation of Geographical Names [http:⁄⁄unstats.un.org⁄unsd⁄geoinfo⁄UNGEGN⁄docs⁄9th-uncsgn-docs⁄econf⁄9th_UNCSGN_e-conf-98-89-add1.pdf].
Names on this reserved list in ARI’s registry system are prevented from registration.
A corresponding list of geographic names will also be available to the public via the registry operators website, to inform Registrars and potential registrants of reserved names. The lists noted above, are regularly monitored for revisions, therefore the reserved list (both within the registry and publicly facing) will be continually updated to reflect any changes.
In addition to these requirements, ARI are able to support the wishes of the Governmental Advisory Council (GAC) or any individual Government in regard to the blocking of individual terms on a case by case basis. ARI’s registry system allows such additions to be made by appropriately authorised staff, with no further system development changes required.
The following applies to all Domain Names contained within the registry’s reserved list:
– Attempts to register listed Domain Names will be rejected.
– WhoIs queries for listed Domain Names will receive responses indicating their reserved status.
– Reserved geographic names will not appear in the TLD zone file.
– DNS queries for reserved domain names will result in an NXDOMAIN response.

2 PROCEDURES FOR RELEASE

We understand that if we wish to release the reserved names at a later date, this will require agreement from the relevant government(s) or review by the GAC, and subsequent approval from ICANN.

We have engaged ARI Registry Services (ARI) to deliver services for .SUCKS. This response describes the registry services for .SUCKS, as provided by ARI.

1 INTRODUCTION

ARI’s Managed TLD Registry Service is a complete offering, providing all of the required registry services. What follows is a description of each of those services.

2 REGISTRY SERVICES
The following sections describe the registry services provided. Each of these services has, where required, been designed to take into account the requirements of consensus policies as documented here:
[http:⁄⁄www.icann.org⁄en⁄resources⁄Registrars⁄consensus-policies]
At the time of delegation into the root .SUCKS will not be offering any unique Registry services.

2.1 Receipt of Data from Registrars

The day-to-day functions of the registry, as perceived by Internet users, involves the receipt of data from Registrars and making the necessary changes to the SRS database. Functionality such as the creation, renewal and deletion of domains by Registrars, on behalf of registrants, is provided by two separate systems:
– An open protocol-based provisioning system commonly used by Registrars with automated domain management functionality within their own systems.
– A dedicated website providing the same functionality for user interaction.
Registrants (or prospective registrants) who wish to manage their existing domains or credentials, register new domains or delete their domains will have their requests carried out by Registrars using one of the two systems described below.
ARI operates Extensible Provisioning Protocol (EPP) server software and distributes applicable toolkits to facilitate the receipt of data from Registrars in a common format. EPP offers a common protocol for Registrars to interact with SRS data and is favoured for automating such interaction in the Registrar’s systems. In addition to the EPP server, Registrars have the ability to use a web-based management interface (SRS Web Interface), which provides functions equivalent to the EPP server functionality.

2.1.1 EPP

The EPP software allows Registrars to communicate with the SRS using a standard protocol. The EPP server software is compliant with all appropriate RFCs and will be updated to comply with any relevant new RFCs or other new standards, as and when they are finalised. All standard EPP operations on SRS objects are supported.
Specifically, the EPP service complies with the following standards:
– RFC 5730 Extensible Provisioning Protocol (EPP).
– RFC 5731 Extensible Provisioning Protocol (EPP) Domain Name Mapping.
– RFC 5732 Extensible Provisioning Protocol (EPP) Host Mapping.
– RFC 5733 Extensible Provisioning Protocol (EPP) Contact Mapping.
– RFC 5734 Extensible Provisioning Protocol (EPP) Transport over TCP.
– RFC 5910 Domain Name System (DNS) Security Extensions for the Extensible Provisioning Protocol (EPP).
– RFC 3915 Domain Registry Grace Period Mapping for the Extensible Provisioning Protocol (EPP).
– Extensions to ARI’s EPP service comply with RFC 3735 Guidelines for Extending the Extensible Provisioning Protocol (EPP).

2.1.1.1 Security for EPP Service

To avoid abuse and to mitigate potential fraudulent operations, the EPP server software uses a number of security mechanisms that restrict the source of incoming connections and prescribe the authentication and authorisation of the client. Connections are further managed by command rate limiting and are restricted to only a certain number for each Registrar, to help reduce unwanted fraudulent and other activities. Additionally, secure communication to the EPP interface is required, lowering the likelihood of the authentication mechanisms being compromised.
The EPP server has restrictions on the operations it is permitted to make to the data within the registry database. Except as allowed by the EPP protocol, the EPP server cannot update the credentials used by Registrars for access to the SRS. These credentials include those used by Registrars to login to ARI’s SRS Web Interface and the EPP service.
Secure communication to the EPP server is achieved via the encryption of EPP sessions. The registry system and associated toolkits support AES 128 and 256 via TLS.
The Production and Operational Testing and Evaluation (OTE) EPP service is protected behind a secure firewall that only accepts connections from registered IP addresses. Registrars are required to supply host IP addresses that they intend to use to access the EPP service.
Certificates are used for encrypted communications with the registry. Registrars require a valid public⁄private key pair signed by the ARI CA to verify authenticity. These certificates are used to establish a TLS secure session between client and server.
EPP contains credential elements in its specification which are used as an additional layer of authentication. In accordance with the EPP specification, the server does not allow client sessions to carry out any operations until credentials are verified.
The EPP server software combines the authentication and authorisation elements described above to ensure the various credentials supplied are associated with the same identity. This verification requires that:
– The username must match the common name in the digital certificate.
– The certificate must be presented from a source IP listed against the Registrar whose common name appears in the certificate.
– The username and password must match the user name and password listed against the Registrar’s account with that source IP address.
To manage normal operations and prevent an accidental or intentional Denial of Service, the EPP server can be configured to rate limit activities by individual Registrars.

2.1.1.2 Stability Considerations

The measures that restrict Registrars to a limit of connections and operations for security purposes also serve to keep the SRS and the EPP server within an acceptable performance and resource utilisation band. Therefore, scaling the service is an almost linear calculation based on well-defined parameters.
The EPP server offers consistent information between Registrars and the SRS Web Interface. The relevant pieces of this information are replicated to the DNS within seconds of alteration, thus ensuring that a strong consistency between the SRS and DNS is maintained at all times.

2.1.2 SRS Web Interface

The registry SRS Web Interface offers Registrars an alternative SRS interaction mechanism to the EPP server. Available over HTTPS, this interface can be used to carry out all operations which would otherwise occur via EPP, as well as many others. Registrars can use the SRS Web Interface, the EPP server interface or both – with no loss of consistency within the SRS.

2.1.2.1 Security and Consistency Considerations for SRS Web Interface

The SRS Web Interface contains measures to prevent abuse and to mitigate fraudulent operations. By restricting access, providing user level authentication and authorisation, and protecting the communications channel, the application limits both the opportunity and scope of security compromise.
Registrars are able to create individual users that are associated with their Registrar account. By allocating the specific operations each user can access, Registrars have full control over how their individual staff members interact with the SRS. Users can be audited to identify which operations were conducted and to which objects those operations were applied.
A secure connection is required before credentials are exchanged and once authenticated. On login, any existing user sessions are invalidated and a new session is generated, thereby mitigating session-fixation attacks and reducing possibilities that sessions could be compromised.

2.1.3 Securing and Maintaining Consistency of Registry-Registrar Interaction Systems

ARI ensures all systems through which Registrars interact with the SRS remain consistent with each other and apply the same security rules. Additionally, ARI also ensures that operations on SRS objects are restricted to the appropriate entity. For example:
– In order to initiate a transfer a Registrar must provide the associated domain password (authinfo) which will only be known by the registrant and the current sponsoring Registrar.
– Only sponsoring Registrars are permitted to update registry objects.
All operations conducted by Registrars on SRS objects are auditable and are identifiable to the specific Registrar’s user account, IP address and the time of the operation.

2.2 Disseminate Status Information of TLD Zone Servers to Registrars

The status of TLD zone servers and their ability to reflect changes in the SRS is of great importance to Registrars and Internet users alike. ARI will ensure that any change from normal operations is communicated to the relevant stakeholders as soon as is appropriate. Such communication might be prior to the status change, during the status change and⁄or after the status change (and subsequent reversion to normal) – as appropriate to the party being informed and the circumstance of the status change.
Normal operations are those when:
– DNS servers respond within SLAs for DNS resolution.
– Changes in the SRS are reflected in the zone file according to the DNS update time SLA.
The SLAs are those from Specification 10 of the Registry Agreement.
A deviation from normal operations, whether it is registry wide or restricted to a single DNS node, will result in the appropriate status communication being sent.

2.2.1 Communication Policy

ARI maintains close communication with Registrars regarding the performance and consistency of the TLD zone servers.
A contact database containing relevant contact information for each Registrar is maintained. In many cases, this includes multiple forms of contact, including email, phone and physical mailing address. Additionally, up-to-date status information of the TLD zone servers is provided within the SRS Web Interface.
Communication using the Registrar contact information discussed above will occur prior to any maintenance that has the potential to effect the access to, consistency of, or reliability of the TLD zone servers. If such maintenance is required within a short time frame, immediate communication occurs using the above contact information. In either case, the nature of the maintenance and how it affects the consistency or accessibility of the TLD zone servers, and the estimated time for full restoration, are included within the communication.
That being said, the TLD zone server infrastructure has been designed in such a way that we expect no down time. Only individual sites will potentially require downtime for maintenance; however the DNS service itself will continue to operate with 100% availability.

2.2.2 Security and Stability Considerations

ARI restricts zone server status communication to Registrars, thereby limiting the scope for malicious abuse of any maintenance window. Additionally, ARI ensures Registrars have effective operational procedures to deal with any status change of the TLD nameservers and will seek to align its communication policy to those procedures.

2.3 Zone File Access Provider Integration

Individuals or organisations that wish to have a copy of the full zone file can do so using the Zone Data Access service. This process is still evolving; however the basic requirements are unlikely to change. All registries will publish the zone file in a common format accessible via secure FTP at an agreed URL.

ARI will fully comply with the processes and procedures dictated by the Centralised Zone Data Access Provider (CZDA Provider or what it evolves into) for adding and removing Zone File access consumers from its authentication systems. This includes:

– Zone file format and location.
– Availability of the zone file access host via FTP.
– Logging of requests to the service (including the IP address, time, user and activity log).
– Access frequency.

2.4 Zone File Update

To ensure changes within the SRS are reflected in the zone file rapidly and securely, ARI updates the zone file on the TLD zone servers using software compliant with RFC 2136 (Dynamic Updates in the Domain Name System (DNS UPDATE)) and RFC 2845 (Secret Key Transaction Authentication for DNS (TSIG)).
This updating process follows a staged but rapid propagation of zone update information from the SRS, outwards to the TLD zone servers – which are visible to the Internet. As changes to the SRS data occur, those changes are updated to isolated systems which act as the authoritative primary server for the zone, but remain inaccessible to systems outside ARI’s network. The primary servers notify the designated secondary servers, which service queries for the TLD zone from the public. Upon notification, the secondary servers transfer the incremental changes to the zone and publicly present those changes.
The protocols for dynamic update are robust and mature, as is their implementation in DNS software. The protocols’ mechanisms for ensuring consistency within and between updates are fully implemented in ARI’s TLD zone update procedures. These mechanisms ensure updates are quickly propagated while the data remains consistent within each incremental update, regardless of the speed or order of individual update transactions. ARI has used this method for updating zone files in all its TLDs including the .au ccTLD, pioneering this method during its inception in 2002. Mechanisms separate to RFC 2136-compliant transfer processes exist; to check and ensure domain information is consistent with the SRS on each TLD zone server within 10 minutes of a change.

2.5 Operation of Zone Servers

ARI maintains TLD zone servers which act as the authoritative servers to which the TLD is delegated.

2.5.1 Security and Operational Considerations of Zone Server Operations

The potential risks associated with operating TLD zone servers are recognised by ARI such that we will perform the steps required to protect the integrity and consistency of the information they provide, as well as to protect the availability and accessibility of those servers to hosts on the Internet. The TLD zone servers comply with all relevant RFCs for DNS and DNSSEC, as well as BCPs for the operation and hosting of DNS servers. The TLD zone servers will be updated to support any relevant new enhancements or improvements adopted by the IETF.
The DNS servers are geographically dispersed across multiple secure data centres in strategic locations around the world. By combining multi-homed servers and geographic diversity, ARI’s zone servers remain impervious to site level, supplier level or geographic level operational disruption.
The TLD zone servers are protected from accessibility loss by malicious intent or misadventure, via the provision of significant over-capacity of resources and access paths. Multiple independent network paths are provided to each TLD zone server and the query servicing capacity of the network exceeds the extremely conservatively anticipated peak load requirements by at least 10 times, to prevent loss of service should query loads significantly increase.
As well as the authentication, authorisation and consistency checks carried out by the Registrar access systems and DNS update mechanisms, ARI reduces the scope for alteration of DNS data by following strict DNS operational practices:
– TLD zone servers are not shared with other services.
– The primary authoritative TLD zone server is inaccessible outside ARI’s network.
– TLD zone servers only serve authoritative information.
– The TLD zone is signed with DNSSEC and a DNSSEC Practice⁄Policy Statement published.

2.6 Dissemination of Contact or Other Information

Registries are required to provide a mechanism to identify the relevant contact information for a domain. The traditional method of delivering this is via the WhoIs service, a plain text protocol commonly accessible on TCP port 43. ARI also provides the same functionality to users via a web-based WhoIs service. Functionality remains the same with the web-based service, which only requires a user to have an Internet browser.
Using the WhoIs service, in either of its forms, allows a user to query for domain-related information. Users can query for domain details, contact details, nameserver details or Registrar details.
A WhoIs service, which complies with RFC 3912, is provided to disseminate contact and other information related to a domain within the TLD zone.

2.6.1 Security and Stability Considerations

ARI ensures the service is available and accurate for Internet users, while limiting the opportunity for its malicious use. Many reputation and anti-abuse services rely on the availability and accuracy of the WhoIs service, however the potential for abuse of the WhoIs service exists.
Therefore, certain restrictions are made to the access of WhoIs services, the nature of which depend on the delivery method – either web-based or the traditional text-based port 43 service. In all cases, there has been careful consideration given to the benefits of WhoIs to the Internet community, as well as the potential harm to registrants – as individuals and a group – with regard to WhoIs access restrictions.
The WhoIs service presents data from the registry database in real time. However this access is restricted to reading the appropriate data only. The WhoIs service does not have the ability to alter data or to access data not related to the WhoIs service. The access limitations placed on the WhoIs services prevent any deliberate or incidental denial of service that might impact other registry services.
Restrictions placed on accessing WhoIs services do not affect legitimate use. All restrictions are designed to target abusive volume users and to provide legitimate users with a fast and available service. ARI has the ability to ‘whitelist’ legitimate bulk users of WhoIs, to ensure they are not impacted by standard volume restrictions.
The data presentation format is consistent with the canonical representation of equivalent fields, as defined in the EPP specifications and ICANN agreement.

2.6.1.1 Port 43 WhoIs

A port 43-based WhoIs service complying with RFC 3912 is provided and will be updated to meet any other relevant standards or best practice guidelines related to the operation of a WhoIs service.
While the text-based service can support thousands of simultaneous queries, it has dynamic limits on queries per IP address to restrict data mining efforts. In the event of identified malicious use of the service, access from a single IP address or address ranges can be limited or blocked.

2.6.1.2 Web-based WhoIs

ARI’s web-based WhoIs service provides information consistent with that contained within the SRS.
The web-based WhoIs service contains an Image Verification Check (IVC) and query limits per IP address. These restrictions strike a balance between acceptable public usage and abusive use or data mining. The web-based WhoIs service can blacklist IP addresses or ranges to prevent abusive use of the service.

2.7 IDNs – Internationalised Domain Names

An Internationalised Domain Name (IDN) allows registrants to register domains in their native language and have it display correctly in IDN aware software. This includes allowing a language to be read in the manner that would be common for its readers. For example, an Arabic domain would be presented right to left for an Arabic IDN aware browser.
The inclusion of IDNs into the TLD zones is supported by ARI. All the registry services, such as the EPP service, SRS Web Interface and RDPS (web and port 43), support IDNs. However there are some stability and security considerations related to IDNs which fall outside the general considerations applicable individually to those services.

2.7.1 Stability Considerations Specific to IDN

To avoid the intentional or accidental registration of visually similar chars, and to avoid identity confusion between domains, there are several restrictions on the registration of IDNs.

2.7.1.1 Prevent Cross Language Registrations

Domains registered within a particular language are restricted to only the chars of that language. This avoids the use of visually similar chars within one language which mimic the appearance of a label within another language, regardless of whether that label is already within the DNS or not.

2.7.1.2 Inter-language and Intra-language Variants to Prevent Similar Registrations

ARI restricts child domains to a specific language and prevents registrations in one language being confused with a registration in another language, for example Cyrillic а (U+0430) and Latin a (U+0061).

2.8 DNSSEC

DNSSEC provides a set of extensions to the DNS that allow an Internet user (normally the resolver acting on a user’s behalf) to validate that the DNS responses they receive were not manipulated en-route.
This type of fraud, commonly called ‘man in the middle’, allows a malicious party to misdirect Internet users. DNSSEC allows a domain owner to sign their domain and to publish the signature, so that all DNS consumers who visit that domain can validate that the responses they receive are as the domain owner intended.
Registries, as the operators of the parent domain for registrants, must publish the DNSSEC material received from registrants, so that Internet users can trust the material they receive from the domain owner. This is commonly referred to as a ‘chain of trust’. Internet users trust the root (operated by IANA), which publishes the registries’ DNSSEC material, therefore registries inherit this trust. Domain owners within the TLD subsequently inherit trust from the parent domain when the registry publishes their DNSSEC material.
In accordance with new gTLD requirements, the TLD zone will be DNSSEC signed and the receipt of DNSSEC material from Registrars for child domains is supported in all provisioning systems.

2.8.1 Stability and Operational Considerations for DNSSEC

2.8.1.1 DNSSEC Practice Statement

ARI’s DNSSEC Practice Statement is included in our response to Question 43. The DPS following the guidelines set out in the draft IETF DNSOP DNSSEC DPS Framework document.

2.8.1.2 Receipt of Public Keys from Registrars

The public key for a child domain is received by ARI from the Registrar via either the EPP or SRS Web Interface. ARI uses an SHA-256 digest to generate the DS Resource Record (RR) for inclusion into the zone file.

2.8.1.3 Resolution Stability

DNSSEC is considered to have made the DNS more trustworthy; however some transitional considerations need to be taken into account. DNSSEC increases the size and complexity of DNS responses. ARI ensures the TLD zone servers are accessible and offer consistent responses over UDP and TCP.
The increased UDP and TCP traffic which results from DNSSEC is accounted for in both network path access and TLD zone server capacity. ARI will ensure that capacity planning appropriately accommodates the expected increase in traffic over time.
ARI complies with all relevant RFCs and best practice guides in operating a DNSSEC-signed TLD. This includes conforming to algorithm updates as appropriate. To ensure Key Signing Key Rollover procedures for child domains are predictable, DS records will be published as soon as they are received via either the EPP server or SRS Web Interface. This allows child domain operators to rollover their keys with the assurance that their timeframes for both old and new keys are reliable.

3 APPROACH TO SECURITY AND STABILITY

Stability and security of the Internet is an important consideration for the registry system. To ensure that the registry services are reliably secured and remain stable under all conditions, ARI takes a conservative approach with the operation and architecture of the registry system.
By architecting all registry services to use the least privileged access to systems and data, risk is significantly reduced for other systems and the registry services as a whole should any one service become compromised. By continuing that principal through to our procedures and processes, we ensure that only access that is necessary to perform tasks is given. ARI has a comprehensive approach to security modelled of the ISO27001 series of standards and explored further in the relevant questions of this response.
By ensuring all our services adhering to all relevant standards, ARI ensures that entities which interact with the registry services do so in a predictable and consistent manner. When variations or enhancements to services are made, they are also aligned with the appropriate interoperability standards.

We have engaged ARI Registry Services (ARI) to deliver services for .SUCKS. ARI provide registry services for a number of TLDs including the .au ccTLD. For more background information on ARI please see the attachment ‘Q24 – ARI Background & Roles.pdf’. This response describes the SRS as implemented by ARI.

1 INTRODUCTION
ARI has demonstrated delivery of an SRS with exceptional availability, performance and reliability. ARI are experienced running mission critical SRSs and have significant knowledge of the industry and building and supporting SRSs.
ARI’s SRS has successfully supported a large group of Registrars for ASCII and IDN based TLDs. The system is proven to sustain high levels of concurrency, transaction load, and system uptime. ARI’s SRS meets the following requirements:
– Resilient to wide range of security & availability threats
– Consistently exceeds performance & availability SLAs
– Allows capacity increase with minimal impact to service
– Provides fair & equitable provisioning for all Registrars

2 CAPACITY
ARI’s SRS was built to sustain 20M domain names. Based on ARI’s experience running a ccTLD registries and industry analysis, ARI were able to calculate the conservative characteristics of a registry this size.
Through conservative statistical analysis of the .au registry and data presented in the May 2011 ICANN reports for the .com & .net, .org, .mobi, .info, .biz and .asia [http:⁄⁄www.icann.org⁄en⁄resources⁄registries⁄reports] we know there is:
– An average of 70 SRS TPS per domain, per month
– A ratio of 3 query to 2 transform txs
This indicates an expected monthly transaction volume of 1,400M txs (840M query and 560M transforms).
Through statistical analysis of the .au registry and backed up by the data published in the .net RFP responses [http:⁄⁄archive.icann.org⁄en⁄tlds⁄net-rfp⁄net-rfp-public-comments.htm] we also know:
– The peak daily TPS is 6% of monthly total
– The peak 5 min is 5% of the peak day
Thus we expect a peak EPP tx rate of 14,000 TPS (5,600 transform TPS and 8,400 query TPS)
Through conservative statistical analysis of the .au registry we know:
– The avg no. contacts⁄domain is 3.76
– The avg no. hosts⁄domain is 2.28
This translates into a requirement to store 75.2M contacts and 45.6M hosts.
Finally through real world observations of the .au registry, which has a comprehensive web interface when compared to those offered by current gTLD registries, we know there is an avg of 0.5 HTTP requests⁄sec to the SRS web interface per Registrar. We also know that this behaviour is reasonably flat. To support an estimated 1000 Registrars, would require 500 requests⁄second.
For perspective on the conservativeness of this, the following was taken from data in the May 2011 ICANN reports referenced above:
– .info: ~7.8M names peaks at ~1,400 TPS (projected peak TPS of ~3,600 with 20M)
– .com: ~98M names peaks at ~41,000 TPS (projected peak TPS of ~8,300 TPS with 20M)
– .org: ~9.3M names, peaks at ~1,400 TPS (projected peak TPS of ~3,100 with 20M)
After performing this analysis the projected TPS for .com was still the largest value.
ARI understand the limitations of this method but it serves as a best estimate of probable tx load. ARI has built overcapacity of resources to account for limitations of this method, however as numbers are more conservative than real world observations, we are confident this capacity is sufficient.
.SUCKS is projected to reach 10049 domains at its peak volume and will generate 7.1624 EPP TPS. This will consume 0.05116% of the resources of the SRS infrastructure. As is evident ARI’s SRS can easily accommodate .SUCKS’s growth plans. See attachment ‘Q24 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI expects to provide Registry services to 100 TLDs and a total of 12M domains by end of 2014. With all the TLDs and domains combined, ARI’s SRS infrastructure will be 60% utilized. The SRS infrastructure capacity can be easily scaled as described in Q32
ARI benchmarked their SRS infrastructure and used the results to calculate the required computing resources for each of the tiers within the architecture; allowing ARI to accurately estimate the required CPU, IOPS, storage and memory requirements for each server, and the network bandwidth & packet throughput requirements for the anticipated traffic. These capacity numbers were then doubled to account for unanticipated traffic spikes, errors in predictions, and headroom for growth. Despite doubling numbers, effective estimated capacity is still reported as 20M. The technical resource allocations are explored in Q32.

3 SRS ARCHITECTURE
ARI’s SRS has the following major components:
– Network Infrastructure
– EPP Application Servers
– SRS Web Interface Application Servers
– SRS Database
Attachment ‘Q24 – SRS.pdf’ shows the SRS systems architecture and data flows. Detail on this architecture is in our response to Q32. ARI provides two distinct interfaces to the SRS: EPP and SRS Web. Registrar SRS traffic enters the ARI network via the redundant Internet link and passes (via the firewall) to the relevant application server for the requested service (EPP or SRS Web). ARI’s EPP interface sustains high volume and throughput domain provisioning transactions for a large number of concurrent Registrar connections. ARI’s SRS Web interface provides an alternative to EPP with a presentation centric interface and provides reporting and verification features additional to those provided by the EPP interface.

3.1 EPP
ARI’s EPP application server is based on EPP as defined in RFCs 5730 – 5734. Registrars send XML based transactions to a load balanced EPP interface which forwards to one of the EPP application servers. The EPP application server then processes the XML and converts the request into database calls that retrieve or modify registry objects in the SRS database. The EPP application server tier comprises of three independent servers with dedicated connections to the registry database. Failure of any one of these servers will cause Registrar connections to automatically re-establish with one of the remaining servers. Additional EPP application servers can be added easily without any downtime. All EPP servers accept EPP both IPv4 & IPv6.

3.2 SRS Web
The SRS Web application server is a Java web application. Registrars connect via the load balancer to a secure HTTP listener running on the web servers. The SRS web application converts HTTPs requests into database calls which query or update objects in the SRS database. The SRS Web application server tier consists of two independent servers that connect to the database via JDBC. If one of these servers is unavailable the load balancer re-routes requests to the surviving server. Additional servers can be added easily without any downtime. These servers accept both IPv4 & IPv6.

3.3 SRS Database
The SRS database provides persistent storage for domains and supporting objects. It offers a secure way of storing and retrieving objects provisioned within the SRS and is built on the Oracle 11g Enterprise Edition RDBMS. The SRS Database tier consists of four servers clustered using Oracle Real Application Clusters (RAC). In the event of failure of a database server, RAC will transparently transition its client connections to a surviving database host. Additional servers can be added easily without any downtime.

3.4 Number of Servers
EPP Servers – The EPP cluster consists of 3 servers that can more than handle the anticipated 20M domains. .SUCKS will utilize 0.05116% of this capacity at its peak volume. As the utilisation increases ARI will add additional servers ensuring the utilisation doesn’t exceed 50% of total capacity. Adding a new server to the cluster can be done live without downtime.
SRS Web Servers – The SRS Web cluster consists of 2 servers that can more than handle the anticipated 20M domains. .SUCKS will utilize 0.05116% of this capacity at its peak volume. As the utilisation increases ARI will add additional servers ensuring the utilisation doesn’t exceed 50% of total capacity. Adding a new server to the cluster can be done live without downtime.
SRS DB Servers – The SRS DB cluster consists of 4 servers that can more than handle the anticipated 20M domains. .SUCKS will utilize 0.05116% of this capacity at its peak volume. As the utilisation increases ARI will add additional servers ensuring the total utilisation doesn’t exceed 50% of total capacity. Adding a new server to the cluster can be done live without downtime.

3.5 SRS Security
ARI adopts a multi-layered security solution to protect the SRS. An industry leading firewall is deployed behind the edge router and is configured to only allow traffic on the minimum required ports and protocols. Access to the ARI EPP service is restricted to a list of known Registrar IPs.
An Intrusion Detection device is in-line with the firewall to monitor and detect suspicious activity.
All servers are configured with restrictive host based firewalls, intrusion detection, and SELinux. Direct root access to these servers is disabled and all access is audited and logged centrally.
The SRS database is secured by removal of non-essential features and accounts, and ensuring all remaining accounts have strong passwords. All database accounts are assigned the minimum privileges required to execute their business function.
All operating system, database, and network device accounts are subject to strict password management controls such as validity & complexity requirements.
Registrar access to the SRS via EPP or the Web interface is authenticated and secured with multi-factor authentication (NIST Level 3) and digital assertion as follows:
– Registrar’s source IP must be allowed by the front-end firewalls. This source IP is received from the Registrar via a secure communication channel from within the SRS Web interface
– Registrar must use a digital certificate provided by ARI
– Registrar must use authentication credentials that are provided by encrypted email
All communication between the Registrar and the SRS is encrypted using at least 128 bit encryption which been designated as ‘Acceptable’ till ‘2031 and beyond’ by NIST Special Publication 800-57.

3.6 SRS High Availability
SRS availability is of paramount. Downtime is eliminated or minimised where possible. The infrastructure contains no single points of failure. N+1 redundancy is used as a minimum, which not only protects against unplanned downtime but also allows ARI to execute maintenance without impacting service.
Redundancy is provided in the network with hot standby devices & multiple links between devices. Failure of any networking component is transparent to Registrar connections.
N+N redundancy is provided in the EPP and SRS Web application server tiers by the deployment of multiple independent servers grouped together as part of a load-balancing scheme. If a server fails the load balancer routes requests to the remaining servers.
N+N redundancy is provided in the database tier by the use of Oracle Real Application Cluster technology. This delivers active⁄active clustering via shared storage. This insulates Registrars from database server failure.
Complete SRS site failure is mitigated by the maintenance of a remote standby site – a duplicate of the primary site ready to be the primary if required.
The standby site database is replicated using real time transaction replication from the main database using Oracle Data Guard physical standby. If required the Data Guard database can be activated quickly and service resumes at the standby site.

3.7 SRS Scalability
ARI’s SRS scales efficiently. At the application server level, additional computing resource can be brought on-line rapidly by deploying a new server online. During benchmarking this has shown near linear.
The database can be scaled horizontally by adding a new cluster node into the RAC cluster online. This can be achieved without disruption to connections. The SRS has demonstrated over 80% scaling at the database level, but due to the distributed locking nature of Oracle RAC, returns are expected to diminish as the number of servers approaches double digits. To combat this ARI ensures that when the cluster is ‘scaled’ more powerful server equipment is added rather than that equal to the current members. Capacity can be added to the SAN at any time without downtime increasing storage and IOPs.

3.8 SRS Inter-operability and Data Synchronisation
The SRS interfaces with a number of related registry systems as part of normal operations.

3.8.1 DNS Update
Changes made in the SRS are propagated to the DNS via an ARI proprietary DNS Update process. This process runs on the ‘hidden’ primary master nameserver and waits on a queue. It is notified when the business logic inserts changes into the queue for processing. The DNS Update process reads these queue entries and converts them into DNS update (RFC2136) commands that are sent to the nameserver. The process of synchronising changes to SRS data to the DNS occurs in real-time.

3.8.2 WhoIs
The provisioned data supporting the SRS satisfies WhoIs queries. Thus the WhoIs and SRS share data sets and the WhoIs is instantaneously updated. Under normal operating conditions the WhoIs service is provided by the infrastructure at the secondary site in order to segregate the load and protect SRS from WhoIs demand (and vice versa). WhoIs queries that hit the standby site will query data stored in the standby database – maintained in near real-time using Oracle Active Data Guard. If complete site failure occurs WhoIs and SRS can temporarily share the same operations centre at the same site (capacity numbers are calculated for this).

3.8.3 Escrow
A daily Escrow extract process executes on the database server via a dedicated database account with restricted read-only access. The results are then transferred to the local Escrow Communications server by SSH.

4 OPERATIONAL PLAN
ARI follow defined policies⁄procedures that have developed over time by running critical registry systems. Some principals captured by these are:
– Conduct all changes & upgrades under strict and well-practised change control procedures
– test, test and test again
– Maintain Staging environments as close as possible to production infrastructure⁄configuration
– Eliminate all single points of failure
– Conduct regular security reviews & audits
– Maintain team knowledge & experience via skills transfer⁄training
– Replace hardware when no longer supported by vendor
– Maintain spare hardware for all critical components
– Execute regular restore tests of all backups
– Conduct regular capacity planning exercises
– Monitor everything from multiple places but ensure monitoring is not ‘chatty’
– Employ best of breed hardware & software products & frameworks (such as ITIL, ISO27001 and Prince2)
– Maintain two distinct OT&E environments to support pre-production testing for Registrars

5 SLA, RELIABILITY & COMPLIANCE
ARI’s SRS adheres to and goes beyond the scope of Specification 6 and Specification 10 of the Registry Agreement. ARI’s EPP service is XML compliant and XML Namespace aware. It complies with the EPP protocol defined in RFC5730, and the object mappings for domain, hosts & contacts are compliant with RFC 5731, 5732 & 5733 respectively. The transport over TCP is compliant with RFC5734. The service also complies with official extensions to support DNSSEC, RFC5910, & Redemption Grace Period, RFC 3915.
ARI’s SRS is sized to sustain a peak transaction rate of 14,000 TPS while meeting strict internal Operational Level Agreements (OLAs). The monthly-based OLAs below are more stringent than those in Specification 10 (Section 2).
EPP Service Availability: 100%
EPP Session Command Round Trip Time (RTT): 〈=1000ms for 95% of commands
EPP Query Command Round Trip Time (RTT): 〈=500ms for 95% of commands
EPP Transform Command Round Trip Time (RTT): 〈=1000ms for 95% of commands
SRS Web Interface Service Availability: 99.9%
ARI measure the elapsed time of every query, transform and session EPP transaction, and calculate the percentage of commands that fall within OLA on a periodic basis. If percentage value falls below configured thresholds on-call personnel are alerted.
SRS availability is measured by ARI’s monitoring system which polls both the EPP and SRS Web services status. These checks are implemented as full end to end monitoring scripts that mimic user interaction, providing a true representation of availability. These ‘scripts’ are executed from external locations on the Internet. 

6 RESOURCES
This function will be performed by ARI. ARI staff are industry leading experts in domain name registries with the experience and knowledge to deliver outstanding SRS performance.
The SRS is designed, built, operated and supported by the following ARI departments:
– Products and Consulting Team (7 staff)
– Production Support Group (27 staff)
– Development Team (11 staff)
A detailed list of the departments, roles and responsibilities in ARI is provided in attachment ‘Q24 – ARI Background & Roles.pdf’. This attachment describes the functions of the teams and the number and nature of staff within.
The number of resources required to design, build, operate and support the SRS does not vary significantly with, and is not linearly proportional to, the number or size of TLDs that ARI provides registry services to.
ARI provides registry backend services to 5 TLDs and has a vast experience in estimating the number of resources required to support a SRS.
Based on past experience ARI estimates that the existing staff is adequate to support an SRS that supporting at least 50M domains. Since .SUCKS projects 0.05116% domains, 0.0205% of these resources are allocated to .SUCKS. See attachment ‘Q24 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI protects against loss of critical staff by employing multiple people in each role. Staff members have a primary role plus a secondary role for protection against personnel absence. Additionally ARI can scale resources as required, trained resources can be added to any of the teams with a 2 month lead time.
The Products and Consulting team is responsible for product management of the SRS solution including working with clients and the industry to identify new features or changes required. The team consists of:
– 1 Products and Consulting Manager
– 1 Product Manager
– 1 Technical Product Manager
– 4 Domain Name Industry Consultants
The Production Support Group (PSG) is responsible for the design, deployment and maintenance of the SRS infrastructure including capacity planning and monitoring as well as security aspects – ensuring the SRS services are available and performing at the appropriate level and operating correctly. The team consists of:
– Production Support Manager
– Service Desk:
 – 1 Level 1 Support Team Lead
 – 8 Customer Support Representatives (Level 1 support)
 – 1 Level 2 Support Team Lead
 – 4 Registry Specialists (Level 2 support)
– Operations (Level 3 support):
 – 1 Operations Team Lead
 – 2 Systems Administrators
 – 2 Database Administrators
 – 2 Network Engineers
– Implementation:
 – 1 Project Manager
 – 2 Systems Administrators
 – 1 Database Administrator
 – 1 Network Engineer
The development team is responsible for implementing changes and new features into the SRS as well as bug fixing and complex issue diagnosis. The team consists of:
– 1 Development Manager
– 2 Business Analysts
– 6 Developers
– 2 Quality Analysts
These resources sufficiently accommodate the needs of .SUCKS, and are included in ARI’s fees as described in our Financial responses.

We have engaged ARI Registry Services (ARI) to deliver services for .SUCKS. ARI provide registry services for a number of TLDs including the .au ccTLD. For more background information on ARI please see the attachment ‘Q25 – ARI Background & Roles.pdf’. This response describes the Extensible Provisioning Protocol (EPP) interface as implemented by ARI.

1 INTRODUCTION

ARI’s EPP service is XML compliant and XML Namespace aware. The service complies with the EPP protocol defined in RFC5730, and the object mappings for domain, hosts and contacts are compliant with RFC5731-3 respectively. The transport over TCP is implemented in compliance with RFC5734. The service also complies with the official extensions to support DNSSEC, RFC5910 and Redemption Grace Period, RFC3915. ARI implemented EPP draft version 0.6 in 2002, then migrated to EPP RFC 1.0 on its publishing in 2004. The system has operated live since 2002 in the .au ccTLD.
Descriptions in this response follow the terminology used in the EPP RFCs. When referring to the software involved in the process, ARI’s EPP interface is called the server, and the software used by Registrars is called the client.

2 TRANSPORT LAYER

The ARI EPP service implements the RFC5734 – EPP Transport over TCP. Connections are allowed using TLSv1 encryption, optionally supporting SSLv2 Hello for compatibility with legacy clients. AES cipher suites for TLS as described in RFC3268 are the only ones allowed.

2.1 Authentication
Registrar access to the EPP interface is authenticated and secured with multi-factor authentication (NIST Level 3) and digital assertion as follows. Registrars must:
– present a certificate, during TLS negotiation, signed by the ARI Certificate Authority (CA). The server returns a certificate also signed by the ARI CA. Not presenting a valid certificate results in session termination. ARI requires that the Common Name in the subject field of the certificate identifies the Registrar.
– originate connections from an IP address that is known to be assigned to the Registrar with that Common Name.
– Registrar must use authentication credentials provided to the Registrar via encrypted email
– Registrars aren’t able to exceed a fixed number of concurrent connections. The connection limit is prearranged and designed to prevent abuse of Registrars’ systems from affecting the Registry. The limit is set to reasonable levels for each Registrar, but can be increased to ensure legitimate traffic is unaffected. If any of the above conditions aren’t met the connection is terminated.
All communication between the Registrars and the EPP service is encrypted using at least 128 bit encryption which been designated as ‘Acceptable’ till ‘2031 and beyond’ by NIST Special Publication 800-57.

2.3 Connection Close
The server may close the connection as a result of a logout, an error where the state of the connection is indeterminate, or after a timeout. Timeout occurs where no complete EPP message is received on the connection for 10 minutes.

3 EPP PROTOCOL

This section describes the interface relating to the EPP protocol described in RFC5730. This includes session management, poll message functionality and object mappings for domains, hosts and contacts.

3.1 Session Management
Session management refers to login and logout commands, used to authenticate and end a session with the SRS. The Login command is used to establish a session between the client and the server. This command succeeds when:
– The username supplied matches the Common Name in the digital certificate used in establishing the TLS session.
– The provided password is valid for the user.
– The user’s access to the system isn’t suspended.
The Logout command is used to end an active session. On processing a logout the server closes the underlying connection. The Hello command can be used as a session keep-alive mechanism.

3.2 Service Messages
Offline notifications pertaining to certain events are stored in a queue. The client is responsible for polling this queue for new messages and to acknowledge read messages. Messages include notification about server modification of sponsored objects, transfer operations, and balance thresholds.

4 EPP OBJECT MAPPINGS

This section covers the interface for the 3 core EPP objects; domain, host and contact objects, as per RFC5731, 5732, & 5733 respectively.

The EPP domain, contact and host object mapping describes an interface for the check, info, create, delete, renew (domain only), transfer (domain & contact only) and update commands. For domain objects the server doesn’t support the use of host attributes as described by RFC5731, but rather uses host objects as described by RFC5731 and RFC5732. Details of each command are:
– check command: checks availability of 1 or more domain, contact or host objects in the SRS. Domain names will be shown as unavailable if in use, invalid or reserved, other objects will be unavailable if in use or invalid.
– info command: retrieves the information of an object provisioned in the SRS. Full information is returned to the sponsoring client or any client that provides authorisation information for the object. Non-sponsoring clients are returned partial information (no more than is available in the WhoIs).
– create command: provisions objects in the SRS. To ascertain whether an object is available for provisioning, the same rules for the check command apply.
– delete command: begins the process of removing an object from the SRS. Domain names transition into the redemption period and any applicable grace periods are applied. Domain names within the Add Grace Period are purged immediately. All other objects are purged immediately if they are not linked.
– renew command (domain only): extends the registration period of a domain name. The renewal period must be between 1 to 10 years inclusive and the current remaining registration period, plus the amount requested in the renewal mustn’t exceed 10 years.
– transfer command (domain and contact only): provides several operations for the management of the transfer of object sponsorship between clients. Clients that provide correct authorisation information for the object can request transfers. Domain names may be rejected from transfer within 60 days of creation or last transfer. The requesting client may cancel the transfer, or the sponsoring client may reject or approve the transfer. Both the gaining and losing clients may query the status of the current pending or last completed transfer.
– update command: updates authorisation information, delegation information (domains), and registration data pertaining to an object.

5 NON-PROPRIETARY EPP MAPPINGS

ARI’s EPP service implements 2 non-proprietary EPP mappings, to support the required domain name lifecycle and to provide & manage DNSSEC information. The relevant schema documents aren’t provided as they are published as RFCs in the RFC repository.

5.1 Grace Period Mapping
The Domain Registry Grace Period Mapping for the Extensible Provisioning Protocol (as per RFC 3915) is used to support the domain name lifecycle as per existing TLDs. The update command is extended by the restore command to facilitate the restoration of previously deleted domains in the redemption period. This command defines 2 operations, request & report, described here:
– Request operation: requests the restoration of a domain.
– Report operation: completes the restoration by specifying the information supporting the restoration of the domain. The restore report must include a copy of the WhoIs information at both the time the domain was deleted & restored, including the restore reason.

5.2 DNSSEC Mapping
The Domain Name System (DNS) Security Extensions Mapping for EPP, as per RFC5910, is used to support the provisioning of DNS Security Extensions. ARI requires clients use the Key Data interface. Clients may associate a maximum of 4 keys per domain. The registry system generates the corresponding DS data using the SHA-256 digest algorithm for the domain and any active variant domains.
ARI is aware of issues DNSSEC causes when transferring DNS providers – a transfer of Registrar usually means a change in DNS provider. DNSSEC key data won’t be removed from the SRS or the DNS if a transfer occurs. It is the responsibility of and requires the cooperation of the registrant, Registrars, and DNS providers, to provide a seamless transition. ARI observes progress with this issue and implements industry agreed solutions as available. DNSSEC information is included in info responses when the secDNS namespace in login.

6 PROPRIETARY MAPPING

The registry system supports 3 additional EPP extensions where no published standard for the required functionality exists. Developed to conform to the requirements specified in RFC3735, these extensions include the provisioning of Internationalised Domain Names and domain name variants, and the association of arbitrary data with a domain name. These 3 extensions are introduced below, and further described in the attached schema documentation.

6.1 Internationalised Domain Names
ARI has developed an extension to facilitate the registration and management of Internationalised Domain Names as per RFCs 5890-5893 (collectively known as the IDNA 2008 protocol). This extension extends the domain create command and the info response.
The create command is extended to capture the language table identifier that identifies the corresponding IDN language table for the domain name. Additionally the extension requires the Unicode form to avoid an inconsistency with DNS-form, as per RFC 5891.
The domain info command is extended to identify the language tag and Unicode form provided in the initial create command. This information is disclosed to all querying clients that provided the extension namespace at login. This extension is documented in the attachment ‘Q25 – idnadomain-1.0.pdf’.

6.2 Variant
ARI has developed an extension to facilitate the management of Domain Name variants. This extension extends the domain update command and the domain create and info responses. The domain update command is extended to allow the addition (activation) and removal (de-activation) of domain name variants subject to registry operator policy.
The domain create and info responses are extended to return the list of activated domain name variants. This information is disclosed to all querying clients that provided the extension namespace at login. The extension is documented in the attachment ‘Q25 – variant-1.1.pdf’.

6.3 Key-Value
ARI has developed an extension to facilitate the transport of arbitrary data between clients and the SRS without the need for developing EPP Extensions for each specific use-case. This extension extends the domain create and domain update transform commands and the domain info query command. This extension is documented in the attachment ‘Q25 – kv-1.0.pdf’.

7 ADDITIONAL SECURITY

The registry system provides additional mechanisms to support a robust interface. The use of command rate limiting enables the registry to respond to and withstand erroneous volumes of commands, while a user permission model provides fine-grained access to the EPP interface. These 2 mechanisms are described below.

7.1 Rate Limiting
The registry system supports command and global rate limits using a token-bucket algorithm. Limits apply to each connection to ensure fair and equitable use by all. Clients that exceed limits receive a command failed response message indicating breach of the limit.

7.2 User Permission Model
The registry system supports a fine-grained permission model controlling access to each specific command. By default, clients receive access to all functionality; however it is possible to remove access to a specific command in response to abuse or threat to stability of the system. Clients that attempt a command they have lost permission to execute, receive an EPP command failed response indicating loss of authorisation.

8 COMPLIANCE

Compliance with EPP RFCs is achieved through design and quality assurance (QA). The EPP interface was designed to validate all incoming messages against the respective XML Schema syntax. The XML Schema is copied directly from the relevant RFCs to avoid any ambiguity on version used. Inbound messages that are either malformed XML or invalid are rejected with a 2400 response. Outbound messages are validated against the XML Schema, and if an invalid response is generated, it is replaced with a known valid pre-composed 2400 response, and logged for later debugging.
A QA process provides confidence that changes don’t result in regressions in the interface. Automated build processes execute test suites that ensure every facet of the EPP service (including malformed input, commands sequencing and synchronisation, and boundary values) is covered and compliant with RFCs and the EPP service specification. These tests are executed prior to committing code and automatically nightly. The final deliverable is packaged and tested again to ensure no defects were introduced in the packaging process.
New versions of the EPP Service follow a deployment schedule. The new version is deployed into an OT&E environment for Registrar integration testing. Registrars are encouraged during this stage to test their systems operate correctly. After a fixed time in OT&E without issue, new versions are scheduled for production deployment. This ensures incompatibilities with RFCs that made it through QA processes are detected in test environments prior reaching production.
ARI surveys Registrars for information about the EPP client toolkit. These surveys indicated that while many Registrars use ARI toolkits, several Registrars use either their own or that from another registry. The ability for Registrars to integrate with the ARI EPP service without using the supplied toolkit indicates the service is compliant with RFCs.
ARI is committed to providing an EPP service that integrates with third party toolkits and as such tests are conducted using said toolkits. Any issues identified during testing fall into the following categories:
– Third-party toolkit not compliant with EPP
– EPP service not compliant with EPP
– Both third-party toolkit and EPP service are compliant, however another operational issue causes an issue
Defects are raised and change management processes are followed. Change requests may also be raised to promote integration of third-party toolkits and to meet common practice.

9 CAPACITY

.SUCKS is projected to reach 10049 domains at its peak volume and will generate 7.1624 EPP TPS. This will consume 0.05116% of the EPP resources. ARI’s SRS can easily accommodate .SUCKS. This was described in considerable detail in the capacity section of question 24.

10 RESOURCES

This function will be performed by ARI. ARI provides a technical support team to support Registrars and also provides Registrars with a tool kit (in Java and C++) implementing the EPP protocol. Normal operations for all registry services are managed by ARI’s Production Support Group (PSG), who ensure the EPP server is available and performing appropriately.
Faults relating to connections with or functionality of the EPP server are managed by PSG. ARI monitors EPP availability and functionality as part of its monitoring practices, and ensures PSG staff are available to receive fault reports from Registrars any time. PSG has the appropriate network, Unix and application (EPP and load balancing) knowledge to ensure the EPP service remains accessible and performs as required. These ARI departments support EPP:
– Products and Consulting Team (7 staff)
– Production Support Group (27 staff)
– Development Team (11 staff)
A detailed list of the departments, roles and responsibilities in ARI is provided as attachment ‘Q25 – ARI Background & Roles.pdf’. This attachment describes the functions of the above teams and the exact number and nature of staff within.
The number of resources required to design, build, operate and support the SRS does not vary significantly with, and is not linearly proportional to, the number or size of TLDs that ARI provides registry services to.
ARI provides registry backend services to 5 TLDs and has a wealth of experience in estimating the number of resources required to support a registry system.
Based on past experience ARI estimates that existing staff are adequate to support a registry system that supports in excess of 50M domains. Since .SUCKS projects 10049 domains, 0.0205% of these resources are allocated to .SUCKS. See attachment ‘Q25 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI protects against loss of critical staff by employing multiple people in each role. Staff members have a primary role plus a secondary role for protection against personnel absence. Additionally ARI can scale resources as required, trained resources can be added to any of the above teams with a 2-month lead time.

10.1 Team Details
The products and consulting team is responsible for product management of the EPP solution, and works with clients and industry to identify required system features or changes. The team consists of:
– 1 Products and Consulting Manager
– 1 Product Manager
– 1 Technical Product Manager
– 4 Domain Name Industry Consultants
The Production Support Group (PSG) is responsible for the design, deployment and maintenance of the EPP infrastructure including capacity planning, monitoring, and security. This team ensures the EPP services are available and performing appropriately. The team consists of:
– Production Support Manager
– Service Desk:
 – 1 Level 1 Support Team Lead
 – 8 Customer Support Representatives (Level 1 support)
 – 1 Level 2 Support Team Lead
 – 4 Registry Specialists (Level 2 support)
– Operations (Level 3 support):
 – 1 Operations Team Lead
 – 2 Systems Administrators
 – 2 Database Administrators
 – 2 Network Engineers
– Implementation:
 – 1 Project Manager
 – 2 Systems Administrators
 – 1 Database Administrator
 – 1 Network Engineer
The development team is responsible for EPP changes and features, bug fixes and issue diagnosis. The team consists of:
– 1 Development Manager
– 2 Business Analysts
– 6 Developers
– 2 Quality Analysts

These resources sufficiently accommodate the needs of .SUCKS, and are included in ARI’s fees as described in our financial responses

We have engaged ARI Registry Services (ARI) to deliver services for .SUCKS. ARI provide registry services for a number of TLDs including the .au ccTLD. For more background information on ARI please see the attachment ‘Q26 – ARI Background & Roles.pdf’. This response describes the WhoIs interface as implemented by ARI.

1 INTRODUCTION

ARI’s WhoIs service is for all domain names, contacts, nameservers and Registrars provisioned in the registry database. This response describes the port 43 and web interfaces of WhoIs, security controls to mitigate abuse, compliance with bulk access requirements for registration data, and the architecture delivering the service.

2 PORT 43 WHOIS SERVICE

WhoIs is on TCP port 43 in accordance with RFC3912. Requests are made in semi-free text format and ended by CR & LF. The server responds with a semi-free text format, terminating the response by connection close.
To support IDNs and Localised data we assume the query is encoded in UTF-8 and sends responses encoded in UTF-8. UTF-8 is backwards compatible with the ASCII charset and its use is consistent with the IETF policy on charsets as defined in BCP 18 [http:⁄⁄tools.ietf.org⁄html⁄bcp18].

2.1 Query Format
By default WhoIs searches domains. To facilitate the queries of other objects keywords must be used. Supported keywords are:
– Domain
– Host⁄Nameserver
– Contact
– Registrar
Keywords are case-insensitive. The rest of the input is the search string. Wildcard chars may be used in search strings to match zero or more chars (%), or match exactly one char(_). Wildcard chars must not be in the first 5 chars.

2.2 Response Format
The response follows a semi-structured format of object-specific data, followed by query-related meta-information, then a disclaimer.
The object-specific data is represented by key⁄value pairs, beginning with the key, followed by a colon and a space then the value terminated by an ASCII CR & LF. Where no object is found ‘No Data Found’ is returned.
The meta-information is used to identify data freshness and indicate when limits have been exceeded. It appears on one line within ‘〉〉〉’ and ‘〈〈〈’ chars.
The legal disclaimer is presented without leading comment marks wrapped at 72 chars. This format is consistent with that in the registry agreement.

2.3 Domain Data
Domain data is returned in response to a query with the keyword omitted, or with the ‘domain’ keyword. Domain queries return information on domains that are provisioned in the registry database.
The IDN domains may be specified in either the ASCII-compatible encoded form or the Unicode form. Clients are expected to perform any mappings, in conformance with relevant guidelines such as those specified in RFC5894 and UTS46.
Variant domains may be specified in the search string and WhoIs will match (using case-insensitive comparison) and return information for the primary registered domain.
For queries containing wildcard chars, if only one domain name is matched its details are returned, if more than one domain name is matched then the first 50 matched domain names are listed.

2.3.1 Internationalised Domain Names
The WhoIs response format, prescribed in Specification 4, does not provide a mechanism to identify active variant domain names. ARI will include active variant domain names in WhoIs responses until a common approach for handling and display of variant names is determined.

2.3.2 Reserved Domain Names
Domain names reserved from allocation will have a specific response that indicates the domain is not registered but also not available.

2.4 Nameserver Data
Nameserver data is returned in response to a query where the ‘nameserver’ or ‘host’ keywords have been used. Nameserver queries return information on hosts that are provisioned in the registry.
The search string for a nameserver query can be either a hostname or IP. Queries using the hostname produce one result unless wildcards are used. Queries using the IP produce one or more results depending on the number of hostnames that match that address. Queries for the hostname are matched case-insensitively.
The quad-dotted notation is expected for IPv4 and the RFC3513 – IPv6 Addressing Architecture format for IPv6. Wildcards cannot be used for IP queries.

2.5 Contact Data
Contact data is returned in response to a query where the ‘contact’ keyword was used. Contact queries return information on contacts that are provisioned in the registry.
The search string for a contact query is the contact identifier. Contact identifiers are matched using a case-insensitive comparison. Wildcards cannot be used.

2.6 Registrar Data
Registrar data is returned in response to a query where the ‘Registrar’ keyword was used. Registrar queries return information on Registrar objects that are provisioned in the registry.
The search string for a Registrar query can be name or IANA ID. Queries using the name or the IANA ID produce only one result. Queries for the name are matched using a case-insensitive comparison. Wildcards cannot be used.

2.7 Non-standard Data
The SRS supports domain-related data beyond that above. It may include information used to claim eligibility to participate in the sunrise process, or other arbitrary data collected using the Key-Value Mapping to the EPP. This information will be included in the WhoIs response after the last object-specific data field and before the meta-information.

3 WEB-BASED WHOIS SERVICE

WhoIs is also available via port 80 using HTTP, known as Web-based WhoIs. This interface provides identical query capabilities to the port 43 interface via an HTML form.

4 SECURITY CONTROLS

WhoIs has an in-built mechanism to blacklist malicious users for a specified duration. Blacklisted users are blocked by source IP address and receive a specific blacklisted notification instead of the normal WhoIs response.
Users may be blacklisted if ARI’s monitoring system determines excessive use. A whitelist is used to facilitate legitimate use by law enforcement agencies and other reputable entities.

5 BULK ACCESS

The registry system complies with the requirements for the Periodic Access to Thin Registration Data and Exceptional Access to Thick Registration Data as described in Specification 4.

5.1 Periodic Access to Thin Registration Data
ARI shall provide ICANN with Periodic Access to Thin Registration Data. The data will contain the following elements as specified by ICANN. The format of the data will be consistent with the format specified for Data Escrow. The Escrow Format prescribes an XML document encoded in UTF-8. The generated data will be verified to ensure that it is well formed and valid.
The data will be generated every Monday for transactions committed up to and on Sunday unless otherwise directed by ICANN. The generated file will be made available to ICANN using SFTP. Credentials, encryption material, and other parameters will be negotiated between ARI and ICANN using an out-of-band mechanism.

5.2 Exceptional Access to Thick Registration Data
If requested by ICANN, ARI shall provide exceptional access to thick registration data for a specified Registrar. The date will contain full information for the following objects:
– Domain names sponsored by the Registrar
– Hosts sponsored by the Registrar
– Contacts sponsored by the Registrar
– Contacts linked from domain names sponsored by the Registrar
As above the format of the data will be consistent with the format specified for Data Escrow. And will be made available to ICANN using SFTP.

6 CAPACITY

ARI’s WhoIs infrastructure is built to sustain 20M domain names. Based on ARI’s experience running a high volume ccTLD registry (.au) and industry analysis, ARI were able to calculate the conservative characteristics of a registry of this size.
Through conservative statistical analysis of the .au registry and data presented in the May 2011 ICANN reports for the .com & .net, .org, .mobi, .info, .biz and .asia [http:⁄⁄www.icann.org⁄en⁄resources⁄registries⁄reports] we know there is:
– An average of 30 SRS txs per domain, per month.
Which indicates an expected monthly transaction volume of 600M txs?
Through statistical analysis of the .au registry and backed up by the data published in the .net RFP responses [http:⁄⁄archive.icann.org⁄en⁄tlds⁄net-rfp⁄net-rfp-public-comments.htm] we also know:
– The peak daily transactions is 6% of the monthly total
– The peak 5 min is 5% of the peak day
Thus we expect a peak WhoIs tx rate of WhoIs 6,000 TPS.
For perspective on the conservativeness of this, the following numbers were taken from data in the May 2011 ICANN reports referenced above:
– .info ~7.8M domain names, peaks at ~1,300 TPS (projected peak TPS of ~3,400 with 20M names).
– .mobi ~1M domain names, peaks at ~150 TPS (projected peak TPS of ~3,000 TPS with 20M names).
– .org ~9.3M domain names, peaks at ~1,300 TPS (projected peak TPS of ~2,800 with 20M names).
ARI understand the limitations of these calculations but they serve as a best estimate of probable transaction load. ARI has built overcapacity of resources to account for limitations of this method, however as conservative numbers were used and these are greater than real world observations, we are confident these capacity numbers are sufficient.
ARI benchmarked their WhoIs infrastructure and used the results to calculate the required computing resources for each of the tiers within the WhoIs architecture – allowing ARI to accurately estimate the required CPU, IOPS, storage and memory requirements for each server within the architecture, as well as the network bandwidth and packet throughput requirements for the anticipated WhoIs traffic. These capacity numbers were then doubled to account for unanticipated traffic spikes, errors in predictions and head room for growth. The technical resource allocations are explored in question 32.
.SUCKS is projected to reach 10049 domains at its peak volume and will generate 3.0696 WhoIs transactions per second. This will consume 0.05116% of the resources of the WhoIs infrastructure. As is evident ARI’s WhoIs can easily accommodate .SUCKS’s growth plans. See attachment ‘Q26 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI expects to provide Registry services to 100 TLDs and a total of 12M domains by end of 2014. With all the TLDs and domains combined, ARI’s WhoIs infrastructure will be only 60% utilized. The WhoIs infrastructure capacity can also be easily scaled as described in question 32

7 ARCHITECTURE

WhoIs uses a database separate from the SRS database as it operates from the secondary site such that network and database resources are decoupled from the operation of the SRS. Oracle Data Guard ensures the two databases are synchronised in real-time. The WhoIs service is operated live from the SRS ‘failover’ site, with the SRS ‘primary’ site serving as the ‘failover’ site for the WhoIs service. Both sites have enough capacity to run both services simultaneously, however by separating them, in normal operating modes headroom above the already over provisioned capacity is available. The architecture and data flow diagrams are described below and shown in the attachment ‘Q26 – WhoIs.pdf’.
Traffic enters the network from the Internet through border routers and then firewalls. All traffic destined for this service except for TCP ports 43, 80 & 443 is blocked. Load balancers forward the request to one of the application servers running ARI built WhoIs software. Each server is connected to the database cluster through another firewall further restricting access to the. Each server uses a restricted Oracle user that has read only access to the registry data and can only access the data that is relevant to the WhoIs queries. This ensures that in the unlikely event of an application server compromise the effects are limited.
All components are configured and provisioned to provide N+1 redundancy. Multiple Internet providers with separate upstream bandwidth suppliers are used. At least one additional component of all hardware exists, enabling maintenance without downtime. This configuration provides a service exceeding the availability requirements in Specification 10.
The use of load balancing allows addition of application servers with no downtime. From a database perspective, the ability to scale is enabled by utilising Oracle RAC database clustering. The entire service, including routers, firewalls and application is IPv6 compatible and WhoIs is offered on both IPv4 and IPv6. Detail about this architecture is available in our response to Question 32.

7.1 Synchronisation
The WhoIs database is synchronised with the SRS database using Oracle Data Guard. Committed transactions in the SRS database are reflected in the WhoIs database in real-time. Should synchronisation break, WhoIs continues to operate with the latest available data until the issue is reconciled. The channel between the two sites consists of two independent dedicated point to point links as well as the Internet. Replication traffic flows via the dedicated links or if both links fail replication traffic flows over Internet tunnels.

7.2. Interconnectivity with Other Services
The WhoIs service is not directly interconnected with other registry services or systems. The software has been developed to provide the WhoIs service exclusively and retrieve response information from a database physically separate to the SRS transactional database. This database is updated as described in ‘Synchronisation’ above. Although for smaller system the WhoIs and SRS can be configured to use the same data store. The WhoIs servers log every request to a central repository that is logically separate from the WhoIs database. This repository is used for query counts, detection of data mining and statistical analysis on query trends.

7.3 IT and Infrastructure Resources
The WhoIs service is provided utilizing Cisco networking equipment, IBM servers & SAN. They are described in the attachment ‘Q26 – WhoIs.pdf’. For more information on the architecture including server specifications and database capabilities please see Questions 32 & 33.

8 COMPLIANCE

Compliance with WhoIs RFCs is achieved through design and QA. The WhoIs interface was designed to conform to the RFCs as documented and independent test cases have been developed.
QA processes provide confidence that any changes to the service don’t result in regression of the WhoIs. Automated build processes execute test suites that ensure every facet of the WhoIs service (including malformed input, commands sequencing and synchronisation, and boundary values) is covered and compliant with RFCs. These tests are executed prior to the committing of code and nightly. The final deliverable is packaged and tested again to ensure no defects were introduced in the packaging of the software.
New versions of the WhoIs follow a deployment schedule. The new version is deployed into an OT&E environment for Registrar integration testing. Registrars who rely on WhoIs functionality are encouraged during this stage to test their systems operate without change. After a fixed time in OT&E without issue, new versions are scheduled for production deployment. This ensures incompatibilities with RFCs that made it through QA processes are detected in test environments prior to reaching production.
ARI is committed to providing a WhoIs service that integrates with third party tools and as such tests are conducted using these tools such as jWhoIs, a popular UNIX command line WhoIs client. Any issues identified during integration fall into 1 of the following categories:
– Third-party tool not compliant with the WhoIs specification
– WhoIs service not compliant
– Both third-party tool and WhoIs service are compliant, however another operational issue causes a problem
Defects are raised and follow the change management. Change requests may also be raised to promote integration of third-party tools and to meet common practice.

9 RESOURCES

This function will be performed by ARI. The WhoIs system is supported by a number of ARI departments:
– Products and Consulting Team (7 staff)
– Production Support Group (27 staff)
– Development Team (11 staff)
– Legal, Abuse and Compliance Team (6 staff)
A detailed list of the departments, roles and responsibilities in ARI is provided as attachment ‘Q26 – ARI Background & Roles.pdf’. This attachment describes the functions of the above teams and the exact number and nature of staff within.
The number of resources required to design, build, operate and support the SRS does not vary significantly with, and is not linearly proportional to, the number or size of TLDs that ARI provides registry services to.
ARI provides registry backend services to 5 TLDs and has a wealth of experience in estimating the number of resources required to support a registry system.
Based on past experience ARI estimates that the existing staff is adequate to support a registry system that supports in excess of 50M domains. Since .SUCKS projects 10049 domains, 0.0205% of these resources are allocated to .SUCKS. See attachment ‘Q26 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI protects against loss of critical staff by employing multiple people in each role. Staff members have a primary role plus a secondary role for protection against personnel absence. Additionally ARI can scale resources as required. Additional trained resources can be added to any of the above teams with a 2 month lead time.
The products and consulting team is responsible for product management of the WhoIs solution including working with clients and the industry to identify new features or changes required to the system. The team consists of:
– 1 Products and Consulting Manager
– 1 Product Manager
– 1 Technical Product Manager
– 4 Domain Name Industry Consultants
ARI employ a development team responsible for the maintenance and continual improvement of the WhoIs software. The team consists of:
– 1 Development Manager
– 2 Business Analysts
– 6 Developers
– 2 Quality Analysts
ARI’s Production Support Team ensures the successful operation of the WhoIs system. The team comprises Database Administrators, Systems Administrators and Network Administrators. This team routinely checks and monitors bandwidth, disk and CPU usages to plan and respond to expected increases in the volume of queries, and perform maintenance of the system including security patches and failover and recovery testing. The team consists of:
– Production Support Manager
– Service Desk:
 – 1 Level 1 Support Team Lead
 – 8 Customer Support Representatives (Level 1 support)
 – 1 Level 2 Support Team Lead
 – 4 Registry Specialists (Level 2 support)
– Operations (Level 3 support)
 – 1 Operations Team Lead
 – 2 Systems Administrators
 – 2 Database Administrators
 – 2 Network Engineers
– Implementation
 – 1 Project Manager
 – 2 Systems Administrators
 – 1 Database Administrators
 – 1 Network Engineers
ARI’s registry provides abuse monitoring detection mechanisms to block data mining. ARI support staff may be contacted to remove blacklisted users during which they may be referred to the Legal, Abuse and Compliance Team for evaluation of their activities. Additionally the support team in conjunction with the Legal, Abuse and Compliance team administer requests for listing on the whitelist. The team consists of:
– 1 Legal Manager
– 1 Legal Counsel
– 4 Policy Compliance Officers
These resources sufficiently accommodate the needs of .SUCKS, and are included in ARI’s fees as described in our Financial responses.

We have engaged ARI Registry Services (ARI) to deliver services for .SUCKS. ARI provide registry services for a number of TLDs including the .au ccTLD. For more background information on ARI please see the attachment ‘Q27 – ARI Background & Roles.pdf’. This response describes the Registration Lifecycle as implemented by ARI.

1 INTRODUCTION

The lifecycle described matches current gTLD registries. All states, grace periods and transitions are supported by the EPP protocol as described in RFC5730 – 5734 & the Grace Period Mapping published in RFC3915. An overview is in attachment ‘Q27 – Registration Lifecycle.pdf’.

2 REGISTRATION PERIODS

The registry supports registration up to 10 years and renewals for 1 to 10 years. The total current validity period can’t exceed 10 years.
Transfers under part A of the ICANN Policy on Transfer of Registrations between Registrars (Adopted 7 November 2008) extend registration by 1 year. The period truncates to 10 years if required.

3 STATES

The states that a domain can exist in are: Registered, Pending Transfer, Redemption, Pending Restore & Pending Delete.
All domain name statuses (RFC3915, 5730-5734 and 5910) are covered below

3.1 Registered
EPP Status: ok
In DNS: Yes
Allowed Operations: Update, Renew, Transfer (request) & Delete
The default state of a domain – no pending operations. The sponsoring Registrar may update the domain.

3.2 Pending Transfer
EPP Status: pendingTransfer
In DNS: Yes
Allowed Operations: Transfer (cancel, reject, approve)
Another Registrar has requested transfer of the domain and it is not yet completed All transform operations, other than those to cancel, reject, or approve the transfer are rejected.

3.3 Redemption
EPP Status: pendingDelete
RGP Status: redemptionPeriod
In DNS: No
Allowed Operations: Restore (request)
Domain has been deleted. The sponsor may request restoration of the domain. The domain continues to be withheld from the DNS unless it is restored. No transform operations other than restore are allowed.

3.4 Pending Restore
EPP Status: pendingDelete
RGP Status: pendingRestore
In DNS: Yes
Allowed Operations: Restore (report)
A restore request is pending. The sponsor must submit a restore report. The domain is provisioned the DNS. No transform operations other than the restore report are allowed.

3.5 Pending Delete
EPP Status: pendingDelete
RGP Status: pendingDelete
In DNS: No
Allowed Operations: None
The Redemption Grace Period has lapsed and the domain is pending purge from the registry. This state prohibits the sponsor from updating, restoring or modifying the domain. This status applies for 5 days. At the end of this period the domain is purged from the database and made available for registration.

4 GRACE PERIODS

The registry system supports 4 grace periods: add, renew, auto-renew, and transfer, described below with consideration for overlap of grace periods. States described here are additional to those above.

4.1 Add Grace Period
Length: 5 days
RGP Status: addPeriod
Allows for the no-cost cancellation of a domain registrations resulting from typing mistakes and other errors by Registrars and registrants – beginning on the creation of a domain and lasting for 5 days. When the following operations are performed during this period these rules apply:
– Delete: the sponsoring Registrar, who must have created the domain, may delete the domain and receive a refund. The domain is deleted with immediate effect. The refund is subject to the Add Grace Period Limits consensus policy. Excess deletions over 50 or 10% of creates (whichever is greater), are not subject to a refund, except in extraordinary circumstances.
– Renew: the sponsor may renew the domain but does not receive any refund for the initial registration fee. The Registrar is charged for the renewal operation. The total period for the domain is the sum of the initial period in the create and any renewal term, limited to a 10 year maximum.
– Transfer: Under ICANN policy a transfer can’t occur during the Add Grace Period or at any other time in the first 60 days after the initial registration. The registry system enforces this, rejecting such requests.
– Bulk Transfers: Under Part B of the ICANN Policy on Transfer of Registrations between Registrars, a bulk transfer can occur during the Add Grace Period. Any bulk transfer causes the Add Grace Period to not apply.
The Add Grace Period does not have any impact on other commands.

4.2 Renew Grace Period
Length: 5 days
RGP Status: renewPeriod
Allows the sponsoring Registrar to undo a renewal via the deletion of a domain – beginning on the receipt of a renewal command and lasting for 5 days. If any of the following operations are performed during this period these rules apply:
– Delete: the sponsoring Registrar, who must have initiated the renewal, may delete the domain and receive a renewal fee refund. The extension to the registration period caused by the preceding renew is reversed and unless the domain is also in the Add Grace Period, the domain enters the Redemption state. If also in the Add Grace Period it is deleted with immediate effect and availability for registration.
– Renew: the sponsoring Registrar, who must have performed the initial renew, can subsequently renew the domain again, causing a second independent Renewal Grace Period to start. The Registrar is charged for the operation and the total registration period for the domain is extended by the renewal term, limited to the 10 year maximum.
– Transfer: an approved transfer command ends the current Renew Grace Period without a refund and begins a Transfer Grace Period.
– Bulk Transfers: bulk transfers cause the Renew Grace Period to end without a refund, consequently registration periods are not changed.
The Renew Grace Period has no impact on other commands.

4.3 Auto-Renew Grace Period
Length: 45 days
RGP Status: autoRenewPeriod
Auto-Renew Grace Period allows for domains to remain in the DNS past registration expiration while giving adequate time for the sponsoring Registrar to obtain intention of renewal from the registrant.
This period begins on the expiration of the domain and lasts for 45 days. If any of the following are performed during this period these rules apply:
– Delete: the sponsoring Registrar, who must be the sponsor when the Auto-Renew Grace Period commenced, may delete the domain and receive an auto-renew fee refund. The registration period auto-renew extension is reversed and the domain enters the Redemption state.
– Renew: the sponsoring Registrar, who must be the sponsor when the auto-renew occurred, can renew the domain again causing an independent Renewal Grace Period to begin. The Registrar is charged and the registration period is extended by the renewal term, limited to the 10 year maximum.
– Transfer: an approved transfer command ends the current Auto-Renew Grace Period with a refund to the losing Registrar and begins a Transfer Grace Period. The registration period auto-renew extension is reversed and the registration is extended by the period specified in the transfer.
– Bulk Transfers: bulk transfers cause the Auto-Renew Grace Period to end without a refund consequently registration periods are not changed.
The Auto-Renew Grace Period does not have any impact on other commands.

4.4 Transfer Grace Period
Length: 5 days
RGP Status: transferPeriod
Transfer Grace Period allows the sponsoring Registrar to undo the registration period extension (due to a transfer command), via the deletion of a domain. This period begins on a transfer completion and lasts for 5 calendar days. If the following are performed during the period these rules apply:
– Delete: the sponsoring Registrar, who must have initiated the transfer, may delete the domain and receive a transfer fee refund. The extension to the registration period of the preceding transfer is reversed and the Redemption state is entered.
– Renew: the sponsoring Registrar can renew the domain thus causing an independent Renewal Grace Period to begin. The Registrar is charged and the registration period for the domain is extended by the renewal term, limited to the 10 year maximum.
– Transfer: under Part A of the ICANN Policy on Transfer of Registrations between Registrars a transfer may not occur during the 60 day period after transfer (except in special circumstances). The registry system enforces this – effects of transfer do not require consideration. Should a special situation require transfer back to the losing Registrar, this is dealt with by taking into account the specific situation. The registry system does not allow this without intervention by registry staff.
– Bulk Transfers: bulk transfers cause the Transfer Grace Period to end without a refund; consequently registration periods are not changed.
The Transfer Grace Period does not have any impact on other commands.

4.5 Redemption Grace Period
Length: 30 days
RGP Status: as described in Redemption state
Redemption Grace Period refers to the period of time the domain spends in the Redemption state, starting after a domain is deleted. The Redemption state description provides information on operations during this period.

4.6 Overlap of Grace Periods
The 4 possible overlapping grace periods are:
– Add Grace Period with 1 or more Renew Grace Periods.
– Renew Grace Period with 1 or more other Renew Grace Periods.
– Transfer Grace Period with 1 or more Renew Grace Periods.
– Auto-Renew Grace Period with 1 or more Renew Grace Periods.
These are treated independently with respect to timelines however action that is taken has the combined effects of all grace periods still current.

4.6.1 Transfer Clarification
If several billable operations, including a transfer, are performed on a domain and it is deleted in the operations’ grace periods, only those operations performed after⁄including the latest transfer are eligible for refund.

5 TRANSITIONS

5.1 Available 〉 Registered
Triggered by the receipt of a create command to register the domain. The sponsoring Registrar is charged for the creation amount. This transition begins the Add Grace Period.

5.2 Registered 〉 Pending Transfer
Triggered by the receipt of a request transfer command. The transfer must result in domain registration extension – the gaining Registrar is charged for the transfer. Requests to transfer the domain within 60 days of creation or a previous transfer are rejected. As per ‘4.4 Transfer Grace Period’, exceptions specified in ICANN’s Transfer Policy apply – dealt with individually.

5.3 Pending Transfer 〉 Registered
Triggered by 1 of 4 operations:
– Operation 1 (Cancel): during the Pending Transfer period the gaining Registrar may cancel the transfer by issuing a cancel transfer command. The gaining Registrar is refunded the transfer fee, the registration period remains unchanged and all existing grace periods at the time of transfer request remain in effect.
– Operation 2 (Reject): during the Pending Transfer period the losing Registrar may reject the transfer by issuing a reject transfer command. The gaining Registrar is refunded the transfer. The registration period remains unchanged and all grace periods existing at the time of transfer request remain in effect if not elapsed.
– Operation 3 (Approve): During the Pending Transfer period the losing Registrar may approve the transfer by issuing an approve transfer command. If the transfer was requested during the Auto-Renew Grace Period, the extension to the registration period is reversed and the losing Registrar is refunded the auto-renew. The registration period is extended by the amount specified in the transfer request. This begins the Transfer Grace Period.
– Operation 4 (Auto-Approve): If after 5 days, no action has been taken, the system approves the transfer. If the transfer was requested during the Auto-Renew Grace Period the extension to the registration period is reversed and the losing Registrar is refunded the auto-renew. The registration period is extended by the amount specified in the transfer request. This begins the Transfer Grace Period.

5.4 Registered 〉 Deleted
On receipt of a delete command if the domain is in the Add Grace Period, it is purged from the Database and immediately available for registration. Renew Grace Period may also be in effect.

5.5 Registered 〉 Redemption
On receipt of a delete command if the domain is not in the Add Grace Period, it transitions to the Redemption Period state and all grace periods in effect are considered.

5.6 Redemption 〉 Pending Restore
On receipt of a restore command if the Redemption Period has not lapsed, the domain transitions to the Pending Restore state. The domain is provisioned in the DNS. The sponsoring Registrar is charged a fee for the restore request.

5.7 Pending Restore 〉 Registered
During the Pending Restore period the sponsoring Registrar may complete the restore via a restore report containing the WhoIs information – submitted prior to the deletion, the WhoIs information at the time of the report, and the reason for the restoration.

5.8 Pending Restore 〉 Redemption
Seven calendar days after the transition to the Pending Restore state, if no restore report is received the domain transitions to the Redemption state, which begins a new redemption period. The domain is removed from the DNS. The restore has no refund.

5.9 Redemption 〉 Pending Delete
Thirty calendar days after the transition to the Redemption state, if no restore request is received the domain transitions to the Pending Delete state.

5.10 Pending Delete 〉 Deleted
Five calendar days after the transition to the Pending Delete state, the domain is removed from the Database and is immediately available for registration.

6 LOCKS

Locks may be applied to the domain to prevent specific operations occurring. The sponsoring Registrar may set the locks prefixed with ‘client’ while locks prefixed with ‘server’ are added and removed by the registry operator. Locks are added and removed independently but they can be combined to facilitate the enforcement of higher processes, such as ‘Registrar Lock’, and outcomes required as part of UDRP. All locks are compatible with EPP RFCs. The available locks are:
– clientDeleteProhibited, serverDeleteProhibited – Requests to delete the object are rejected
– clientHold, serverHold – DNS information is not published
– clientRenewProhibited, serverRenewProhibited – Requests to renew the object are rejected. Auto-renew is allowed
– clientTransferProhibited, serverTransferProhibited – Requests to transfer the object are rejected
– clientUpdateProhibited, serverUpdateProhibited – Requests to update the object are rejected, unless the update removes this status

7 SPECIAL CONSIDERATIONS

7.1 ICANN-Approved Bulk Transfers
ICANN-Approved Bulk Transfers do not follow the typical transfer lifecycle. Existing grace periods are invalidated and no refunds are credited to the losing Registrar. The prohibition of transfer period on domains created or transferred within 60 days does not apply.

7.2 Uniform Rapid Suspension
In the Uniform Rapid Suspension (URS) process, as described in the ‘gTLD Applicant Guidebook’ 11th January 2012, the following modification to the above processes is required.
Remedy allows for the addition of a year to the registration period, limited to the 10 year maximum. During this time no transform operations may be performed other than to restore the domain as allowed by Appeal. At the expiration of the registration period the domain is not automatically renewed, but proceeds to the Redemption state as per the lifecycle described above, and it is not eligible for restoration.

8 UPDATE⁄DNS

The update command does not impact the state of the domain through the Registration Lifecycle, however the command can be used to add and remove delegation information, which changes the DNS state of the domain.
A domain is required to have 2 or more nameservers published in the DNS. An update that results in a domain having less than 2 nameservers removes the domain from the DNS. An exception is when 1 nameserver remains assigned to a domain due to deletion of its other nameservers due to purge of their parent domain. The next update that modifies delegation information ends the exception and from then on the domain requires 2 nameservers be in the DNS.

9 RESOURCES

This function will be performed by ARI. ARI’s registry performs all time-based transitions automatically and enforces all other business rules – without requiring human resources for normal operation. If changes to the automatic behaviours or restrictions enforced by the policy system are required, ARI has a development team for this.
Domain Name Lifecycle aspects requiring human resources to manage are included in the ARI outsourcing include:
– Processing Add Grace Period exemptions as requested by Registrars.
– Processing restore reports provided by Registrars.
– Meeting the registry operator’s obligations under ICANN’s Transfer Dispute Policy.
– Performing exception processing in the case of approved transfers during the 60 day transfer prohibition window.
The Registration Lifecycle is designed, built, operated and supported by these ARI departments:
– Products and Consulting Team (7 staff)
– Legal, Abuse and Compliance Team (6 staff)
– Development Team (11 staff)
A detailed list of the departments, roles and responsibilities in ARI is provided as attachment ‘Q27 – ARI Background & Roles.pdf’. This attachment describes the functions of the above teams and the exact number and nature of staff within.
The number of resources required to design, build, operate and support the SRS does not vary significantly with, and is not linearly proportional to, the number or size of TLDs that ARI provides registry services to.
ARI provides registry backend services to 5 TLDs and has a wealth of experience in estimating the number of resources required to support a registry system.
Based on past experience ARI estimates that the existing staff is adequate to support a registry system that supports in excess of 50M domains. Since .SUCKS projects 10049 domains, 0.0205% of these resources are allocated to .SUCKS. See attachment ‘Q27 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI protects against loss of critical staff by employing multiple people in each role. Staff members have a primary role plus a secondary role for protection against personnel absence. Additionally ARI can scale resources as required. Additional trained resources can be added to any of the above teams with a 2 month lead time.
The Products and Consulting team is responsible for product management of the Registration Lifecycle, including working with clients and the industry to identify new features or changes required to the system. The team consists of:
– 1 Products and Consulting Manager
– 1 Product Manager
– 1 Technical Product Manager
– 4 Domain Name Industry Consultants
Most manual tasks fall to the Legal, Abuse and Compliance team, with staff experienced in development of policy for policy rich TLD environments. They have the required legal and industry background to perform this function. The team consists of:
– 1 Legal Manager
– 1 Legal Counsel
– 4 Policy Compliance Officers
The automated aspects of the Registration lifecycle are supported by ARI’s Domain Name Registry software. ARI has a development team for maintenance and improvement of the software. The team consist of:
– 1 Development Manager
– 2 Business Analysts
– 6 Developers
– 2 Quality Analysts
Information on these roles is in Resources in our response to Question 31. These resources sufficiently accommodate the needs of .SUCKS, and are included in ARI’s fees as described in our Financial responses.

We have engaged ARI Registry Services (ARI) to deliver services for .SUCKS. ARI provides registry services for a number of TLDs including the .au ccTLD. For more background information on ARI please see the attachment ‘Q28 – ARI Background & Roles.pdf’.

1 INTRODUCTION

The Registry will undertake a variety of steps to minimise abusive registrations and other activities in .SUCKS that have a negative impact on Internet users. We will utilise the ARI Anti-Abuse Service (AAS), which includes the implementation of the comprehensive .SUCKS Anti-Abuse Policy (RAAP). This policy, developed in consultation with ARI, clearly defines abusive behaviour, identifies particular types of abusive behaviour, and specifies the steps to be taken in responding to such behaviour.

2 OVERVIEW

Owing to their extensive industry experience and established anti-abuse operations, ARI will implement and manage on our behalf various procedures and measures to prevent, detect, identify, and respond to abuse. ARI will automatically respond to information about the categories of abuse that fall within the scope of the ARI AAS, and forward to us all matters requiring determination by the registry operator and⁄or falling outside of the scope of ARI’s AAS. This is described below in the context of the implementation of the .SUCKS Anti-Abuse Policy.
The ARI Anti-Abuse Service is structured to address the following categories of abuse:. Spam, Malware, Pornography, Fast Flux Hosting, Phishing, Illegal Access to other Computers or Networks, Pharming, Botnet command and control and Cyberbullying, We nonetheless understand that it is our responsibility to minimise abusive registrations and other activities that have a negative impact on Internet users in the TLD. In recognition of this responsibility, we will play a hands-on role in the implementation of the ARI Anti-Abuse Service for .SUCKS. Our contract with ARI will contain SLA’s to ensure that ARI’s delivery of the Anti-Abuse Service is aligned with our strong commitment to minimise abuse in our TLD. 
That strong commitment is further demonstrated by our adoption of many of the requirements proposed in the ‘2011 Proposed Security, Stability and Resiliency Requirements for Financial TLDs’ (at http:⁄⁄www.icann.org⁄en⁄news⁄correspondence⁄aba-bits-to-beckstrom-crocker-20dec11-en.pdf) (the ‘BITS Requirements). While these requirements were developed by the financial services sector to address potential abuses in financial TLDs, a number of the Requirements, if adapted and adopted in .SUCKS (which is not financial-related), will result in a more robust approach to combating abuse. 
Consistent with Requirement 6 of the BITS Requirements, we will certify to ICANN on an annual basis our compliance with our Registry Agreement.
Please note that the various policies and practices that we have implemented to minimise abusive registrations and other activities that affect the rights of trademark holders are specifically described in our response to Question 29. Accordingly, they are NOT addressed in our response to this Question.

3 POLICY

In consultation with ARI we have developed a comprehensive Anti-Abuse Policy, which is the main instrument that captures our strategy in relation to abuse in the TLD.

3.1 Definition of Abuse
Abusive behaviour in a TLD may relate to the core domain name-related activities performed by Registrars and registries including, but not limited to:
– The allocation of registered domain names
– The maintenance of and access to registration information
– The transfer, deletion, and reallocation of domain names
– The manner in which the registrant uses the domain name upon creation
The scope of such activities makes it challenging to define abusive behaviour in a TLD. Defining abusive behaviour by reference to the stage in the domain name lifecycle in which the behaviour occurs also presents difficulty given that a particular type of abuse may occur at various stages of the life cycle.
With this in mind, ARI has fully adopted the definition of abuse developed by the Registration Abuse Policies Working Group (Registration Abuse Policies Working Group Final Report 2010, at http:⁄⁄gnso.icann.org⁄issues⁄rap⁄rap-wg-final-report-29may10-en.pdf), which does not focus on any particular stage in the domain name life cycle.
Under this policy, abusive behaviour in a TLD is defined as an action that:
– causes actual and substantial harm, or is a material predicate of such harm.
– is illegal or illegitimate, or is otherwise considered contrary to the intention and design of the mission⁄purpose of the TLD.

In applying this definition the following must be noted:
1. The party or parties harmed, and the severity and immediacy of the abuse, should be identified in relation to the specific alleged abuse.
2. The term ʺharmʺ is not intended to shield a party from fair market competition.
3. A predicate is a related action or enabler. There must be a clear link between the predicate and the abuse, and justification enough to address the abuse by addressing the predicate (enabling action).
For example, WhoIs data can be used in ways that cause harm to domain name registrants, intellectual property (IP) rights holders and Internet users. Harmful actions may include the generation of spam, the abuse of personal data, IP infringement, loss of reputation or identity theft, loss of data, phishing and other cybercrime-related exploits, harassment, stalking, or other activity with negative personal or economic consequences. Examples of predicates to these harmful actions are automated email harvesting, domain name registration by proxy⁄privacy services to aid wrongful activity, support of false or misleading registrant data, and the use of WhoIs data to develop large email lists for commercial purposes. The misuse of WhoIs data is therefore considered abusive because it is contrary to the intention and design of the stated legitimate purpose of WhoIs data.

3.2 Aims and Overview of Our Anti-Abuse Policy
The .SUCKS Anti-Abuse Policy will first ensure that registrants are on notice of the TLD policies, the ways in which the TLD will be monitored for abuse, the mechanisms for reporting abuse, and the manner in which we will respond to verified instances of abuse. We believe that unavoidable, “in your face” notification about these policies and procedures will serve as a deterrent to those seeking to register and use domain names for abusive purposes. The policy will be specifically called out in the registration process, easily accessible on the Abuse page of our registry website which will be linked directly from the home page, along with FAQs and contact information for reporting abuse.
Consistent with Requirements 15 and 16 of the BITS Requirements, our policy:
– Defines abusive behaviour in our TLD.
– Identifies types of actions that constitute abusive behaviour, consistent with our adoption of the RAPWG definition of ‘abuse’.
– Classifies abusive behaviours based on the severity and immediacy of the harm caused.
– Identifies how abusive behaviour can be notified to us and the steps that we will take to determine whether the notified behaviour is abusive.
– Identifies the actions that we may take in response to behaviour determined to be abusive.

Our RRA will oblige all Registrars to:
– comply with the .SUCKS Anti-Abuse Policy; and
– enter into a registration agreement with each registrant that obligates each registrant to comply with the Anti-Abuse Policy and each of the following requirements:
‘operational standards, policies, procedures, and practices for the TLD established from time to time by the registry operator in a non-arbitrary manner and applicable to all Registrars, including affiliates of the registry operator, and consistent with ICANNʹs standards, policies, procedures, and practices and the registry operator’s Registry Agreement with ICANN.’ In addition, we will reserve the right to impose additional or revised registry operator operational standards, policies, procedures, and practices for the TLD which shall be effective upon thirty days notice by the registry operator to the Registrar. If there is a discrepancy between the terms required by this Agreement and the terms of the Registrar’s registration agreement, the terms of this Agreement shall supersede those of the Registrar’s registration agreement’.
Our RRA will additionally incorporate the following BITS Requirements:
– Requirement 7: Registrars must certify annually to ICANN and us compliance with ICANN’s Registrar Accreditation Agreement (RAA) our Registry-Registrar Agreement (RRA).
– Requirement 9: Registrars must provide and maintain valid primary contact information (name, email address, and phone number) on their website.
– Requirement 14: Registrars must notify us immediately regarding any investigation or compliance action, including the nature of the investigation or compliance action by ICANN or any outside party (eg. law enforcement, etc.) along with the TLD impacted.
– Requirement 19: Registrars must disclose registration requirements on their website.
We will re-validate our RRAs at least annually, consistent with Requirement 10.

3.3 Anti-Abuse Policy
Our Anti-Abuse Policy is as follows:
Anti-Abuse Policy
Introduction:
The abusive registration and use of domain names in the TLD creates security and stability issues for all participants in the Internet environment and will not be tolerated.
Definition of Abusive Behaviour:
Abusive behaviour is an action that:
– causes actual and substantial harm, or is a material predicate of such harm; or
– is illegal or illegitimate, or is otherwise considered contrary to the intention and design of the mission⁄purpose of the TLD.
A ‘predicate’ is an action or enabler of harm.
‘Material’ means that something is consequential or significant.
Examples of abusive behaviour falling within this definition:
– 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 a fraudulently presented web site to deceive Internet users into divulging sensitive information such as usernames, passwords or financial data.
– Pharming: the redirecting of unknowing users to fraudulent web sites or services, typically through DNS hijacking or poisoning, in order to deceive Internet users into divulging sensitive information such as usernames, passwords or financial data.
– Wilful distribution of malware: the dissemination of software designed to infiltrate or cause damage to devices or to collect confidential data from users without their informed consent.
– Fast Flux hosting: the use of DNS to frequently change the location on the Internet to which the domain name of an Internet host or nameserver resolves in order to disguise the location of web sites or other Internet services, or to avoid detection and mitigation efforts, or to host illegal activities. Fast flux hosting may only be used with prior permission of the registry operator.
– Botnet command and control: the development and use of a command, agent, motor, service or software which is implemented: (1) to remotely control the computer or computer system of an Internet user without their knowledge or consent, (2) to generate direct denial of service (DDOS) attacks.
– Distribution of any form of pornography: the storage, publication, display and⁄or dissemination of pornographic 
- Any form of cyber bullying defined as ‘any cyber-communication or publication posted or sent by a minor online, by instant message, e-mail, website, diary site, online profile, interactive game, handheld device, cellphone, game device, digital camera or video, webcam or use of any interactive device that is intended to frighten, embarrass, harass, hurt, set up, cause harm to, extort, or otherwise target another minor.’ 
– Illegal access to other computers or networks: the illegal accessing of computers, accounts, or networks belonging to another party, or attempt to penetrate security measures of another individual’s system (hacking). Also, any activity that might be used as a precursor to an attempted system penetration.

Detection of Abusive Behaviour:
Abusive behaviour in the TLD may be detected in the following ways:
– By us through our on-going monitoring activities and industry participation.
– By third parties (general public, law enforcement, government agencies, industry partners) through notification submitted to the abuse point of contact on our website, or industry alerts.
Reports of abusive behaviour will be notified immediately to the Registrar of record. 
Intake and handling of reports of abusive behaviour:
The registry will maintain a web-based system (the “Abuse Reporting System” or the “ARS”) for reporting non-compliant registrations and⁄or registrants operating in a manner that violates .SUCKS Policies.
The ARS will facilitate prompt processing by queuing reports by category (e.g., phishing, pharming, spam, cyberbullying, etc.). 
Personnel responsible for receiving and responding to abuse reports will be trained to recognize actions or activity that constitute abuse. Such personnel will have access to subject matter experts to assess reports about particular categories of abuse. 
Handling of abusive behaviour:
Upon receipt of a report of abuse, a preliminary assessment will be performed in order to validate the report. Applying the definitions of types of abusive behaviours identified in this policy, we will classify each incidence of validated abuse into one of two categories based on the probable severity and immediacy of harm to registrants and Internet users. These categories are provided below and are defined by reference to the action that may be taken by us. The examples of types of abusive behaviour falling within each category are illustrative only.
Category 1:
Probable Severity or Immediacy of Harm: Low
Examples of types of abusive behaviour: Spam, Malware, Pornography
Mitigation steps:
1. Investigate
2. Notify registrant (notice to cure)
Category 2:
Probable Severity or Immediacy of Harm: Medium to High
Examples of types of abusive behaviour: Fast Flux Hosting, Phishing, Illegal Access to other Computers or Networks, Pharming, Botnet command and control
Mitigation steps:
1. Suspend domain name 
2. Investigate 
3. Restore or terminate domain name
Category 3:
Probable Severity or Immediacy of Harm: Medium to High
Examples of types of abusive behaviour: Cyber bullying
Mitigation steps:
1. Suspend domain name 
2. Investigate and refer to an independent third party expert. In this case we will engage industry subject matter experts to assist us in the development and implementation of the required policy and processes towards implementing our cyber bullying take down framework. Our plan is to create a framework similar to the UDRP process that would include assessment and review by a qualified unbiased third party of alleged Cyber Bullying claims.
3. Restore or terminate domain name
All reports of child abuse images will be automatically referred to the hotline designated to receive such reports.

Reports of illegal abusive behaviour submitted by a law enforcement agency, government or quasi-governmental agency will be reviewed and evaluated on an expedited basis, and the registry will comply with any specific instructions provided by the referring agency provided such steps are consistent with applicable law and respect any due process rights contained in applicable law. Please see section 4.3.2.2.1 below for information about the expedited process for qualifying agencies.

All reports of abusive behaviours will be date stamped and logged upon receipt. Subsequent processing, including suspension, referral, issuance of notice to cure, restore, termination, etc. will be logged.

The registry will conduct annual audits of reports of abusive behaviour, and adjust the operation of the .SUCKS registration policies and procedures, the ARS, and the .SUCKS policies on abusive behaviours as appropriate. 
Note that these expected actions are intended to provide a guide to our response to abusive behaviour rather than any guarantee that a particular action will be taken.
The identification of abusive behaviour in the TLD, as defined above, shall give us the right, but not the obligation, to take such actions in accordance with the following text in the .SUCKS RRA, which provides that the registry operator:
‘reserves the right to deny, cancel or transfer any registration or transaction, or place any domain name(s) on registry lock, hold or similar status, or instruct Registrars to take such an action as we deem necessary in our discretion to;
1. protect the integrity and stability of the registry;
2.enforce TLD policies;
3. comply with any applicable laws, government rules or requirements, requests of law enforcement, or dispute resolution process;
4. avoid any liability, civil or criminal, on the part of the registry operator, as well as its affiliates, subsidiaries, officers, directors, and employees, per the terms of the registration agreement; and
5. correct mistakes made by the registry operator or any Registrar in connection with a domain name registration.
We reserve the right to place upon registry lock, hold or similar status a domain name during resolution of a dispute.
We also reserve the right to deny registration of a domain name to a registrant who has repeatedly engaged in abusive behaviour in our TLD or any other TLD.
Registrars only and not Resellers may offer proxy registration services to private individuals using the domain name for non-commercial purposes.
We may amend or otherwise modify this policy to keep abreast of changes in consensus policy or new and emerging types of abusive behaviour in the Internet.
Registrar’s failure to comply with this Anti-Abuse Policy shall constitute a material breach of the RRA, and shall give rise to the rights and remedies available to us under the RRA.

4 ABUSE PREVENTION AND MITIGATION

This section describes the implementation of our abuse related processes regarding:
– Building awareness of the Anti-Abuse Policy.
– Mitigating the potential for abusive behaviour.
– Identifying abusive behaviour.
– Handling abusive behaviour.

4.1. Awareness of Policy
The Anti-Abuse Policy will be published on the Abuse page of our registry website, which will be accessible and have clear links from the home page. In addition, the URL to the Abuse page will be included in all email correspondence to the registrant, thereby placing all registrants on notice of the applicability of the Anti-Abuse Policy to all domain names registered in our TLD. The Abuse page will, consistent with Requirement 8 of the BITS Requirements, provide registry contact information (name, email address, and phone number) to enable the public to communicate with us about TLD policies. The Abuse page will emphasise and evidence our commitment to combating abusive registrations by clearly identifying what our policy on abuse is and what effect our implementation of the policy may have on registrants. We anticipate that this clear message, which communicates our commitment to combating abusive registrations, will serve to minimise abusive registrations in our TLD.

4.2 Pre-emptive – Mitigating of the Potential for Abuse
The following practices and procedures will be adopted to mitigate the potential for abusive behaviour in our TLD.

4.2.1 ICANN Prescribed Measures
In accordance with our obligations as a registry operator, we will comply with all requirements in the ‘gTLD Applicant Guidebook’. In particular, we will comply with the following measures prescribed by ICANN which serve to mitigate the potential for abuse in the TLD:
– DNSSEC deployment, which reduces the opportunity for pharming and other man-in-the-middle attacks. We will encourage Registrars and Internet Service Providers to deploy DNSSEC capable resolvers in addition to encouraging DNS hosting providers to deploy DNSSEC in an easy-to-use manner in order to facilitate deployment by registrants. DNSSEC deployment is further discussed in the context of our response to Question 43.
– Prohibition on Wild Carding as required by section 2.2 of Specification 6 of the Registry Agreement.
– Removal of Orphan Glue records (discussed below in ‎‘4.2.8 Orphan Glue Record Management’).

4.2.2 Increasing Registrant Security Awareness
In accordance with our commitment to operating a secure and reliable TLD, we will attempt to improve registrant awareness of the threats of domain name hijacking, registrant impersonation and fraud, and emphasise the need for and responsibility of registrants to keep registration (including WhoIs) information accurate. Awareness will be raised by:
– Publishing the necessary information on the Abuse page of our registry website in the form of videos, presentations and FAQ’s.
– Developing and providing to registrants and resellers Best Common Practices that describe appropriate use and assignment of domain auth Info codes and risks of misuse when the uniqueness property of this domain name password is not preserved.
The increase in awareness renders registrants less susceptible to attacks on their domain names owing to the adoption of the recommended best practices thus serving to mitigate the potential for abuse in the TLD. The clear responsibility on registrants to provide and maintain accurate registration information (including WhoIs) further serves to minimise the potential for abusive registrations in the TLD.

4.2.3 Mitigating the Potential for Abusive Registrations that Affect the Legal Rights of Others
Many of the examples of abusive behaviour identified in our Anti-Abuse Policy may affect the rights of trademark holders. While our Anti-Abuse Policy addresses abusive behaviour in a general sense, we have additionally developed specific policies and procedures to combat behaviours that affect the rights of trademark holders at start-up and on an ongoing basis. These include the implementation of a trademark claims service and a sunrise registration service at start-up and implementation of the UDRP, URS and PDDRP on an ongoing basis. The implementation of these policies and procedures serves to mitigate the potential for abuse in the TLD by ensuring that domain names are allocated to those who hold a corresponding trademark.
These policies and procedures are described in detail in our response to Question 29.

4.2.4 Safeguards Against Allowing for Unqualified Registrations
The eligibility restrictions for .SUCKS are outlined in our response to Question 18.
Eligibility restrictions will be implemented contractually through our RRA, which will require Registrars to include the following in their Registration Agreements:
– Registrant warrants that it satisfies eligibility requirements.
Where applicable, eligibility restrictions will be enforced through the adoption of the Charter Eligibility Dispute Resolution Policy or a similar policy, and Registrars will be obliged to require in their registration agreements that registrants agree to be bound by such policy and acknowledge that a registration may be cancelled in the event that a challenge against it under such policy is successful.
Providing an administrative process for enforcing eligibility criteria and taking action when notified of eligibility violations mitigates the potential for abuse. This is achieved through the risk of cancellation in the event that it is determined in a challenge procedure that eligibility criteria are not satisfied.

4.2.5 Registrant Disqualification
As specified in our Anti-Abuse Policy, we reserve the right to deny registration of a domain name to a registrant who has repeatedly engaged in abusive behaviour in our TLD or any other TLD.
Registrants, their agents or affiliates found through the application of our Anti-Abuse Policy to have repeatedly engaged in abusive registration will be disqualified from maintaining any registrations or making future registrations. This will be triggered when our records indicate that a registrant has had action taken against it an unusual number of times through the application of our Anti-Abuse Policy. Registrant disqualification provides an additional disincentive for qualified registrants to maintain abusive registrations in that it puts at risk even otherwise non-abusive registrations, through the possible loss of all registrations.
In addition, nameservers that are found to be associated only with fraudulent registrations will be added to a local blacklist and any existing or new registration that uses such fraudulent NS record will be investigated.
The disqualification of ‘bad actors’ and the creation of blacklists mitigates the potential for abuse by preventing individuals known to partake in such behaviour from registering domain names.

4.2.6 Restrictions on Proxy Registration Services
Whilst it is understood that implementing measures to promote WhoIs accuracy is necessary to ensure that the registrant may be tracked down, it is recognised that some registrants may wish to utilise a proxy registration service to protect their privacy. In the event that Registrars elect to offer such services, the following conditions apply:
– Proxy registration services may only be offered by Accredited Registrars and NOT resellers.
– Registrars must obtain and maintain the actual WhoIs data from the registrant.
– Registrars must provide Law Enforcement Agencies (LEA) with the actual WhoIs data upon receipt of a verified request.
– Proxy registration services may only be made available to private individuals using the domain name for non-commercial purposes.
These conditions will be implemented contractually by inclusion of corresponding clauses in the RRA as well as being published on the Abuse page of our registry website. Individuals and organisations will be encouraged through our Abuse page to report any domain names they believe violate the above restrictions, following which appropriate action may be taken by us. Publication of these conditions on the Abuse page of our registry website ensures that registrants are aware that despite utilisation of a proxy registration service, actual WhoIs information will be provided to LEA upon request in order to hold registrants liable for all actions in relation to their domain name. The certainty that WhoIs information relating to domain names which draw the attention of LEA will be disclosed results in the TLD being less attractive to those seeking to register domain names for abusive purposes, thus mitigating the potential for abuse in the TLD.

4.2.7 Registry Lock
Certain mission-critical domain names such as transactional sites, email systems and site supporting applications may warrant a higher level of security. Whilst we will take efforts to promote the awareness of security amongst registrants, it is recognised that an added level of security may be provided to registrants by ‘registry locking’ the domain name thereby prohibiting any updates at the registry operator level. The registry lock service will be offered to all Registrars who may request this service on behalf of their registrants in order to prevent unintentional transfer, modification or deletion of the domain name. This service mitigates the potential for abuse by prohibiting any unauthorised updates that may be associated with fraudulent behaviour. For example, an attacker may update nameservers of a mission-critical domain name, thereby redirecting customers to an illegitimate website without actually transferring control of the domain name.
Upon receipt of a list of domain names to be placed on registry lock by an authorised representative from a Registrar, ARI will:
1. Validate that the Registrar is the Registrar of record for the domain names.
2. Set or modify the status codes for the names submitted to serverUpdateProhibited, serverDeleteProhibited and⁄or serverTransferProhibited depending on the request.
3. Record the status of the domain name in the Shared Registration System (SRS).
4. Provide a monthly report to Registrars indicating the names for which the registry lock service was provided in the previous month.

4.2.8 Orphan Glue Record Management
The ARI registry SRS database does not allow orphan records. Glue records are removed when the delegation point NS record is removed. Other domains that need the glue record for correct DNS operation may become unreachable or less reachable depending on their overall DNS service architecture. It is the registrant’s responsibility to ensure that their domain name does not rely on a glue record that has been removed and that it is delegated to a valid nameserver. The removal of glue records upon removal of the delegation point NS record mitigates the potential for use of orphan glue records in an abusive manner.

4.2.9 Promoting WhoIs Accuracy
Inaccurate WhoIs information significantly hampers the ability to enforce policies in relation to abuse in the TLD by allowing the registrant to remain anonymous. In addition, LEAs rely on the integrity and accuracy of WhoIs information in their investigative processes to identify and locate wrongdoers. In recognition of this, we will implement a range of measures to promote the accuracy of WhoIs information in our TLD including:
– Random monthly audits: registrants of randomly selected domain names are contacted by telephone using the provided WhoIs information by a member of the ARI Abuse and Compliance Team in order to verify all WhoIs information. Where the registrant is not contactable by telephone, alternative contact details (email, postal address) will be used to contact the registrant, who must then provide a contact number that is verified by the member of the ARI Policy Compliance team. In the event that the registrant is not able to be contacted by any of the methods provided in WhoIs, the domain name will be cancelled following five contact attempts or one month after the initial contact attempt (based on the premise that a failure to respond is indicative of inaccurate WhoIs information and is grounds for terminating the registration agreement).
– Semi-annual audits: to identify incomplete WhoIs information. Registrants will be contacted using provided WhoIs information and requested to provide missing information. In the event that the registrant fails to provide missing information as requested, the domain name will be cancelled following five contact attempts or one month after the initial contact attempt.
– Email reminders: to update WhoIs information to be sent to registrants every 6 months.
– Reporting system: a web-based submission service for reporting WhoIs accuracy issues available on the Abuse page of our registry website.
– Analysis of registry data: to identify patterns and correlations indicative of inaccurate WhoIs (eg repetitive use of fraudulent details).
Registrants will continually be made aware, through the registry website and email reminders, of their responsibility to provide and maintain accurate WhoIs information and the ramifications of a failure to do so or respond to requests to do so, including termination of the Registration Agreement.
The measures to promote WhoIs accuracy described above strike a balance between the need to maintain the integrity of the WhoIs service, which facilitates the identification of those taking part in illegal or fraudulent behaviour, and the operating practices of the registry operator and Registrars, which aim to offer domain names to registrants in an efficient and timely manner.
Awareness by registrants that we will actively take steps to maintain the accuracy of WhoIs information mitigates the potential for abuse in the TLD by discouraging abusive behaviour given that registrants may be identified, located and held liable for all actions in relation to their domain name.

4.3 Reactive – Identification
The methods by which abusive behaviour in our TLD may be identified are described below. These include detection by ARI and notification from third parties. These methods serve to merely identify and not determine whether abuse actually exists. Upon identification of abuse, the behaviour will be handled in accordance with ‘4.4 Abuse Handling’.
Any abusive behaviour identified through one of the methods below will, in accordance with Requirement 13 of the BITS Requirements, be notified immediately to relevant Registrars.

4.3.1 Detection – Analysis of Data
ARI will routinely analyse registry data in order to identify abusive domain names by searching for behaviours typically indicative of abuse. The following are examples of the data variables that will serve as indicators of a suspicious domain name and may trigger further action by the ARI Abuse and Compliance Team:
– Unusual Domain Name Registration Practices: practices such as registering hundreds of domains at a time, registering domains which are unusually long or complex or include an obvious series of numbers tied to a random word (abuse40, abuse50, abuse60) may, when considered as a whole, be indicative of abuse.
– Domains or IP addresses identified as members of a Fast Flux Service Network (FFSN): ARI uses the formula developed by the University of Mannheim and tested by participants of the Fast Flux PDP WG to determine members of this list. IP addresses appearing within identified FFSN domains, as either NS or A records shall be added to this list.
– An Unusual Number of Changes to the NS record: the use of fast-flux techniques to disguise the location of web sites or other Internet services, to avoid detection and mitigation efforts, or to host illegal activities is considered abusive in the TLD. Fast flux techniques use DNS to frequently change the location on the Internet to which the domain name of an Internet host or nameserver resolves. As such an unusual number of changes to the NS record may be indicative of the use of fast-flux techniques given that there is little, if any, legitimate need to change the NS record for a domain name more than a few times a month.
– Results of WhoIs audits: The audits conducted to promote WhoIs accuracy described above are not limited to serving that purpose but may also be used to identify abusive behaviour given the strong correlation between inaccurate WhoIs data and abuse.
– Analysis of cross-validation of registrant WhoIs data against WhoIs data known to be fraudulent.
– Analysis of Domain Names belonging to a registrant subject to action under the Anti-Abuse Policy: in cases where action is taken against a registrant through the application of the Anti-Abuse Policy, we will also investigate other domain names by the same registrant (same name, nameserver IP address, email address, postal address etc).

4.3.2 Abuse Reported by Third Parties
Whilst we are confident in our abilities to detect abusive behaviour in the TLD owing to our robust ongoing monitoring activities, we recognise the value of notification from third parties to identify abuse. To this end, we will incorporate notifications from the following third parties in our efforts to identify abusive behaviour:
– Industry partners through ARI’s participation in industry forums which facilitate the sharing of information.
– LEA through a single abuse point of contact (our Abuse page on the registry website, as discussed in detail below) and an expedited process (described in detail in ‘4.4 Abuse Handling’) specifically for LEA.
– Members of the general public through a single abuse point of contact (our Abuse page on the registry website).

4.3.2.1 Industry Participation and Information Sharing
ARI is a member of the Registry Internet Safety Group (RISG), whose mission is to facilitate data exchange and promulgate best practices to address Internet identity theft, especially phishing and malware distribution. In addition, ARI coordinates with the Anti-Phishing Working Group (APWG) and other DNS abuse organisations and is subscribed to the NXdomain mailing list. ARI’s strong participation in the industry facilitates collaboration with relevant organisations on abuse-related issues and ensures that ARI is responsive to new and emerging domain name abuses.
The information shared as a result of this industry participation will be used to identify domain names registered or used for abusive purposes. Information shared may include a list of registrants known to partake in abusive behaviour in other TLDs. Whilst presence on such lists will not constitute grounds for registrant disqualification, ARI will investigate domain names registered to those listed registrants and take action in accordance with the Anti-Abuse Policy. In addition, information shared regarding practices indicative of abuse will facilitate detection of abuse by our own monitoring activities.

4.3.2.2 Single Abuse Point of Contact on Website
In accordance with section 4.1 of Specification 6 of the Registry Agreement, we will establish a single abuse point of contact (SAPOC) responsible for addressing and providing a timely response to abuse complaints concerning all names registered in the TLD through all Registrars of record, including those involving a reseller. Complaints may be received from members of the general public, other registries, Registrars, LEA, government and quasi-governmental agencies and recognised members of the anti-abuse community.
The SAPOC’s accurate contact details (email and mailing address as well as a primary contact for handling inquiries related to abuse in the TLD) will be provided to ICANN and published on the Abuse page of our registry website, which will also include:
– All public facing policies in relation to the TLD, including the Anti-Abuse Policy.
– A web-based submission service for reporting inaccuracies in WhoIs information.
– Registrant Best Practices.
– Conditions that apply to proxy registration services and direction to the SAPOC to report domain names that violate the conditions.
As such, the SAPOC may receive complaints regarding a range of matters including but not limited to:
– Violations of the Anti-Abuse Policy.
– Inaccurate WhoIs information.
– Violation of the restriction of proxy registration services to individuals.
The SAPOC will be the primary method by which we will receive notification of abusive behaviour from third parties. It must be emphasised that the SAPOC will be the initial point of contact following which other processes will be triggered depending on the identity of the reporting organisation. Accordingly, separate processes for identifying abuse exist for reports by LEA⁄government and quasi-governmental agencies and members of the general public. These processes will be described in turn below.

4.3.2.2.1 Notification by LEA of Abuse
We recognise that LEA, governmental and quasi-governmental agencies may be privy to information beyond the reach of others which may prove critical in the identification of abusive behaviour in our TLD. As such, we will provide an expedited process which serves as a channel of communication for LEA, government and quasi-governmental agencies to, amongst other things, report illegal conduct in connection with the use of the TLD.
The process will involve prioritisation and prompt investigation of reports identifying abuse from those organisations. The steps in the expedited process are summarised as follows:
1. ARI’s Abuse and Compliance Team will publish a mechanism for verifying relevant LEA, government and quasi-governmental agencies eligible to use the expedited process, depending on the mission⁄purpose and jurisdiction of our TLD. In addition, the Team will pro-actively identify and reach-out to relevant agencies. 
2. We will publish contact details on the Abuse page of the registry website for the SAPOC to be utilised by only those taking part in the expedited process.
3. All calls to this number will be responded to by the ARI Service Desk on a 24⁄7 basis. All calls will result in the generation of a ticket in ARI’s case management system (CMS). 
4. The identity of the reporting agency will be identified using the established means of verification (ARIʹs Security Policy has strict guidelines regarding the verification of external parties over the telephone). If no means of verification has been established, the report will be immediately escalated to the ARI Abuse and Compliance Team. Results of verification will be recorded against the relevant CMS ticket.
6. Upon verification of the reporting agency, the ARI Service Desk will obtain the details necessary to adequately investigate the report of abusive behaviour in the TLD. This information will be recorded against the relevant CMS ticket.
7. Reports from verified agencies may be provided in the Incident Object Description Exchange Format (IODEF) as defined in RFC 5070. Provision of information in the IODEF will improve our ability to resolve complaints by simplifying collaboration and data sharing.
8. Tickets will then be forwarded to the ARI Abuse and Compliance Team to be dealt with in accordance with ‘4.4 Abuse Handling’.

4.3.2.2.2 Notification by General Public of Abuse
Abusive behaviour in the TLD may also be identified by members of the general public including but not limited to other registries, Registrars or security researchers. The steps in this notification process are summarised as follows:
1. We will publish contact details on the Abuse page of the registry website for the SAPOC (note that these contact details are not the same as those provided for the expedited process).
2. All calls to this number will be responded to by the ARI Service Desk on a 24⁄7 basis. All calls will result in the generation of a CMS ticket. 
3. The details of the report identifying abuse will be documented in the CMS ticket using a standard information gathering template. 
4. Tickets will be forwarded to the ARI Abuse and Compliance Team, to be dealt with in accordance with ‎‘4.4 Abuse Handling’.
All reports of child abuse images will be automatically referred to the hotline designated to receive such reports.

4.4 Abuse Handling
Upon being made aware of abuse in the TLD, whether by ongoing monitoring activities or notification from third parties, the ARI Abuse and Compliance Team will perform the following functions:

4.4.1 Preliminary Assessment and Categorisation
Each report of purported abuse will undergo an initial preliminary assessment by the ARI Abuse and Compliance Team to determine the legitimacy of the report. This step may involve simply visiting the offending website and is intended to weed out spurious reports, and will not involve the in-depth investigation needed to make a determination as to whether the reported behaviour is abusive.
Where the report is assessed as being legitimate, the type of activity reported will be classified as one of the types of abusive behaviour as found in the Anti-Abuse Policy by the application of the definitions provided. In order to make this classification, the ARI Abuse and Compliance Team must establish a clear link between the activity reported and the alleged type of abusive behaviour such that addressing the reported activity will address the abusive behaviour.
While we recognise that each incident of abuse represents a unique security threat and should be mitigated accordingly, we also recognise that prompt action justified by objective criteria are key to ensuring that mitigation efforts are effective. With this in mind, we have categorised the actions that we may take in response to various types of abuse by reference to the severity and immediacy of harm. This categorisation will be applied to each validated report of abuse and actions will be taken in accordance with the table below. It must be emphasised that the actions to mitigate the identified type of abuse in the table are merely intended to provide a rough guideline and may vary upon further investigation.
Category 1
Probable Severity or Immediacy of Harm: Low
Examples of types of abusive behaviour: Spam, Malware
Mitigation steps:
1. Investigate
2. Notify registrant
Category 2
Probable Severity or Immediacy of Harm: Medium to High
Examples of types of abusive behaviour: Fast Flux Hosting, Phishing, Illegal Access to other Computers or Networks, Pharming, Botnet command and control
Mitigation steps:
1. Suspend domain name
2. Investigate
3. Restore or terminate domain name
The mitigation steps for each category will now be described:
Category 3:
Probable Severity or Immediacy of Harm: Medium to High
Examples of types of abusive behaviour: Cyber bullying
Mitigation steps:
1. Suspend domain name 
2. Investigate by an independent third party. In this case we will engage industry subject matter experts to assist us in the development and implementation of the required policy and processes towards implementing our cyber bullying take down framework. Our plan is to create a framework similar to the UDRP process that would include assessment and review by a qualified unbiased third party of alleged Cyber Bullying claims. 

4.4.2 Investigation – Category 1
Types of abusive behaviour that fall into this category include those that represent a low severity or immediacy of harm to registrants and Internet users. These generally include behaviours that result in the dissemination of unsolicited information or the publication of illegitimate information. While undesirable, these activities do not generally present such an immediate threat as to justify suspension of the domain name in question. We will contact the registrant to instruct that the breach of the Anti-Abuse Policy be rectified. If the ARI Abuse and Compliance Team’s investigation reveals that the severity or immediacy of harm is greater than originally anticipated, the abusive behaviour will be escalated to Category 2 and mitigated in accordance with the applicable steps. These are described below. The assessment made and actions taken will be recorded against the relevant CMS ticket.

4.4.3 Suspension – Category 2
Types of abusive behaviour that fall into this category include those that represent a medium to high severity or immediacy of harm to registrants and Internet users. These generally include behaviours that result in intrusion into other computers’ networks and systems or financial gain by fraudulent means. Following notification of the existence of such behaviours, the ARI Abuse and Compliance Team will suspend the domain name pending further investigation to determine whether the domain name should be restored or cancelled. Cancellation will result if, upon further investigation, the behaviour is determined to be one of the types of abuse defined in the Anti-Abuse Policy. Restoration of the domain name will result where further investigation determines that abusive behaviour, as defined by the Anti-Abuse Policy, does not exist. Due to the higher severity or immediacy of harm attributed to types of abusive behaviour in this category, ARI will, in accordance with their contractual commitment to us in the form of SLA’s, carry out the mitigation response within 24 hours by either restoring or cancelling the domain name. The assessment made and actions taken will be recorded against the relevant CMS ticket.

Phishing is considered to be a serious violation of the Anti-Abuse Policy owing to its fraudulent exploitation of consumer vulnerabilities for the purposes of financial gain. Given the direct relationship between phishing uptime and extent of harm caused, we recognise the urgency required to execute processes that handle phish domain termination in a timely and cost effective manner. Accordingly, the ARI Abuse and Compliance Team will prioritise all reports of phishing from brand owners, anti-phishing providers or otherwise and carry out the appropriate mitigation response within 12 hours in accordance with the SLA’s in place between us and ARI. In addition, since a majority of phish domains are subdomains, we believe it is necessary to ensure that subdomains do not represent an unregulated domain space to which phishers are known to gravitate. Regulation of the subdomain space is achieved by holding the registrant of the parent domain liable for any actions that may occur in relation to subdomains. In reality, this means that where a subdomain determined to be used for phishing is identified, the parent domain may be suspended and possibly cancelled, thus effectively neutralising every subdomain hosted on the parent. In our RRA we will require that Registrars ensure that their Registration Agreements reflect our ability to address phish subdomains in this manner.

4.4.3 Suspension – Category 3
Types of abusive behaviour that fall into this category are anything defined as cyber bullying per http:⁄⁄www.stopcyberbullying.org. This organization represents one example of an organization that could be engaged to formulate the .SUCKS TLD’s cyber bullying policies. Notification of the alleged existence of cyberbullying shall be reviewed within 8 business hours of receipt and promptly investigated to rule out any abusive reports. After ruling out clearly abusive reports, the ARI Abuse and Compliance Team will suspend the domain name pending further investigation to determine whether the domain name should be restored or cancelled. As this represents a very specialized form of abuse, ARI will pass all complaints of cyberbullying (including reports deemed to have been abusive) on to our partner (yet to be determined), whose organization will conduct the investigation under contract. Cancellation will result if, as a result of the investigation, the behaviour is determined to be one of the types of abuse defined in the Anti-Abuse Policy. Restoration of the domain name will result where further investigation determines that abusive behaviour, as defined by the Anti-Abuse Policy, does not exist. Due to the higher severity or immediacy of harm attributed to types of abusive behaviour in this category, ARI will, in accordance with their contractual commitment to us in the form of SLA’s, carry out the mitigation response within 24 hours by either restoring or cancelling the domain name. The assessment made and actions taken will be recorded against the relevant CMS ticket.

4.4.5 Executing LEA Instructions
We understand the importance of our role as a registry operator in addressing consumer vulnerabilities and are cognisant of our obligations to assist LEAs, government and quasi-governmental agencies in the execution of their responsibilities. As such, we will make all reasonable efforts to ensure the integration of these agencies into our processes for the identification and handling of abuse by, amongst other things:
1. Providing expedited channels of communication (discussed above).
2. Notifying LEA of abusive behaviour believed to constitute evidence of a commission of a crime eg distribution of child pornography.
3. Sharing all available information upon request from LEA utilising the expedited process, including results of our investigation.
4. Providing bulk WhoIs information upon request from LEA utilising the expedited process.
5. Acting on instructions from a verified reporting agency.
It is anticipated that these actions will assist agencies in the prevention, detection, investigation, prosecution or punishment of criminal offences or breaches of laws imposing penalties. The relevant agencies are not limited to those enforcing criminal matters but may also include those enforcing civil matters in order to eliminate consumer vulnerabilities.
Upon notification of abusive behaviour by LEA, government or quasi– governmental agencies through the expedited process and verification of the reporting agency, a matter will be immediately communicated to us for our consideration. If we do not instruct ARI to refer the matter to us for our resolution, the CMS ticket will be forwarded to the ARI Abuse and Compliance Team, which will take one of the following actions:
1. The reported behaviour will be subject to preliminary assessment and categorisation as described above. The reported behaviour will then be mitigated based on the results of the categorisation. A report describing the manner in which the notification from the agency was handled will be provided to the agency within 24 hours. This report will be recorded against the relevant CMS ticket.
OR
2. Where specific instructions are received from the reporting agency in the required format, ARI will act in accordance with those instructions provided that they do not result in the contravention of applicable law. ARI will, in accordance with their contractual commitment to us in the form of SLA’s, execute such instructions within 12 hours. The following criteria must be satisfied by the reporting agency at this stage:
 a. The request must be made in writing to ARI using a Pro Forma document on the agency’s letterhead. The Pro Forma document will be sent to the verified agency upon request.
 b. The Pro Forma document must be delivered to ARI by fax.
 c. The Pro Forma document must:
 i. Describe in sufficient detail the actions the agency seeks ARI to take.
 ii. Provide the domain name⁄s affected.
 iii. Certify that the agency is an ‘enforcement body’ for the purposes of the Privacy Act 1988 (Cth) or local equivalent.
 iv. Certify that the requested actions are required for the investigation and⁄or enforcement of relevant legislation which must be specified.
 v. Certify that the requested actions are necessary for the agency to effectively carry out its functions.
Following prompt execution of the request, a report will be provided to the agency in a timely manner. This report will be recorded against the relevant CMS ticket.
Finally, whilst we do not anticipate the occurrence of a security situation owing to our robust systems and processes deployed to combat abuse, we are aware of the availability of the Expedited Registry Security Request Process to inform ICANN of a present or imminent security situation and to request a contractual waiver for actions we might take or have taken to mitigate or eliminate the security concern.

5 RESOURCES

This function will be performed by ARI. Abuse services are supported by the following departments:

– Abuse and Compliance Team (6 staff)
– Development Team (11 staff)
– Service Desk (14 staff)

A detailed list of the departments, roles and responsibilities in ARI is provided as attachment ‘Q28 – ARI Background & Roles.pdf’. This attachment describes the functions of the above teams and the exact number and nature of staff within.
The number of resources required to design, build, operate and support the SRS does not vary significantly with, and is not linearly proportional to, the number or size of TLDs that ARI provides registry services to.
ARI provides registry backend services to 5 TLDs and has a wealth of experience in estimating the number of resources required to support a registry system.
Based on past experience ARI estimates that the existing staff is adequate to support a registry system that supports in excess of 50M domains. Since .SUCKS projects 10,049 domains, 0.0205% of these resources are allocated to .SUCKS. See attachment ‘Q28 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI protects against loss of critical staff by employing multiple people in each role. Staff members have a primary role plus a secondary role for protection against personnel absence. Additionally ARI can scale resources as required. 

ARI’s Anti-Abuse Service serves to prevent and mitigate abusive behaviour in the TLD as well as activities that may infringe trademarks. These responsibilities will be undertaken by three teams. ARI’s Development Team will be responsible for developing the technical platforms and meeting technical requirements needed to implement the procedures and measures adopted to mitigate the potential for abuse, identify abuse and handle identified abuse. ARI’s Abuse and Compliance Team will be responsible for the ongoing implementation of measures to minimise abusive registrations and other activities that have a negative impact on Internet users. ARI’s Service Desk will be responsible for responding to reports of abuse received through the abuse point of contact on the registry’s website and logging these in a ticket in ARI’s case management system. 
The responsibilities of these teams relevant to the initial implementation and ongoing maintenance of our measures to minimise abusive registrations and other activities that affect the rights of trademark holders are described in our response to Question 29.
All of the responsibilities undertaken by ARI’s Development Team, Abuse and Compliance Team, and Service Desk are inclusive in ARI’s Managed TLD Registry services fee, which is accounted for as an outsourcing cost in our response to Question 47. The resources needs of these teams have been determined by applying the conservative growth projections for our TLD (which are identified in our response to Question 48) to the team’s responsibilities at start-up and on an ongoing basis.

5.1 ARI Development Team
All tools and systems needed to support the initial and ongoing implementation of measures adopted to mitigate the potential for abuse, identify abuse and handle identified abuse will be developed and maintained by ARI. ARI has a software development department dedicated to this purpose which will ensure that the tools are fit for purpose and adjusted as requirements change.
ARI’s Development Team participate actively in the industry; this facilitates collaboration with relevant organisations on abuse related issues and ensures that the ARI Development Team is responsive to new and emerging domain name abuses and the tools and systems required to be built to address these abuses. This team consists of:
– 1 Development Manager
– 2 Business Analysts
– 6 Developers
– 2 Quality Analysts

5.2 ARI Abuse and Compliance Team
ARI’s Abuse and Compliance Team will be staffed by six full-time equivalent positions. These roles will entail the following:
Policy Compliance Officers: A principal responsibility of the Policy Compliance Officers will be handling notifications of abuse through the SAPOC. This will involve managing the expedited process, identifying and categorising suspected abuse according to our Anti-Abuse Policy, and carrying out the appropriate mitigation response for all categorised abuses. When abuse is identified, Policy Compliance Officers will investigate other domain names held by a registrant whose domain name is subject to a mitigation response. They will maintain a list of and disqualify registrants found to have repeatedly engaged in abusive behaviour. They will also be responsible for analysing registry data in search of behaviours indicative of abuse, reviewing industry lists in search of data that may identify abuse in the TLD.
Another key responsibility of Policy Compliance Officers will be implementing measures to promote WhoIs accuracy (including managing and addressing all reports of inaccurate WhoIs information received from the web submission service) and verifying the physical address provided by a registrant against various databases for format and content requirements for the region.
Policy Compliance Officers will act on the instructions of verified LEA and Dispute Resolution Providers and participate in ICANN and industry groups involved in the promulgation of policies and best practices to address abusive behaviour. They will escalate complaints and issues to the Legal Manager when necessary and communicate with all relevant stakeholders (Registrars, registrants, LEA, general public) as needed in fulfilling these responsibilities. This role will be provided on a 24⁄7 basis, supported outside of ordinary business hours by ARI’s Service Desk.
Policy Compliance Officers will be required to have the following skills⁄qualifications: customer service⁄fault handling experience, comprehensive knowledge of abusive behaviour in a TLD and related policies, Internet industry knowledge, relevant post-secondary qualification, excellent communication and professional skills, accurate data entry skills, high-level problem solving skills, and high-level computer skills.
Legal Manager: The Legal Manager will be responsible for handling all potential disputes arising in connection with the implementation of ARI’s Anti-Abuse service and related policies. This will involve assessing escalated complaints and issues, liaising with Legal Counsel and the registry operator, resolving disputes and communicating with all relevant stakeholders (Registrars, registrants, LEA, general public) as needed in fulfilling these responsibilities. The Legal Manager will be responsible for forwarding all matters requiring determination by the registry operator which fall outside the scope of ARI’s Anti-Abuse functions. The Legal Manager will be required to have the following skills⁄qualifications: legal background (in particular, intellectual property⁄information technology law) or experience with relevant tertiary or post-graduate qualifications, dispute resolution experience, Internet industry experience, strong negotiation skills, excellent communication and professional skills, good computer skills, high-level problem solving skills.
Legal Counsel: A qualified lawyer who will be responsible for all in-house legal advice, including responding to LEA and dealing with abusive behaviour.
The team consists of:
– 4 Policy Compliance Officers
– 1 Legal Manager
– 1 Legal Counsel
5.3 ARI Service Desk
ARI’s Service Desk will be staffed by 14 full-time equivalent positions. Responsibilities of Service Desk relevant to ARI’s Anti-Abuse Service include the following: responding to notifications of abuse through the abuse point of contact and expedited process for LEA, logging notifications as a ticket in ARI’s case management system, notifying us of a report received through the expedited process for LEA, government and quasi-governmental agencies, and forwarding tickets to ARI’s Abuse and Compliance team for resolution in accordance with the Anti-Abuse Policy. 
For more information on the skills and responsibilities of these roles please see the in-depth resources section in response to Question 31.
Based on the projections and the experience of ARI, the resources described here are more than sufficient to accommodate the needs of .SUCKS.
The use of these resources and the services they enable is included in the fees paid to ARI which are described in the financial responses.

We have engaged ARI Registry Services (ARI) to deliver services for .SUCKS. ARI provide registry services for a number of TLDs including the .au ccTLD. For more background information on ARI please see the attachment ‘Q29 – ARI Background & Roles.pdf’.

1 INTRODUCTION

This response is organised by first addressing the RPMs that we will apply during start-up of our TLD (sunrise and trademark claims service) and then by addressing the RPMs that we will apply on an ongoing basis (URS, UDRP and efforts to avoid infringement trademark infringement including implementation of and compliance with the Trademark PDDRP). Each measure is described and the technological and contractual steps needed for its implementation are identified.
The abusive behaviour primarily targeted by these RPMs is cybersquatting, which is the registration of names constituting trademarks by registrants lacking rights in such trademarks. Cybersquatting is one of the many forms of abuse we will seek to minimise in our TLD. Our approach to combating abusive behaviours other than cybersquatting is described in our response to Question 28. Some overlap between the responses to Questions 28 and Question 29 is inherent because the prevention of cybersquatting can also serve to minimise other abusive behaviours such as phishing and pharming. By implementing the RPMs discussed below we thus aim to minimise not only cybersquatting but also some of the abusive behaviours identified in the response to Question 28. The registration policy of our TLD is described in our response to Question 18.
We acknowledge that the legal rights protected by ICANN-mandated RPMs are limited to trademarks. Different RPMs define the scope of protectable trademarks slightly differently; we therefore clearly identify the scope of protectable marks as respects each RPM.
In addition to the RPMs mandated by the Applicant Guidebook, we have also adopted certain requirements proposed in the ‘2011 Proposed Security, Stability and Resiliency Requirements for Financial TLDs’ (at http:⁄⁄www.icann.org⁄en⁄news⁄correspondence⁄aba-bits-to-beckstrom-crocker-20dec11-en.pdf) (the ‘BITS Requirements). We acknowledge that these requirements were developed by the financial services sector in relation to financial TLDs, but nevertheless believe that their adoption in .SUCKS (which is not financial-related) results in a more robust approach to combating abuse. 
In particular, we will adopt the following:
Requirement 6: we will certify annually to ICANN our compliance with our Registry Agreement.
Requirement 8: we will provide and maintain valid primary contact information (name, email address, and phone number) on our registry website.
Requirement 10: we will re-validate our Registry-Registrar Agreements at least annually.
Requirement 13: we will notify Registrars immediately regarding any RPM investigation or compliance action including the nature of the investigation or compliance action by ICANN or any outside party (eg, law enforcement etc).
We will additionally require through our Registry-Registrar Agreement (RRA) that Registrars comply with the following:
Requirement 7: Registrars must certify annually to ICANN their compliance with ICANN’s Registrar Accreditation Agreement (RAA).
Requirement 9: Registrars must provide and maintain valid primary contact information (name, email address, and phone number) on their website.
Requirement 19: Registrars must disclose registration requirements on their website.

2 START-UP RPMS

Below we identify our start-up RPM timeline and describe our implementation of:
– A sunrise period.
– The trademark claims service (‘TM claims service’) during a landrush period.

2.1 Start-up RPMs Timeline
The timeline for start-up RPMs in our TLD is as follows:
Day 1: Single sunrise round opens
Day 30: Sunrise round closes
Day 31: Sunrise allocation begins
Day 40: Landrush (including TM claims service) opens
Day 100: Landrush closes
Day 101: Landrush allocation begins
Day 110: General availability begins

2.2 Sunrise Registration Service
Our sunrise will provide trademark holders with a 30-day priority period in which to register their trademarks as domain names.
The following stakeholders are involved in implementation of the sunrise registration service:
– TMCH Service Provider⁄s
– Trademark owner prospective domain name registrants
– Registrars
– Registry operator
– Auction provider
The role played by these stakeholders is described below by reference to:
– A summary of our Sunrise Policy and Sunrise Dispute Resolution Policy (SDRP)
– Our Sunrise Implementation Plan
– Our SDRP Implementation Plan
– Our implementation of sunrise and SDRP through contractual relationships

2.2.1 Sunrise Policy Summary and SDRP Summary
Through our Sunrise Policy we will offer a single, 30-day sunrise round in which trademark holders satisfying (i), (iii) and (iv) of the Sunrise Eligibility Requirements (SERs) and any general eligibility requirements (as identified in our response to Question 18) proposed in the Applicant Guidebook at Trademark Clearinghouse s6.2.3 will be eligible to apply for a domain name. Our Sunrise Policy will specify that applications satisfying the SERs received by a Registrar within the 30-day sunrise period will be accepted for participation in the sunrise. This will be the first opportunity for registration in our TLD.
Our Sunrise Policy will mandate that the trademarks upon which sunrise applications are based must fall within s7.2 of the Applicant Guidebook (Trademark Clearinghouse) and be supported by an entry in the TMCH.
Consistent with Requirement 2 of the BITS Requirements, our Sunrise Policy will describe how we will allocate domain names applied for during the sunrise period, as follows: allocation will start at the end of the 30-day sunrise period. Where only one validated application is received for a domain name, that domain will be allocated to the applicant during the 10-day period between the close of the sunrise applications period and start of the landrush. Where multiple validated applications are received for a domain name, applicants will be invited to participate in an auction to determine the party to which the domain will be allocated. Our Sunrise Policy will specify that by making a sunrise application (or, where relevant, by agreeing to participate in an auction), the applicant agrees to purchase the domain if it is allocated to the applicant. Domain names registered during the sunrise period will have a term of one year from the date of registration.
We will adopt an SDRP to allow any party to raise a challenge on the four grounds identified in the Applicant Guidebook at Trademark Clearinghouse, s6.2.4. The remedy will be cancellation or deletion of a successfully challenged domain. All registrants will be required to submit to proceedings under the SDRP. Our SDRP will specify that SDRP claims may be raised after registration of a sunrise domain and will require that complaints clearly identify the challenger, the challenged domain, and the ground⁄s on which the complaint is based.
If a TMCH service provider is not able to receive challenges directly as part of its undertaking to ‘maintain the SERs, validate and authenticate marks, as applicable, and hear challenges’ (Applicant Guidebook at Trademark Clearinghouse, s6.2.5), ARI will receive SDRP challenges and communicate these to the SDRP provider.

2.2.2 Implementation
Our Sunrise and SDRP Implementation Plan are set out below followed by a description of the implementation that will take place through contractual relationships.

2.2.2.1 Sunrise Implementation Plan
1. Prior to or during our 30-day sunrise period, trademark holders can apply for validation of marks by the TMCH and inclusion of validated marks in the TMCH database.
2. ARI will develop a website and make available on that website our Sunrise Policy and SDRP.
3. A trademark holder warranting satisfaction of the SERs in our Sunrise Policy (as described above) will submit to an ICANN-accredited Registrar its application to register a domain corresponding to its TMCH entry with evidence of the TMCH entry. A non-refundable sunrise application⁄validation fee will be payable by the applicant to the Registrar on submitting the application.
4. Registrars will be required through our RRA to communicate sunrise application information to ARI. On receipt of this information, ARI will charge the sunrise application⁄validation fee to the submitting Registrar.
5. ARI will perform standard checks (including IDN validity checks where relevant, reserved and restricted words in accordance with the Registry Agreement, composition requirements, etc) to ensure that the domain being applied for is technically valid; an error message will be returned to the Registrar if the domain fails any of these checks. If the domain passes these checks, ARI will hold the application for allocation.
6. Allocation will commence upon conclusion of the 30-day sunrise period. As an initial step, ARI will compile a list of applied-for names and reserve these from registration in landrush and general availability.
7. Through an interface with the TMCH, ARI will identify all sunrise applications constituting an ‘Identical Match’ (as defined in the Applicant Guidebook at Trademark Clearinghouse s6.1.5) with a TMCH entry and provide notice to the holders of those marks of the filing of a corresponding sunrise application.
8. Where a single application exists for a particular domain, between the end of the sunrise application period and start of the landrush period ARI will enable the sponsoring Registrar to CREATE (using EPP or the SRS web interface) the domain and charge the sunrise registration fee to the Registrar, who will collect this fee from the registrant.
9. Where multiple sunrise applications exist for an identical domain name, ARI will compile and communicate to a third-party auction services provider a list of competing applicants, who will be invited to participate in an auction.
10. The auction services provider will facilitate the auction process and upon its completion will notify all participants of the outcome and collect the auction payment from the winning participant.
11. Upon payment of the auction bid, the auction services provider will communicate to ARI the details of the winning auction participant and submit the revenue collected to ARI.
12. ARI will validate the communication from the auction services provider and enable the sponsoring Registrar to CREATE (using EPP or the SRS web interface) the domain name. ARI will charge the sunrise registration fee to the auction winner’s Registrar, who will collect this fee from the registrant.

2.2.2.2 SDRP Implementation Plan
1. If a TMCH service provider is not able to directly receive complaints under our SDRP, we will specify in our SDRP the email address to which SDRP filings must be sent. This email address will be monitored by ARI’s Abuse and Compliance Team.
2. ARI will develop a process of manual or automatic interface with the TMCH to communicate the SERs and any SDRP challenges received by ARI. This interface will also enable the TMCH Service Provider to notify ARI of successful SDRP challenges.
3. Upon notification from a TMCH service provider of a successful SDRP challenge, ARI will cancel or delete the successfully challenged domain.

2.2.2.3 Implementation through Contractual Relationships
The following features of the Sunrise and SDRP implementation plan described above will be executed by inclusion of corresponding clauses in our RRA, which will require inclusion in Registrars’ Registration Agreements:
– By making a sunrise application (or, where relevant, by agreeing to participate in an auction), applicant agrees to purchase the domain name if that name is allocated to the applicant.
– The sunrise application fee is non-refundable.
– All sunrise applicants must submit to proceedings under the SDRP.

2.3 TM Claims Service During Landrush
Ten days after the day that sunrise allocations begin, a 60-day landrush period will commence during which we will offer the TM claims service. This is a service whereby prospective domain name registrants receive notice of existing trademark rights matching their applied-for domain and trademark owners receive notice of domain name registrations matching their trademark. In accordance with the Applicant Guidebook, our TM claims service will be supported exclusively by the TMCH and will recognise and honour all word marks falling within the Applicant Guidebook at Trademark Clearinghouse s7.1.
The following stakeholders are involved in implementation of the TM claims service:
– TMCH Service Provider⁄s
– Trademark owners
– Landrush domain name applicants
– Landrush domain name registrants
– Registrars
– Registry operator
The role played by these stakeholders is described below by reference to:
– Our Landrush⁄TM Claims Service Implementation Plan
– Our implementation of Landrush⁄TM Claims Service through contractual relationships
Consistent with Requirement 2 of the BITS Requirements, the Landrush⁄TM Claims Service Implementation Plan identifies how we will allocate domain names applied for during the landrush.

2.3.1 Implementation
Our Landrush⁄TM Claims Service Implementation Plan is set out below followed by a description of the implementation that will take place through contractual relationships.

2.3.1.1 Landrush⁄TM Claims Service Implementation Plan
1. Prior to or during our 60-day landrush period trademark holders can apply for validation of their marks by the TMCH and inclusion of validated marks in the TMCH database. This will enable provision of notice to landrush applicants of entries in the TMCH and provision of notice to trademark holders of registrations matching TMCH entries (how and by whom this will be achieved is detailed in subsequent steps of this implementation plan).
2. An applicant warranting compliance with the registration policies in .SUCKS (as described in our response to Question 18) will make an application to an ICANN-accredited Registrar for a domain name during the 60-day landrush period. A non-refundable landrush application⁄validation fee will be payable by the applicant to the Registrar on submitting the application.
3. Registrars will be required through our RRA to communicate landrush application information to ARI. On receipt of this information, ARI will charge the landrush application⁄validation fee to the submitting Registrar.
4. Registrars will be required through our RRA to interface with the TMCH to determine whether an applied-for domain constitutes an ‘Identical Match’ with a mark in the TMCH. If an ‘Identical Match’ is identified, the Registrar will provide to the landrush applicant a TM Claims Notice in the form prescribed by the Applicant Guidebook. Following receipt of this notice a landrush applicant must communicate to the Registrar its decision either to proceed with or abandon the application. If the applied-for name does not constitute an ‘Identical Match’ with a trademark in the TMCH, no TM Claims Notice will be generated.
5. ARI will utilise the manual or automatic interface it establishes for implementation of the SDRP (described above in ‘Implementation Plan’) to facilitate reporting by the TMCH of attempts to register domains that are an ‘Identical Match’ with a trademark (within the scope of the Applicant Guidebook at Trademark Clearinghouse s7.1) in the TMCH database.
6. ARI will perform standard checks (including IDN validity checks where relevant, reserved and restricted words in accordance with the Registry Agreement, composition requirements, etc) on all landrush applications (irrespective of whether they have generated a TM Claims Notice) to ensure that the domain being applied for is technically valid and an error message will be returned to the Registrar if the domain fails any of these checks. If the domain passes these checks, ARI will hold the application for allocation.
7. Allocation of landrush applications will commence on conclusion of the 60-day landrush application period. Where a single landrush application exists for a particular domain, between the end of the landrush application period and start of general availability, ARI will enable the sponsoring Registrar to CREATE (using EPP or the SRS web interface) the domain and charge the landrush registration fee to the Registrar, who will collect this fee from the registrant.
8. Where multiple landrush applications exist for an identical domain, ARI will compile and communicate to a third-party auction services provider a list of competing applicants, who will be invited to participate in an auction for the domain name.
9. The auction services provider will facilitate the auction process and on its completion will notify all participants of the outcome and collect payment from the winning participant.
10. Upon payment of the auction bid the auction services provider will communicate to ARI the details of the winning participant and will submit the revenue collected to ARI.
11. ARI will validate the communication from the auction services provider and enable the auction winner’s Registrar to CREATE (using EPP or the SRS web interface) the domain name. ARI will charge the landrush registration fee to the Registrar, who will collect this fee from the registrant.
12. The Registrar will be required through our RRA to interface with the TMCH to promptly notify relevant mark holders of the registration of a domain constituting an ‘Identical Match’ to their TMCH entry.
13. Ten days after the start of the landrush allocation period, general availability of domain names (at first-come, first-served allocation) will commence.

2.3.1.2 Implementation through Contractual Relationships
The following features of our Landrush⁄TM Claims Service Implementation Plan described above will additionally be executed by the inclusion of corresponding clauses in our RRA:
– Registrars must use the TMCH as required by ICANN and the TMCH Service Provider⁄s.
– Registrars must not in their provision of the TM Claims Service make use of any trademark information aggregation, notification or validation service other than the TMCH.
– In order to prevent a chilling effect on registration, Registrars must ensure that landrush applicants are not prevented from registering domains considered an ‘Identical Match’ with a mark in the TMCH.
– Registrars must provide clear notice in the specific form provided by the Applicant Guidebook to the prospective registrant of relevant entries in the TMCH.
– The landrush application fee is non-refundable. Registrars must also include this in their Registration Agreements.

3 ONGOING RPMS

Below we describe the way in which we will implement on an ongoing basis the URS and UDRP and address issues related to the Trademark PDDRP. These RPMs serve to mitigate not only cybersquatting but other types of abuse that frequently occur in conjunction with cybersquatting, such as phishing and pharming.

3.1 URS
The URS is a new RPM the implementation of which is mandated in all new gTLDs. The URS is targeted at providing a rapid takedown solution to clear-cut cases of cybersquatting. It is intended to have a deterrent effect and reduce the number of UDRP disputes.
The URS is intended to supplement and not replace the UDRP, and the Applicant Guidebook foreshadows (at URS ss8.6 and 13) the likelihood of URS claimants also commencing UDRP claims. For this reason, we have considered in our URS Implementation Plan the potential interaction between URS stakeholders and UDRP stakeholders.
The following stakeholders are involved in implementation of the URS:
– URS claimants (holders of valid and enforceable trade or service marks)
– Registrants
– Registrars
– Registry operator
– URS provider⁄s
– URS Examiner

The role played by these stakeholders is described below by reference to:
– Our URS Implementation Plan
– Our implementation of the URS through contractual relationships
Our URS Implementation Plan identifies certain aspects of implementation that are not clearly addressed in the Applicant Guidebook. For example, the Guidebook does not specify how, from an operational perspective, suspension of a domain name will transform to another domain name status (eg the transfer of a domain following a successful UDRP challenge); we assume that such a status change would only occur upon expiry of the registration, but acknowledge the potential for further development of URS policy to allow for change of status as a result of a subsequent UDRP decision.
In addition to identifying such gaps, our URS Implementation Plan identifies our proposed method of addressing these. Furthermore, understanding that a fundamental aim of the URS is expediency, all of the steps in our Implementation Plan below will be undertaken as soon as practical but without compromising security or accuracy.

3.1.1 Implementation
Our URS Implementation Plan is set out below followed by a description of the implementation that will take place through contractual relationships.

3.1.1.1 URS Implementation Plan
1. As an initial step, ARI will notify to each URS provider an email address for all URS-related correspondence. On an ongoing basis, ARI’s Abuse and Compliance Team will monitor this address for communications from URS providers, including the Notice of Complaint, Notice of Default, URS Determination, Notice of Appeal and Appeal Panel Findings.
2. ARI will validate correspondence from a URS provider to ensure that it originates from the URS Provider.
3. ARI will within 24 hours of receipt of a URS Notice of Complaint lock the domain name⁄s the subject of complaint by restricting all changes to the registration data, including transfer and deletion of the domain. The domain will continue to resolve while in this locked status.
4. ARI will immediately notify the URS provider in the manner requested by the URS provider once the domain name⁄s have been locked.
5. Upon receipt of a favourable URS Determination ARI will lock the domain name the subject of the Determination for the balance of the registration period and redirect the nameservers to an informational web page provided by the URS provider. While a domain name is locked, ARI will continue to display all of the WhoIs information of the original registrant except for the redirection of the nameservers and (subject to future policy development taking into account the transfer of a URS-locked domain name following a successful UDRP challenge) the additional statement that the domain will not be able to be transferred, deleted or modified for the life of the registration.
6. Upon receipt of notification from the URS provider of termination of a URS proceeding ARI will promptly unlock the domain and return full control to the registrant.
7. Where a default has occurred (because a registrant has not submitted an answer to a URS complaint in accordance with the Applicant Guidebook at URS s6.1) and a Determination has been made in favour of the complainant, in the event that ARI receives notice from a URS provider that a Response has been filed in accordance with the Applicant Guidebook at URS s6.4, ARI will as soon as practical restore a domain to resolve to the original IP address while preserving its locked status until a Determination from de novo review is notified to ARI.
8. ARI will ensure that no changes are made to the resolution of a registration the subject of a successful URS Determination until expiry of the registration or the additional registration year unless otherwise instructed by UDRP provider.
9. ARI will make available to successful URS complainants an optional extension of the registration period for one additional year at commercial rates. We understand that this requirement has been based on the provision in the Expired Domain Deletion Policy (3.7.5.7 of the 2009 RAA), under which there is no requirement of notification to the complainant that a name is due to expire. From this we conclude that there is likewise no requirement in the operation of our TLD that ARI notify a successful URS complainant that a name is due to expire.
10. The Applicant Guidebook specifies that renewal must be offered ‘at commercial rates’ but it does not specify how and to whom payment for renewal should be made. If payment is to be made to a stakeholder other than the registry operator, it is not clear how this will be received by the registry operator. ARI’s Abuse and Compliance Team will be prepared and have the expertise and flexibility necessary to develop the technical and financial interfaces necessary to facilitate the receipt of renewal fees by ARI.

3.1.1.2 Implementation of the URS through Contractual Relationships
The following features of our URS Implementation Plan described above will be executed by inclusion of corresponding clauses in our RRA:
– In the event that a registrant does not submit an answer to a URS complaint in accordance with the Applicant Guidebook at URS s6.1 (default), Registrars must prevent registrants from making changes to the WhoIs information of a registration while it is in default.
– Registrars must prevent changes to a domain it is in locked status to ensure that both the Registrar’s systems and registry’s systems contain the same information for the locked domain.
– Registrars must not take any action relating to a URS proceeding except as in accordance with a validated communication from ARI or URS provider.

3.2 UDRP
The UDRP is applicable to domain name registrations in all new gTLDs. It is available to parties with rights in valid and enforceable trade or service marks and is actionable on proof of all of the following three grounds:
i. The registrant’s domain name is identical or confusingly similar to a trademark or service mark in which the complainant has rights.
ii. The registrant has no rights or legitimate interests in respect of the domain name.
iii. The registrant’s domain name has been registered and is being used in bad faith.
Available remedies are cancellation of a domain or transfer of a domain to a successful UDRP claimant.
The following stakeholders are involved in implementation of the UDRP:
– UDRP claimants
– Registrants
– Registrar
– Registry operator
– UDRP providers
The role played by these stakeholders is described below by reference to:
– Our UDRP Implementation Plan
– Our implementation of the UDRP through contractual relationships
Our UDRP Implementation Plan considers the potential overlap between URS implementation and UDRP implementation because we consider it likely that URS complainants may commence UDRP claims as a second recourse or simultaneously. We note that neither policy prohibits complainants from commencing proceedings simultaneously.

3.2.1 Implementation
Our UDRP Implementation Plan is set out below followed by a description of the implementation that will take place through contractual relationships.

3.2.1.1 UDRP Implementation Plan
Our UDRP Implementation Plan focuses on interaction with Registrars because there is currently no interaction between existing gTLD registry operators and UDRP providers. On this basis we anticipate ARI has two responsibilities to facilitate Registrars’ implementation of the UDRP.
1. ARI’s Development Team (as described in ‘4 RESOURCES’) will maintain awareness of UDRP requirements and be capable of taking action when required and sufficiently skilled and flexible to respond to any changes to UDRP policy.
2. ARI will provide EPP and the SRS web interface to enable Registrars to perform required UDRP functions in accordance with the Policy on Transfer of Registrations between Registrars.

3.2.1.2 Implementation of the UDRP through Contractual Relationships
The UDRP is applicable to domain name registrations in all new gTLDs by force of a contractual obligation (Registry Agreement Art. 2.9) on registry operators to use only ICANN-accredited Registrars, who in turn are contractually required (RAA, 21 May 2009, at s3.8) to incorporate the UDRP in their Registration Agreements.

3.3 Preventing Trademark Infringement in Operating the Registry
We take seriously our responsibilities in running a registry and understand that while offering a sunrise registration service and TM Claims Service during start-up of our TLD and the URS and UDRP on an ongoing basis serves to minimise abuse, this does not necessarily serve to minimise trademark infringement in our operation of the TLD. This responsibility is now clearly placed on registry operators through the new Trademark PDDRP, which targets infringement arising from the registry operator’s manner of operation or use of its TLD.
While we will as required by the Registry Agreement agree to participate in all Trademark PDDRP procedures and be bound by resulting determinations, we will also have in place procedures to identify and address potential conflicts before they escalate to the stage of a Trademark PDDRP claim.
The following stakeholders are involved in our implementation of measures to prevent trademark infringement in operation of the TLD:
– Trademark holders
– Registry operator
– Trademark PDDRP provider⁄s
The role played by these stakeholders is described below by reference to:
– Our Trademark PDDRP Implementation Plan
– Our implementation of our Trademark PDDRP through contractual relationships

3.3.1 Implementation
Our Trademark PDDRP Implementation Plan is set out below followed by a description of the implementation that will take place through contractual relationships.

3.3.1.1 Trademark PDDRP Implementation Plan
1. ARI will notify to the Trademark PDDRP provider⁄s contact details for all communications regarding the Trademark PDDRP.
2. As described in our response to Question 28, ARI will publish our Anti-Abuse Policy on a website dedicated to abuse handling in our TLD. Consistent with Requirement 8 of the BITS Requirements, this website will include information necessary to enable trademark holders to raise concerns regarding infringement of their trademarks and resultant harm caused by our operation or use of our TLD.
3. Using the single abuse point of contact (SAPOC) discussed in our response to Question 28, a complainant can notify ARI’s Service Desk of its belief that one or more of its marks have been infringed and harm caused by our operation or use of our TLD. The complainant will be required to provide the following information:
– Name of the complainant
– Contact details
– Trademark name
– Jurisdiction
– Registration date
– Registration number
– Nature of entitlement to trademark
– Explanation of why complainant believes that its mark has been infringed and harm caused by our operation or use of the TLD
4. ARI’s Service Desk will receive complaints submitted through the SAPOC on a 24⁄7 basis and generate a ticket in ARI’s case management system (CMS). The details of the complaint (which will at a minimum include the information above) will be documented using a standard information gathering template and forwarded to ARI’s Abuse and Compliance Team.
5. Upon receipt of a complaint, the Abuse and Compliance Team will conduct a preliminary assessment to ensure that a complaint is not spurious. If it is determined that a complaint is not spurious, a member of the team will use the contact details provided in the complaint to acknowledge receipt of the complaint and commence investigation of the subject matter of the complaint and good faith negotiations with the complainant in accordance with the Applicant Guidebook at Trademark PDDRP s7.2.3(d). The results of this preliminary assessment and subsequent actions taken will be recorded against the CMS ticket.
6. On an ongoing basis, ARI’s Abuse and Compliance Team will monitor the email address notified to the Trademark PDDRP provider⁄s for all communications from the Trademark PDDRP provider, including threshold determination, Trademark PDDRP complaint, complainant’s reply, notice of default, expert panel determination, notice of appeal and determination of an appeal panel.
7. In the event that a complaint cannot be resolved and a Trademark PDDRP claim is made, ARI’s Abuse and Compliance Team will do the following:
– File a response to the complaint in accordance with the Applicant Guidebook at Trademark PDDRP s10 thus avoiding (whenever possible) default.
– Where appropriate, undertake discovery in compliance with the Applicant Guidebook at Trademark PDDRP s15, attend hearings raised under s16 if required, and gather evidence in compliance with ss20.5 and 20.6.
8. ARI’s Abuse and Compliance Team will upon notification of an Expert Panel finding in favour of the Claimant (Applicant Guidebook at Trademark PDDRP s14.3), reimburse the Claimant.
9. ARI will implement any remedial measures recommended by the expert panel pursuant to the Applicant Guidebook at Trademark PDDRP s18.3.1 and take all steps necessary to cure violations found by the expert panel (s18.3.2) and notified by ICANN (s21.3).

3.3.2 Implementation of Trademark PDDRP through Contractual Relationships
All new gTLD registry operators are bound to comply with the Trademark PDDRP by Specification 7, cl 2 of the Registry Agreement. In accordance with Requirement 6 of the BITS Requirements, we will certify annually to ICANN our compliance with our Registry Agreement.

4 RESOURCES

ARI’s abuse services are supported by the following departments:
– Abuse and Compliance Team (6 staff)
– Development Team (11 staff)
– Service Desk (14 staff)
A detailed list of the departments, roles and responsibilities in ARI is provided as attachment ‘Q29 – ARI Background & Roles.pdf’. This attachment describes the functions of these teams and the exact number and nature of staff within.
The number of resources required to design, build, operate and support the SRS does not vary significantly with, and is not linearly proportional to, the number or size of TLDs that ARI provides registry services to. 
ARI provides registry backend services to 5 TLDs and has a wealth of experience in estimating the number of resources required to support a registry system. Based on past experience ARI estimates that the existing staff is adequate to support a registry system that supports in excess of 50M domains. Since .SUCKS projects 10049 domains, 0.0205% of these resources are allocated to .SUCKS. See attachment ‘Q29 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI protects against loss of critical staff by employing multiple people in each role. Staff members have a primary role plus a secondary role for protection against personnel absence. Additionally ARI can scale resources as required. 
The measures described in the context of the responses to Question 28 and Question 29 – which serve to prevent and mitigate abusive behaviour in the TLD as well as activities that may infringe trademarks – will be implemented and managed by ARI on our behalf. These responsibilities will be undertaken by two teams. ARI’s Development Team will be responsible for developing the technical platforms and meeting technical requirements needed to implement the RPMs discussed above. ARI’s Abuse and Compliance Team will be responsible for the ongoing operations of measures to minimise abusive registrations and other activities that affect trademark rights recognised through RPMs. ARI’s Service Desk will be responsible for responding to reports of trademark infringement received through the abuse point of contact on the Registry’s website and logging these in a ticket in ARI’s case management system.
The responsibilities of these teams relevant to the initial implementation and ongoing maintenance for our measures to minimise the potential in our TLD for abuse not specifically affecting trademark rights are described in our response to Question 28.
All of the responsibilities undertaken by ARI’s Development Team, Abuse and Compliance Team, and Service Desk are inclusive in ARI’s Managed TLD Registry services fee, which is accounted for as an outsourcing cost in our response to Question 47. The resource needs of these teams have been determined by applying the conservative growth projections for our TLD (as identified in our response to Question 48) to the teams’ responsibilities at startup and on an ongoing basis.

4.1 ARI Development Team
All tools and systems used for the transmission and receipt of information related to RPMs will be developed and maintained by ARI. ARI has a Development Team dedicated to this purpose which will ensure that the tools are fit for purpose and adjusted as requirements change.
ARI will ensure that systems and tools will be compliant with the appropriate processes for dealing with Registrars, the TMCH, URS and Trademark PDDRP providers as these processes are defined. ARI has been and will remain active in the formulating of these processes, using its resources to remain current with the approved measures for exchange of any material relevant to RPMs, whether during sunrise, landrush or on an ongoing basis. This team consists of:
– 1 Development Manager
– 2 Business Analysts
– 6 Developers
– 2 Quality Analysts

4.2 ARI Abuse and Compliance Team
ARI’s Abuse and Compliance Team will be staffed by five full-time equivalent positions:
– 4 Policy Compliance Officers
– 1 Legal Manager
Policy Compliance Officers will be responsible for managing sunrise and landrush applications, supporting the SDRP, TM Claims Service, URS, UDRP and Trademark PDDRP, managing communications with the TMCH, receiving, assessing and managing trademark infringement complaints received through the single abuse point of contact, escalating complaints and issues to the Legal Manager when necessary and communicating with all relevant stakeholders (Registrars, registrants, trademark holders, general public) as needed in fulfilling these responsibilities. This role will be provided on a 24⁄7 basis supported outside of ordinary business hours by ARI’s Service Desk. Policy Compliance Officers will be required to have the following skills⁄qualifications: customer service⁄fault handling experience, complete knowledge of all RPMs offered by the TLD and related policies, Internet industry knowledge, relevant post-secondary qualification, excellent communication and professional skills, accurate data entry skills, high-level problem solving skills, and high-level computer skills.
The Legal Manager will be responsible for handling all potential disputes arising in connection with RPMs and related policies. This will involve assessing complaints and issues, liaising with legal counsel and management, resolving disputes and communicating with all relevant stakeholders (Registrars, registrants, trademark holders, general public) as needed in fulfilling these responsibilities. The Legal Manager will be required to have the following skills⁄qualifications: legal background (in particular, intellectual property⁄information technology law) or experience with relevant tertiary or post-graduate qualifications, dispute resolution experience, Internet industry experience, excellent communication, negotiation, problem solving and professional skills and good computer skills.
For more information on the skills and responsibilities of these roles, please see the in-depth resources section in response to Question 31.
Based on the projections and the experience of ARI, the resources described here are more than sufficient to accommodate the needs of .SUCKS.
The use of these resources and the services they enable is included in the fees paid to ARI, which are described in response to Question 47.

We have engaged ARI Registry Services (ARI) to deliver services for .SUCKS. ARI provide registry services for a number of TLDs including the .au ccTLD. For more background information on ARI please see the attachment ‘Q30a – ARI Background & Roles.pdf’. This response describes Security as implemented by ARI under direction from the registry operator, taking into account any specific needs for .SUCKS.

1 SECURITY POLICY SUMMARY

ARI operates an ISO27001 compliant Information Security Management System (ISMS) for Domain Name Registry Operations; see attachment ‘Q30a – SAI Global Certificate of Compliance.pdf’. The ISMS is an organisation-wide system encompassing all levels of Information Security policy, procedure, standards, and records. Full details of all the policies and procedures included in the ISMS are included in the attachment to Question 30b.

1.1 The ISMS
ARI’s ISMS’s governing policy:
– Defines the scope of operations to be managed (Domain Name Registry Operations).
– Designates the responsible parties (COO, CTO and Information Security Officer) for governance, Production Support Group for implementation and maintenance, and other departments for supporting services.
– Requires a complete Risk Assessment (a developed Security Threat Profile for the Service – in this case registry services for the TLD – and a Risk Analysis tracing threats and vulnerabilities through to Risks) and Risk Treatment Plan (each major risk in the Risk Assessment references the Statement of Applicability indicating controls to be implemented, responsible parties, and the effectiveness metrics for each).
– Includes a series of major sub policies governing security, which include but are not limited to:
 – ICT acceptable use policy and physical security policies.
 – PSG Security Policy which outlines the registry operations policies, the management of end-user devices, classification of networks and servers according to the classification of information they contain, networking, server & database configuration and maintenance guidelines, vulnerability and patch management, data integrity controls, access management, penetration testing, third party management, logging and monitoring, and cryptography.
– Requires ongoing review:
 – Of risks, threats, the Risk Treatment Plan, client requirements and commitments, process and policy compliance, process and policy effectiveness, user etc.
 – Regular internal and external penetration testing & vulnerability scanning.
 – Ad-hoc review raised during normal operations, common sources being change management processes, scheduled maintenance or project debriefs, and security incidents.
 – Yearly review cycle which includes both internal and external audits, including external surveillance audits for compliance.
 – Additional yearly security controls assessment reviews, which include analysis of the security control implementations themselves (rather than compliance with any particular standard).
 – At 24 month intervals, external penetration testing of selected production services.
 – periodic ISO reaccreditation
ARI’s ISMS encompasses the following ARI standards:
– Configuration standards for operating systems, networking devices and databases based on several key publications, including those released by NIST (eg SP800-123, SP800-44v2, SP-800-40, SP800-41) and the NSA, staff testing and experience, and vendor supplied standards.
– Security Incident Classification, which identifies the various classifications of security incidents and events to ensure that events that qualify as security incidents.
– Information Classification and Handling which specifies the information classification scheme and the specific requirements of handling, labelling, management and destruction for each level of classification.

1.2 SECURITY PROCESSES
Processes are used to implement the policies. These include, but are not limited to:

1.2.1 Change Management
This includes change management and its sub-processes for access management, software deployment, release of small changes and scheduled maintenance. This process includes:
– The classification of changes and the flow into sub processes by classification.
– The release and deployment process for change control into production environments, outlining peer review, testing steps, approval points, checklist sets, staging requirements and communication requirements.
– The software release and deployment process with its specific testing and staged rollout requirements.
– The scheduled maintenance process and its various review points.

1.2.2 Incident Management
This includes incident management process and its sub-process for unplanned outages. These outline:
– How incidents are managed through escalation points, recording requirements, communication requirements etc.
– The unplanned outage procedure which applies directly to situations where the registry itself or other critical services are unexpectedly offline.

1.2.3 Problem Management
The goal of problem management is to drive long term resolution of underlying causes of incidents. This process centres on finding and resolving the root causes of incidents. It defines escalation points to third parties or other ARI departments such as Development, as well as verification of the solution prior to problem closure.

1.2.4 Security Incident Management
This process deals with the specific handling of security incidents. It outlines the requirements and decision points for managing security incidents. Decision points, escalation points to senior management and authorities are defined, along with evidence-gathering requirements, classification of incidents and incident logging.

1.2.5 Access Management
This process handles all access changes to systems. HR must authorize new users, and access changes are authorized by departmental managers and approved by the Information Security Officer.
When staff leave or significantly change roles, a separation process is followed which ensures all access that may have been granted during their employment (not just their initially granted access) is checked and where appropriate, revoked.
Finally, quarterly review of all access is undertaken by the ISO, reviewing and approving or rejecting (with an action ticket) as appropriate.

2 ARI’s SECURITY INFRASTRUCTURE SOLUTIONS

ARI has developed a layered approach to IT security infrastructure. At a high level, some of the layers are as follows:
– DDoS countermeasures are employed outside ARI networks. These include routing traps for DDoS attacks, upstream provider intervention, private peering links and third party filtering services.
– Routing controls at the edge of the network at a minimum ensures that only traffic with valid routing passes into ARI networks.
– Overprovisioning and burstable network capabilities help protect against DoS and DDoS attacks.
– Network firewalls filter any traffic not pre-defined by network engineering staff as valid.
– Application layer firewalls then analyse application level traffic and filter any suspicious traffic. Examples of these would be an attempt at SQL injection, script injection, cross-site scripting, or session hijacking.
– Server firewalls on front-end servers again filter out any traffic that is not strictly defined by systems administrators during configuration as valid traffic.
– Only applications strictly necessary for services are running on the servers.
– These applications are kept up-to-date with the latest security patches, as are all of the security infrastructure components that protect them or that they run on.
– ARI infrastructure is penetration-tested by external tools and contracted security professionals for vulnerabilities to known exploits.
– ARI applications are designed, coded and tested to security standards such as OWASP and penetration-tested for vulnerabilities to common classes of exploits by external tools and contracted security professionals.
– ARI configures SELinux on its production servers. Specific details of this configuration is confidential; essentially any compromised application is extremely limited in what it can do.
– Monitoring is used to detect security incidents at all layers of the security model. Specifically:
 – Network Intrusion Detection systems are employed to monitor ARI networks for suspicious traffic.
 – ARI maintains its own host-based Intrusion Detection system based on tripwire, which has now undergone four years of development. Specific details are confidential, but in summary, the system can detect any unusual activity with respect to configuration, program files, program processes, users, or network traffic.
 – More generic monitoring systems are used as indicators of security incidents. Any behaviour outside the norm across over 1,100 individual application, database, systems, network and environmental checks is investigated.
– Capacity management components of the monitoring suite are also used to detect and classify security incidents. Some examples are:
 – Network traffic counts, packet counts and specific application query counts.
 – Long term trend data on network traffic vs. specific incident windows.
 – CPU, Storage, Memory and Process monitors on servers.
– A second layer of hardware firewalling separates application and middle tier servers from database servers.
– Applications only have as much access to database information as is required to perform their function.
– Finally, database servers have their own security standards, including server-based firewalls, vulnerability management for operating system and RDBMS software, and encryption of critical data.

2.1 Physical Security Infrastructure
ARI maintains a series of physical security infrastructure measures including but not limited to biometric and physical key access control to secured areas and security camera recording, alarm systems and monitoring.

3 COMMITMENTS TO REGISTRANTS

We commit to the following:
– Safeguarding the confidentiality, integrity and availability of registrant’s data.
– Compliance with the relevant regulation and legislation with respect to privacy.
– Working with law enforcement where appropriate in response to illegal activity or at the request of law enforcement agencies.
– Maintaining a best practice information security management system that continues to be ISO27001-compliant.
– Validating requests from external parties requesting data or changes to the registry to ensure the identity of these parties and that their request is appropriate. This includes requests from ICANN.
– That access to DNS and contact administrative facilities requires multi-factor authentication by the Registrar on behalf of the registrant.– That Registry data cannot be manipulated in any fashion other than those permitted to authenticated Registrars using the EPP or the SRS web interface. Authenticated Registrars can only access Registry data of domain names sponsored by them.
– A Domain transfer can only be done by utilizing the AUTH CODE provided to the Domain Registrant.
– Those emergency procedures are in place and tested to respond to extraordinary events affecting the integrity, confidentiality or availability of data within the registry.

4 AUGMENTED LEVEL OF SECURITY

.SUCKS is a SRSU TLD (.brand style) and as such requires security considerations that are commensurate with its purpose. Our goal with .SUCKS is to use the TLD internally and adequate protect it against unauthorized registrations or modifications to the namespace, without making the internal process too onerous and thus increasing costs. Whilst, due to the SRSU nature, it is relatively straightforward to restrict and enforce restrictions on registrations, the impact of an unauthorised registration can be high, potentially damaging.
The following attributes describe the security with respect to the TLD:
– ARI, follows the highest security standards with respect to its Registry Operations. ARI is ISO 27001 certified and has been in the business of providing a Registry backend for 10 years. ARI have confirmed their adherence to all of the security standards as described in this application. As per recommendation 24 this ensures that the technical implementations do not compromise elevated security standards
– A single Registrar will be nominated for .SUCKS, facilitating the tightest possible control over Registrant validity enforcement and domain registration restrictions.
– Registrant will only be permitted to make changes to their domain name after a authenticating to their Registrar.
– Registrants will only be able to access all interfaces for domain registration and management via HTTPS. A reputed digital certificate vendor will provide the SSL certificate of the secure site.
– Registrar identity will be manually verified before they are accredited within .SUCKS. This will include verification of corporate identity, identity of individuals involved ⁄ mentioned, and verification of contact information
– Registrars will only be permitted to connect with the SRS via EPP after a multi-factor authentication that validates their digital identity. This is described further ahead.
– Registrars will only be permitted to use a certificate signed by ARI to connect with the Registry systems. Self-signed certificates will not be permitted.
– The Registry is DNSSEC enabled and the TLD zone will be DNSSEC enabled. This is described in detail in our response to question 43. The following additional requirements will exist for Registrars who want to get accredited to sell .SUCKS:
 – Registrars must support DNSSEC capabilities within its control panels.
 – If the Registrar provides Managed DNS services to Registrants within .SUCKS they must provide DNSSEC for the same. This ensures that DNSSEC is deployed at each zone and subsequent sub-zones at Registry, Registrar and Registrant level as per recommendation 26.
– Registrar access to all Registry Systems will be via TLS and secured with multi-factor authentication as per recommendation 27. This is described in detail in our responses to Question 24 and Question 25.
– Registrant access to all Registrar and Registry Systems will be via TLS and secured with multi-factor authentication as per recommendation 28. This is described in detail in our response to Question 25, Question 27 and Question 29.
 – All communication between the Registrar or the Registrars systems and the registry system is encrypted using at least 128 bit encryption which been designated as ‘Acceptable’ till ‘2031 and beyond’ by NIST Special Publication 800-57. This includes the following communication:
 – Secure websites and control panels provided by the Registrar to the Registrant.
 – Ticketing systems provided by the Registrar to the Registrant.
 – Web and EPP interfaces provided by ARI to the Registrars.
 – Ticketing systems provided by ARI to the Registrar.
 – Any communication between the Registrant, Registrar and Registry that is deemed as critical or contains credentials or sensitive information.
Where these requirements put controls on Registrars these will be enforced through the RRA.

5 RESOURCES

This function will be performed by ARI. The following resources are allocated to performing the tasks required to deliver the services described:
– Executive Management Team (4 staff)
– Production Support Group (27 staff)
ARI has ten years’ experience designing, developing, deploying, securing and operating critical Registry systems, as well as TLD consulting and technology leadership.
As a technology company, ARI’s senior management are technology and methodology leaders in their respective fields who ensure the organisation maintains a focus on technical excellence and hiring, training and staff management.
Executive Management is heavily involved in ensuring security standards are met and that continued review and improvement is constantly undertaken. This includes the:
– Chief Operations Officer
– Chief Technology Officer
A detailed list of the departments, roles and responsibilities in ARI is provided as attachment ‘Q30a – ARI Background & Roles.pdf’. This attachment describes the functions of the above teams and the exact number and nature of staff within.
The number of resources required to design, build, operate and support the SRS does not vary significantly with, and is not linearly proportional to, the number or size of TLDs that ARI provides registry services to.
ARI provides registry backend services to 5 TLDs and has a wealth of experience in estimating the number of resources required to support a registry system.
Based on past experience ARI estimates that the existing staff is adequate to support a registry system that supports in excess of 50M domains. Since .SUCKS projects 10049 domains, 0.0205% of these resources are allocated to .SUCKS. See attachment ‘Q30a – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI protects against loss of critical staff by employing multiple people in each role. Staff members have a primary role plus a secondary role for protection against personnel absence. Additionally ARI can scale resources as required. Additional trained resources can be added to any of the above teams with a 2 month lead time.
The Production Support Group is responsible for the deployment and operation of TLD registries. 
The group consists of:
– Production Support Manager (also the ISO)
– Service Desk:
 – 1 Level 1 Support Team Lead
 – 8 Customer Support Representatives (Level 1 support)
 – 1 Level 2 Support Team Lead
 – 4 Registry Specialists (Level 2 support)
– Operations (Level 3 support):
 – 1 Operations Team Lead
 – 2 Systems Administrators
 – 2 Database Administrators
 – 2 Network Engineers
– Implementation:
 – 1 Project Manager
 – 2 Systems Administrators
 – 1 Database Administrators
 – 1 Network Engineers
ARI employs a rigorous hiring process and screening (Police background checks for technical staff and Australian Federal Government ‘Protected’ level security clearances for registry operations staff).