Application number: 1-860-46860 for NetCologne Gesellschaft für Telekommunikation mbH

NetCologne Gesellschaft für Telekommunikation mbH

Am Coloneum 9
Cologne North Rhine-Westphalia 50829
DE

+49 221 2222 0

+49 221 2222 390

http:⁄⁄www.netcologne.de

Mr. Hartmut Schulz

project coordinator

+49 221 2222 228

+49 221 2222 7228

hschulz@netcologne.de

Mr. Dirk Janssen

system engineer

+49 221 2222 619

+49 221 2222 7619

djanssen@netcologne.de

Limited liability company (GmbH: Gesellschaft mit beschraenkter Haftung)

German jurisdiction

Not Available

GEW Koeln AG

Not applicable

Dipl. Ing. Karl-Heinz Zankel
Member of Board of Directors
Dr. Hans Konle
Speaker of Board of Directors

Dipl.-Ing. Dipl.-Wirtsch.-Ing. Hender Bucobo
Head of administration, authorized representative
Dir. Günter Nowitzki
Marketing Director Business Customers, authorized representative

GEW Koeln AG
Not Applicable

koeln

Not Available

The NetCologne GmbH (and Knipp Medien und Kommunikation GmbH as its technical provider) ensured that there are no known operational or rendering problems concerning the applied-for gTLD string ʺkoelnʺ.
Since the gTLD string ʺkoelnʺ is an ASCII-only string, it is safe to assume that, just like with existing ASCII-only TLD strings like .com, .net or .de, no operational or rendering problems may be expected. In particular, the name consists only of ASCII characters that are already used for existing top level domains; all the characters in the name are even used in the leftmost position of existing TLD labels. In order to confirm this, Knipp Medien und Kommunikation GmbH conducted a thorough research regarding whether operational or rendering issues occurred for any existing ASCII-only top level domain in the past. The results of this research confirmed the assumption.
Since the registry does not support right-to-left scripts on the second level, bi-directional issues (like the ones described at http:⁄⁄stupid.domain.name⁄node⁄683) will not occur.
Moreover, the gTLD string exclusively uses characters from a single alphabet, does not contain digits or hyphens, and it contains characters that are not subject to homograph issues, which means there is no potential for confusion with regard to the rendering of other TLD strings.
Finally, Knipp Medien und Kommunikation GmbH set up a testing environment for the .koeln TLD using the TANGO Registration System, including an EPP SRS, Whois and DNS servers, in order to conduct a series of tests involving typical use cases (like web site operation and e-mail messaging) for a TLD. The tests revealed no operational or rendering issues with any popular software (web browsers, e-mail clients) or operating systems.

The mission of the proposed gTLD is two-fold. First and foremost, the new gTLD is aimed to benefit Cologne’s companies, communities and residents as well as the city itself. Secondly, based on how the business model is set out, the introduction of the gTLD is also supposed to supplement NetCologne GmbH’s (in the following “NetCologne”) daily business operations. 

With regard to the city and its residents, the introduction of .koeln provides a new means for companies, communities and residents to express their local sense of belonging. As Cologne is known for its strong local patriotism, it is very likely that the new gTLD will be embraced by the city’s interest groups, who will then have a means to express their identification with Cologne in the web space. However, the benefits for Cologne’s interest groups will be elaborated upon in my more detail in the answers to question 18b. 

Yet, NetCologne’s purpose to host the respective gTLD goes beyond the mere provision of an additional Top Level Domain. When introducing a city TLD for local residents, companies and communities, the respective TLD must be safeguarded against any fraudulent behaviour. Therefore, NetCologne intends to make sure that only organisations, communities and private people with an eligible purpose can register their domain under a .koeln Top Level Domain, so that the city’s reputation sustains. As being a local company, NetCologne believes to be the ideal candidate for this purpose. 

Apart from the primary interest to offer the city and its interest groups a local TLD, hosting .koeln will also strengthen NetCologne’s business operations. NetCologne is planning to use the already established outreach to Cologne’s companies, communities and residents in order to promote .koeln in Cologne and the surrounding area. Thus, besides operating as a registry, NetCologne also intends to engage in reselling activities – of course while granting other registrars the same conditions. NetCologne’s activities as a reseller will be performed in full accordance with the requirements according to Specification 9 no. 2. NetCologne is currently already operating as a provider for various Top Level Domains, so .koeln will add to the already existing portfolio and potentially expand NetCologne’s domain business. Present customers will be able to order their preferred .koeln domain via their already trusted service provider while mere .koeln customers may potentially also turn into customers of NetCologne’s core business units – online and telephony services. 

In order to consider the gTLD’s introduction as successful, NetCologne expects to operate 58,402 .koeln domains by the end of year 5 of registry operations. The forecast on registered .koeln domains is therefore as follows:
Year 1 Year 2 Year 3 Year 4 Year 5
21,065 41,534 49,556 53,287 58,402

This forecast includes the direct sales of domains to accredited registrars, but also the additional sales by NetCologne in combination with already existing Internet products, for example homepage services or webspace. Moreover, this calculation accounts for an annual termination rate of 2%. 

The business case in question 46 will further illustrate which revenues are expected from the registry business, i.e. including NetCologne’s registry and registrar activities. 
It must be noted that NetCologne intends to host the gTLD .koeln in combination with the gTLD .cologne, for which a separate application is submitted. One of the city council’s requirements was that an application for .koeln would have to be made in combination with an application for .cologne – in order to ensure an international presentation of the Internet brand Cologne. Thus, the domain sales forecast for .cologne and the resulting revenues can be found in the respective application for .cologne. In total, .cologne domain sales will supplement .koeln and will lead to additional, despite not comparable, revenue. 

1. Beneficiaries and benefits from the introduction of .koeln

The beneficiaries from the new gTLD .koeln are three groups: the domain users, i.e. companies, communities and private people, the city itself and the engaged registrars. 

1.1 Domain users: companies, communities and private people

The benefits for the local companies, communities and private people have been touched upon in the previous section (18a). Their main benefit therefore is the possibility to adopt a city- own TLD and thus express a local sense of belonging. This becomes increasingly important as the proportion of regional searches in the Internet is constantly growing. Moreover, a study from the Association of the German Internet Economy (Verband der deutschen Internetwirtschaft “eco”) has shown that there is a high degree of interest and acceptance within the German population for new TLDs with a regional character. This should hold especially true for the people living in Cologne, as they are known for their strong local patriotism. Therefore, the introduction of an own city TLD seems appropriate and promising in Cologne.

In addition, these interest groups will be provided with the opportunity to register a particular domain that might not be available anymore under the currently existing TLDs. As the current domain space is very limited, many interested parties do not have the opportunity to register their preferred domain. Especially, local communities, private people and small to medium sized businesses are likely to be in this situation. The introduction of .koeln will therefore mitigate this problem. 

Moreover, especially companies and communities will be able to use .koeln as a means for branding and differentiation, as being present in the web under a gTLD will be considered as highly innovative within the next upcoming years. Therefore, companies and communities will receive the opportunity to differentiate themselves from competitors. 
In addition to the above mentioned, the agreement with Cologne’s city council allows for the provision of domains under .koeln at no charge for non-profit organisations and associations. Thus, non-profit organisations and associations will be able to have a web presence with a local character at no expense. 

1.2 The City: Cologne

Besides the benefits for domain users as listed above, the city, Cologne, will also gain from the introduction of its own TLD. The mere fact of having an own TLD will give Cologne a clear standing as a metropolis that is proud to present itself in the web. Throughout Germany geographic TLDs in general and city TLDs in particular will be considered as highly innovative within the next years due to the fact that very few cities are planning to introduce their own TLD. Therefore, the introduction of .koeln will provide Cologne with a clear source of differentiation. More importantly, .koeln will strengthen the brand Cologne as an Internet brand – in a national and potentially in an international context. Thereby, Cologne can strengthen and boost its economic region. Especially with regard to tourism .koeln is likely to generate positive effects. Moreover, the city council will highly benefit from the new Internet address, under which city relevant institutions, such as the city council itself, can present themselves and their respective services in a modern e-government environment. 

1.3 Registrars:

Lastly, the registrars, on whose cooperation the TLD’s final success depends, will highly benefit from the introduction. Today, Cologne has the second most members of registered .de domains in Germany (based on a comparison between German cities) and a very steady registration growth. This translates into a great revenue potential for registrars. Firstly, because potentially even more people that did not own a domain before become interested in registering their own domain under this very special TLD. Secondly, companies, communities or private people are very likely to wish to register their website under .koeln, in addition to their already existing TLD. Lastly, many interested parties that might have been interested in registering their domain could not do so in the past due to availability issues. However, these will now have the opportunity to register their preferred domain under the new TLD .koeln. Thus, there is a great market potential that will provide registrars with acquisition and cross-selling opportunities. 

NetCologne GmbH (in the following “NetCologne”) has already been in contact with well-known registrars on the German market who have already shown an interest in the .koeln TLD. NetCologne’s pricing strategy towards registrars was discussed in collaboration with registrars. Aim is to generate a high market penetration with .koeln domain. Thus, already established registrars engaged in discussions at which price a high market penetration could be achieved. 


2. Goals of introducing .koeln:

The expected goals from the introduction of .koeln can be summarised from the above mentioned with the following:
- Establishment of a sustainable and relevant competitive advantage for Cologne with regard to location marketing
- Provision of a new and highly differentiated means of presentation on the Internet for the city itself, and its companies, communities and residents
- Provision of a new means of self-awareness and self-confidence for the entire region around Cologne
- Constitution of the Internet brand .koeln


3. .koeln communications plan

In terms of communication, an image campaign has started to be set up which aims to spread the word regarding the availability of the new TLD .koeln. This campaign pursues the following goals: 
- To advertise the TLD .koeln towards Cologne’s residents, companies and communities
- To point out the benefits gained from the introduction of .koeln
- To mobilise supporters that can transport the campaign and its messages to the relevant target audience
- To position the Internet brand .koeln as an information tool about Cologne in a regional, national and international context
- To promote the Internet brand .koeln as an easy, but effective means of location marketing
- To generate a pull effect for .koeln domains

The campaign will be targeted towards the following groups: 
- Supporters (companies, organisations, initiatives)
- Companies, communities and institutions
- Industry associations
- The city Cologne (city council, public institutions, tourism)
- Cologne’s residents
- Opinion leaders (celebrities, opinion leaders from science, politics, culture)
- Tourists 
- The media

The campaign logo includes visual elements associated with Cologne, such as Cologne’s typical city colours (red, white) as well as the symbol of Cologne’s cathedral. Moreover, the visual prominently depicts the “dot”, representing the modern Internet and its possibilities. At the core of each visual there will be people from Cologne, demonstrating their sense of belonging and their commitment to the new domain .koeln. 

The campaign’s underlying message is that .koeln is for everybody in Cologne and the surrounding area: the bakery around the corner, the student, the carpenter or the car manufacturing company. Anybody who feels a sense of belonging to Cologne is granted the opportunity to express this in one of the most important media vehicles – the Internet. This message will be customized for the respective target groups. This means that a message towards, for example, companies will stress the competitive advantage that can be gained, while a message towards the city will focus on better communication with Cologne’s citizens. 

The campaign includes above-the-line, as well as below-the-line marketing activities which are steered via a local advertising agency. The media vehicles which will be used include:
- Social Media
- Website “koeln.de”; “koelner-fuer-koeln.de”
- Billboards
- Press
- Testimonials
- Promotions
- Events
- Merchandising
- Digital Cologne Register

This comprehensive media coverage guarantees a huge outreach and a high level of awareness. A detailed communications plan including specific phases per media vehicle has already been set up in collaboration with the advertising agency. 


4. .koeln Registration Policies

The information laid out below can also be found in the answers to question 27, 28 and 29. 
Registrants wishing to register a .koeln domain will need to do so via an accredited registrar. This registrar will redirect the enquiry towards NetCologne and NetCologne will – if all eligibility requirements are met – transfer the domain into the zone name system. The registrar or a respective provider will serve as the point of contact over the course of the registrant’s registration lifecycle. 

The eligibility requirements are as follows: 
- All information provided by the registrant is fulsome and true
- The domain name registration does not infringe upon the rights of others (e.g. trademarks)
- The registrant has a legitimate interest in the domain name
- The registrant does not act in bad faith

The latter two aspects may not become evident during the registration process. However, in connection with abuse prevention procedures registrars will be asked to react to any complaints arising with regard to rights infringement, lack of legitimate interest and registrations made in bad faith. 

Moreover, registrants will only be able to register a particular domain name, if:
- The name has not yet been registered
- The name is not reserved or blocked
- The name fulfils the technical and lexical requirements, i.e. German text 

As indicated, NetCologne has decided to reserve and block specific terms and names from domain name registration. The decision to reserve certain names at the second level was made in order to protect especially the city’s rights. As will further be laid out in the answer to question 22, NetCologne therefore has granted the city the opportunity to reserve various names at the second level. These include 
- Names of relevant authorities
- Generic terms with relevance for the city
- Names of municipal organisations and holdings
- Urban districts
- Fractions of the city council
- Chambers

The respective names were thoroughly compiled by the city’s representatives. By reserving these names at the second level, NetCologne makes sure that the city’s rights are protected from fraudulent behaviour.

Moreover, as laid out above, NetCologne as a local company intends to protect .koeln from fraudulent registrations and abusive behaviour. Thus, in order to prevent from domain name registrations which are defamatory, racist or in breach of public law, the city council was granted the opportunity to compile a list of names and terms which will be blocked. The compilation of blocked names was conducted by the city council itself, the respective list was bound to the provision of the letter of support. These names and terms will not be available for registration over the entire registry lifespan, i.e. at least for ten years. If however a domain name happens to be registered which is defamatory, racist or in breach of public law a specified process will set in and the respective name will be added to the existing list of blocked names. This process will be laid out in the answer to question 28.

Besides the security measures as pointed out above, NetCologne will ensure that the registrant’s privacy and confidential information is protected. Thus, NetCologne will merely gather, process and use registrant’s data in accordance with data protection regulations. NetCologne is already governed by the Federal Data Protection Act (in German: Bundesdatenschutzgesetz). Since operating in the telecommunications sector, the company is additionally subject to the Telecommunications Act (in German: Telekommunikationsgesetz, TKG) as well as the German Teleservices Act (in German: Telemediengesetz). In addition to the Federal Data Protection Act, the latter two very strictly regulate the handling and use of customer data. Therefore, NetCologne’s registrants’ data will be highly protected.

One decision in order to eliminate social costs has been to assign domains on a first-come first-serve basis. The reason is that NetCologne GmbH (in the following “NetCologne”) introduces the .koeln TLD in order to benefit interested parties especially from the region in and around Cologne. Here, NetCologne wants to provide all prospects with the opportunity to register their preferred domain name. By choosing to resolve multiple applications for a domain by conducting an auction, potentially only privileged registrants would be provided with their preferred domain name. As NetCologne intends to avoid such a situation, a decision has been made in favour of a first-come first-served allocation. 

The pricing model for registrants is, based on the nature of the registry business, only partly in NetCologne’s control. NetCologne has decided to sell a domain for 5.50 EUR per year to all registrars – including NetCologne’s own registrar operations. From there on, it is the respective registrar’s decision at which price to sell a domain.
With regard to NetCologne’s own reseller operations (in accordance with Specification 9 no.2), domains are expected to be primarily sold in combination with other Internet products, for example homepage services or webspace. In this respect, there will be a special price for bundled product packages. In general however, NetCologne intends to sell .koeln domains at 1.49 EUR per domain⁄month.

NetCologne has set out that registrars will be provided with the opportunity to register domain names for their registrants for periods between one to ten years. This means that a registrar has the right to initially register a domain for up to ten years, but in no case for more than ten years. This ruling is in line with requirements from the Registry Agreement. The description of the registration lifecycle will further elaborate on this matter. 

With regard to price increases, NetCologne today cannot make any binding commitment that no price increases will occur over the course of the next ten years. However, price increases will only be based on currency and general economic developments, not on goals of profit maximisation. Yet, if price increases are to occur, NetCologne will inform registrars three months in advance of the increase, so that registrars can inform their respective registrants. In case of a price increase, registrants will be provided with a special right of termination. 

No

Not Available

Yes

1. Reserved List

In accordance with Specification 5, NetCologne GmbH (in the following “NetCologne”) will not allow reservation of the following country and territory names at the second- and other sub-level: 

- The short form in English of all country and territory names contained in the ISO 3166-1list, including all updates made to it 
- The United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardization of Geographical Names, Part III Names of Countries in the World 
- The list of United Nations member states in 6 official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names 

The names of countries and territories specified in the lists above will be reserved at the second and all other levels of the .koeln TLD and thus, will not be available for domain name registration. 

Moreover, NetCologne will grant governments, IGOs and public authorities the possibility to report and challenge abuses of geographical names and names with geographical significance. Reporting will be directed either towards the responsible registrar or towards NetCologne itself. If NetCologne or a registered registrar receives such a complaint by any institution mentioned above, the complaint will be inspected and a decision will be made. More information regarding the reporting process as well as the domain status during this process can be found in the answer to question 28 “Abuse Prevention and Mitigation”. In addition to the country and territory names as specified above, NetCologne will reserve and especially block several domain names in order to protect the geographic name “.koeln” itself. In this respect, the city council has compiled a list of 770 names and terms which will be reserved for the city’s sole use in order to protect the geographic name. These names and terms include:

- Names of relevant authorities
- Generic terms with relevance for the city 
- Names of municipal organisations and holdings 
- Urban districts
- Fractions of the city council 
- Chambers 

Moreover, in accordance with the “GAC Principles regarding new gTLDs” NetCologne has given the city the opportunity to compile a list of names and terms which will be blocked from registration. The compilation of blocked names was conducted by the city council itself, the respective list was bound to the provision of the letter of support. More information on these matters can be found in the answers to questions 28 “Abuse Prevention and Mitigation” and 29 “Rights Protection Mechanisms”. 

Technically, this is achieved by utilising the advanced domain name rule engine that is part of the TANGO Registration System and described in detail in the answer to Question 28. As laid out there, the underlying set of checks can be tuned to block registrations of .koeln names based on various syntactic rules, multiple reserved names lists, and patterns. Prior to the launch of the .koeln TLD, the rule engine will be configured in accordance with the reserved lists mandated by Specification 5 and the city of Cologne, which means that the listed names are not available for registration by registrars.

2. Exceptions

A release of such a domain name as laid out in Specification 5 will merely take place following an agreement with the respective government as well as after official approval by ICANN. This release process will follow the guidelines that have been set out by the GAC. Thus, the relevant authority wishing to reserve its specific name will need to inform the GAC Secretariat. After authentication the GAC Secretariat will transfer the request to ICANN and NetCologne. NetCologne will verify the availability of the name and issue an authorisation number which will be transmitted to the beneficiary, i.e. the registrant. This beneficiary then can register the name with a registrar by providing the authorisation number. In order to ensure that relevant governments and authorities are aware of the process, information regarding the registration of geographic domains will be displayed on NetCologne’s website. Moreover, the process will be documented in the registration policies. 

3. Additional monitoring

The .koeln registry does not plan to monitor use of geographic names below the second level (i.e. subdomains used by a .koeln domain name registrant), as those procedures are both difficult and ineffective. Available dispute resolution mechanisms are a more adequate resolution procedure in cases where third or higher level domains unduly use country or territory names.

1. Overview

Knipp Medien und Kommunikation GmbH will provide the technical registry services for the operations of the NetCologne GmbH. The TANGO Registration System offers the usual registry services for the .koeln TLD: Receipt of data from registrars concerning registration of domain names and name servers via EPP (SRS; see also answer to Question 24, SRS Performance); Dissemination of top-level domain (TLD) zone files (DNS; see also answer to Question 35, DNS service, configuration and operation of name servers); Dissemination of contact or other information concerning domain name registrations (port-43 Whois, web-based Whois; see also answer to Question 26, Whois service); Internationalised Domain Names (see also answer to Question 44, Support for Registering IDN domains); DNS Security Extensions (DNSSEC; see also answer to Question 43, DNSSEC). These services are introduced below. For more detailed descriptions, please refer to the answer to the respective question in the gTLD Applicant Guidebook. Additional benefits offered by the registry are full support for Internet Protocol version 6 (IPv6), data escrow, registrar reports and support for Sunrise and Landrush phases. All of these are compliant with the new gTLD requirements. No further registry services according to the definition in the gTLD Applicant Guidebook are offered for the .koeln TLD.

The Shared Registry System (SRS) is the central coordinating instance in the overall system concept. It is the authoritative source of the domain, host and contact data, provides client⁄server-based access methods for the registrars and internal personnel to this data, is responsible for the zone generation, performs accounting and reporting, and feeds the Whois servers.

The SRS is responsible for managing the domain registrations by accepting requests for the creation, update and deletion of domains and related information from the registrars, who act on behalf of the registrants.

The Knipp Medien und Kommunikation GmbH and its developers have ample experience in designing, developing and operating shared registry systems. The TANGO Registration System is compliant with established standards like Internet Engineering Task Force (IETF) Requests for Comments (RFCs) and can be customised for the specific needs of a top level domain, ensuring Internet Corporation for Assigned Names and Numbers (ICANN) gTLD standards compliance.

As a technical provider for CORE, Knipp is responsible for the technical operation of the .cat and .museum TLDs for the puntCAT and MuseDoma registries. Therefore, Knipp has the knowledge and experience that are necessary to provide the mentioned registry services. Since the software development is handled exclusively in-house, the .koeln Registry Services do not depend on any external companies or developers. Software development at Knipp is always based on principles like efficiency, scalability and security by design.


2. Infrastructure Design


2.1 Goals

The design of the NetCologne GmbH infrastructure achieves three goals:


2.1.1 High Availability

The resolution of domain names by the Domain Name System (DNS) infrastructure is the most critical part. If it fails, not only a large fraction of Internet users is affected, but other Internet infrastructure depends on the domain name resolution as well, causing a cascade of failures.

The shared registry system itself is also in the focus. While theoretically, a short outage would not have a direct and larger impact to the TLD users, a longer outage can become problematic, especially in the light of DNSSEC: If the registry is unable to re-sign the zone in time, the zone will become bogus and the effect will be similar to a failure of the whole DNS infrastructure.


2.1.2 Scalability

The aspects of scalability must be observed for two reasons: The infrastructure must grow with the demand; economic considerations let it seem unreasonable to launch with oversized hardware equipment. The software design must be able to cope with increasing demand, it must allow the long term upgrade of the infrastructure. Scalability must also be provided for unforeseeable load peaks. The infrastructure must be resilient and one step ahead; spare resources must be available.


2.1.3 Security

In an increasingly adverse environment, security is a cardinal goal. Various attack vectors need to be addressed. For example, the public infrastructure must be protected against pure (distributed) denial of service attacks and exploits of bugs in devices, operating systems and application software, and the SRS must be protected against intrusion by third parties with the intent of deletion or manipulation of data or stealing private keys used for DNSSEC.


2.2 Design Principles

The design principles that follow these goals are as follows:

* Shared Registry System (SRS)
** The SRS (actually all services except the name servers) is run on two sites, a primary and a secondary site. These sites are geographically separated for an event of force majeure that makes one of the sites unavailable.
** Fail-over strategies are used systematically, either by the software itself or by employing cluster technologies where applicable.
** Systematic data replication⁄backup⁄escrow is ensured.
** Modularisation of the software and avoidance of monolithic structures improves scalability and maintainability.
** Intrinsic support for multiple instances of software components to distribute load is guaranteed.
** State-of-the-art security technology reduces chances for attackers to a minimum.
** Some components like the Extensible Provisioning Protocol (EPP) interfaces may run in multiple instances. Incoming requests are distributed to these instances with the help of load balancers. Excluding instances one by one allows maintainance in respect to both hardware and software without interrupting the actual service.
* DNS Infrastructure
** Diversity in software and hardware increases security.
** Use of Anycast networks ensures high availability.


3. Features


3.1 Receipt of Data from Registrars

The SRS receives data from the registrars, writes the data into the database and passes on TLD zone files to the DNS services. The registry has a Whois function to make information about contacts and domain registrations available to the general public. DNS and Whois are updated dynamically. The registry TLD name servers receive DNSSEC-signed master zone data.

The .koeln TLD will be operated as a so-called ʺthickʺ registry, i.e. the data for domain registrants, administrative contacts, technical contacts and billing contacts is stored in the registry repository. Registry policy mandates that each domain must be associated with exactly four contacts, one contact of each type. In contrast to a ʺthinʺ registry (which doesnʹt store contact information), this allows the registry Whois service to provide contact information itself, i.e. it doesnʹt rely on registrars to operate their own Whois services for the inquiry of domain contact data.

Registrars can provide the data necessary for the registration of domains, contacts and name servers (hosts) in two ways. Firstly, using the EPP interface of the TANGO Registration System, which allows completely automatic processing of requests. Secondly, there is the option of using a password-protected web interface (ʺControl Panelʺ). The Control Panel offers copious amounts of information and many tools for registrars and registry administrators. Registry objects can be inquired and modified, creating new objects is possible just as easily. In addition, automatically generated reports for registrars are made available for download. Each report contains detailed information about the registry objects of the respective registrar. The Control Panel also allows the administration of registrars. Such administrative functions are of course limited to users belonging to the registry. These can also - their privileges permitting - inspect the tariffs and make corrective entries in the billing system.


3.2 Internationalised Domain Names

The TANGO Registration System supports internationalised domain names (IDN, see RFC 3490, 5890-5894) in several ways.

In the extensible provisioning protocol (EPP), there are various XML elements that expect a domain name. The EPP implementation of the TANGO Registration System accepts domain names in A-label notation (punycode) as well as in U-label notation (unicode). The former notation is preferred; all EPP responses use A-labels, even if the respective request used U-labels.

For more information about IDN support, please refer to the answer to Question 44, Support for Registering IDN Domains.


3.3 DNSSEC

Support of the DNSSEC extension according to RFC 5910 allows to specify the DNSKEY data. The TANGO Registration System calculates the delegation signer (DS) records from the DNSKEY data and adds them to the zone file. Further information about the DNSSEC implementation can be found in the answer to Question 43, DNSSEC.


3.4 IPv6 Support

The NetCologne GmbH infrastructure supports IPv6 on all levels: Firstly, the name servers use IPv6 addresses on the DNS protocol level (port 53), i.e. domain names can be resolved by using the IPv6 protocol. Secondly, the registry software is able to assign IPv6 addresses to in-zone hosts as provided in the EPP Host Mapping (RFC 5732) and to publish these addresses via AAAA records in the zone. Thirdly, registrars can connect to the registry by using the EPP transport protocol via IPv6. Fourthly, the Whois service (both port 43 and web interface) can be accessed via IPv6. Fifthly, the registrar web interface can be accessed via IPv6. Details about the IPv6 capabilities can be found in the answer to Question 36, IPv6 Reachability.


4. Zone Management

Whenever the authoritative data of a domain or host is altered, the change is forwarded to the DNS component and other components. Upon reception of this change, the DNS-specific database tables are updated. The structure of these tables directly corresponds to the structure of the zone file, so that the zone file can be generated with little effort.

The generated zone is then fed into the DNSSEC signing component. Since the zone changes only marginally between the runs, the signing component re-uses RRSIG signatures and NSEC3 name mappings from previous runs. This reduces the run time of the signing process by an order of magnitude on average.

In the next step, the zone is delivered to the ironDNS system, which manages the distribution of the zone to the name servers independently. For more details about this process, please refer to the answer to Question 35, DNS Service.

The whole process is covered by integrity checks. The zone is inspected by heuristic rules, for example, the change in size between the previous and new zone is determined and checked against limits. If there is any evidence that the zone may contain problems, the deployment process is halted and manual inspection by the support team is requested. Where applicable, the distribution is accompanied by safeguards, like cryptographic digests, to allow the detection of changes or truncations.


5. Whois service

The TANGO Registration System contains a public service that can be used to inquire data of registry objects (i.e. domains, contacts, hosts and registrars), the Registration Data Directory Services (RDDS). At the moment, this is implemented as a Whois service. Details regarding the Whois service can be found in the answer to Question 26, Whois service. Abuse of this service is effectively prevented, for details refer to the answer to Question 28, Abuse Prevention and Mitigation.


6. Escrow and Reports

The SRS also handles the monthly reports to ICANN and the generation of escrow files according to ICANNʹs specifications. The reports and escrow files are automatically sent to ICANN and the escrow provider, respectively.

As a technical provider for CORE Internet Council of Registrars, Knipp Medien und Kommunikation GmbH designed, developed and still operates ICANN-compliant escrow services as part of COREʹs shared registry system, which is used to supply registry backend services for the .museum and .cat registries. In this function, Knipp Medien und Kommunikation GmbH has continuously provided (and still provides) reliable registry data escrow services for these registries, helping CORE to be in full compliance with the escrow specifications of the respective ICANN registry agreements.

In the same fashion, Knipp Medien und Kommunikation GmbH also developed and still operates a system that produces registrar escrow files for COREʹs registrar activities, in full compliance with ICANNʹs RDE requirements.

Fully automated daily processes are in place that create the full or incremental XML escrow files as required, then split, sign and encrypt them according to the requirements from ICANN and the escrow agent, and finally transfer the resulting data to the escrow agentʹs server. The escrow files contain the main SRS data, zone data and RDDS⁄Whois data. Knipp Medien und Kommunikation GmbH as a vendor for CORE also provides access to full zone data for the .museum and .cat TLDs to eligible parties upon sign-up to this service. Access is granted to authenticated users via an SSL⁄TLS-secured web interface.

All registry agreements with ICANN require the registry operator to submit a monthly report about the registryʹs activities, inventory and performance to ICANN. Knippʹs registry system is able to create such a report containing (among other things) data about: domain⁄host inventory statistics, domain transfer statistics and domain renewal⁄deletion⁄restore statistics per registrar; service availability, outage durations and response times for SRS, DNS and Whois; Whois request statistics.

In addition, the following reports may be created for each registrar: Inventory report: domain, contact and host objects sponsored by the registrar on a specific date; Transfer report: transfers in progress, completed or rejected on a specific date; Autorenewal report: domains being automatically renewed on a specific date; Billing report: detailed information about every single billing operation that has been performed on the registrarʹs account (including refunds).


7. Support for Sunrise and Landrush Phases

A common problem that arises during the initial launch of a new top level domain (and, potentially, subsequently when new features like IDNs are introduced) is to ensure that trademark owners or otherwise eligible parties can claim their names in an organised manner that can be audited in case of legal disputes. To this end, registries ususally offer a so-called ʺSunriseʺ phase, i.e. a certain period of time during which only eligible parties are allowed to register domain names. Eligibility has to be proved by providing information about a trademark related to the domain name, for example. Such additional information is provided by the registrars during registration of the domain name, with the help of a special EPP extension (see answer to Question 25, Extensible Provisioning Protocol, for details).

The validity of a Sunrise domain name application is checked by an external service provider, the so-called Trademark Clearinghouse. At the time of writing, ICANN has issued a request for information for providers to perform the Trademark Clearinghouse functions. It is envisaged that the TANGO Registration System will use a suitably defined interface of the Trademark Clearinghouse to submit requests according to the trademark data submitted by domain name applicants.

To facilitate the handling of Sunrise applications, the TANGO Registration System is equipped with a built-in issue system that offers registry personnel a convenient web interface to review domain name applications and to approve or reject them accordingly.

The issue system allows searching for applications by various criteria (e.g. domain name or current workflow⁄approval state). It offers a two-level review workflow that allows the delegation of pre-selection tasks to the first level support staff, after which a final decision - if still required - can be made by second level personnel. All application details, including registrant information and all supplied trademark information is conveniently displayed. The issue system fully tracks and documents application status and history, allowing for a complete audit in case of legal issues. Furthermore, it is fully integrated with the registry backend, i.e. it automatically notifies the SRS about the reviewersʹ decisions and immediately activates the respective domain in case of an approval.

The issue system was first used during puntCATʹs elaborate multi-phase Sunrise period in 2006 and proved to be an invaluable tool for efficiently organising a TLD roll-out process.

Another problem registries are facing, mostly during initial launch phases, is the unbiased allocation of domains in case of multiple competing valid applications for the same name. This is predominantly an issue during the so-called ʺLandrushʺ phase (i.e. the beginning of a TLDʹs general availability (GA) when anybody may register a domain), but it may also apply to Sunrise cases in which multiple applicants present valid trademarks or similar proof of eligibility.

In the past, many registries have chosen a simple first-come, first-served approach to handle these situations - the registrar who was able to submit the first registration request after the opening of the GA phase was awarded the name. However, this seemingly fair model not only puts an unnecessary load on the registryʹs server infrastructure, it also gives registrars an unfair advantage if their systems are located closer (in terms of network topology) to the registryʹs SRS. The system also encourages the creation of ʺpseudoʺ registrars just for the purpose of getting more parallel connections to the registry system for fast submission of as many requests as possible.

Consequently, Knipp suggests an alternative, auction-based approach for Landrush situations.

Knippʹs registry system provides the technical infrastructure required to conduct auctions for the assignment of domain names to the highest bidding registrant.

Its core component is an EPP extension that registrars may use to place a bid for a domain name and obtain information about the status of an auction they participate in (refer to the answer to Question 25, Extensible Provisioning Protocol, for more information).

The TANGO Registration System offers built-in support for Sunrise and Landrush phases. In the case of the NetCologne GmbH, both a Sunrise phase and a Landrush phase will be supported.


8. Domain Expiration and (Auto-)Renewal Policies

Domains are registered for a certain interval only. The possible intervals are multiples of a year. The system maintains a so-called ʺexpirationʺ date, which represents the date up to which the registrar has paid the fees for the respective domain. This date is also published on the public Whois servers and is included in reports generated for the registrars.

Domains must be registered at least for a year. The registration period can be extended at any time by issuing a ʺrenewʺ request to the registry. However, the resulting expiration date must be not beyond 10 full years in the future.

Since usually the registrars use the same intervals for their customers, there is always the problem that some customers make up their decisions whether to keep a domain or to delete it at the very end of the registration term. To accommodate the registrars with this problem, it is common practice among the registries to grant a so-called grace period, which starts at the expiration date. During this 45 day period, the registrar may delete the domain without paying any fees for the already started next term. If after 45 days the domain has neither been deleted nor renewed by the registrar, the registry itself automatically renews the domain by one year.


9. Billing

The registry maintains an account for each registrar. All registrations, transfers, renewals and other billable operations have to be prepaid, and corresponding fees are deducted from the registrarʹs account.

Whenever a billable operation is attempted, the registrarʹs account is first checked for sufficient funds. If the account is lacking the required funds, the operation is rejected. A corresponding result code is returned if the rejection affects a realtime EPP command, as opposed to e.g. an internal autorenew operation that was not directly triggered by a registrar command. However, the autorenewal of expired domains is treated differently; to avoid accidental domain deletions, autorenewals are continued even in case of insufficient registrar funds. Non-billable operations (like all read-only commands) and activities that trigger refunds are always executed, regardless of the registrarʹs account balance.

If sufficient funds are available, the operation is executed and the registrarʹs account is charged with the corresponding fee (if the operation was completed successfully).

Each registrar may provide an account balance threshold value. The billing subsystem will automatically send an e-mail containing a ʺlow account balance warningʺ to the registrar whenever the registrarʹs funds drop below the configured threshold value.

Some commands, like domain deletions or transfer cancellations, result in refunds if corresponding grace periods apply. The affected registrarʹs account is immediately credited for each refund.

The billing subsystem utilises its own database, containing tables for registrar accounts (including current balance and warning threshold), tariffs for billable operations along with their validity periods and book entries (each one representing a single credit or debit).

The SRS component responsible for actual registry operation communicates with the billing component. Any billable or refundable event (such as domain creation, domain deletion within grace period, request for domain transfer, domain renewal or autorenewal) results in the lookup of a suitable tariff in the tariff table, the creation of a corresponding record in the book entry table and the update of the registarʹs account.

The entire implementation is carefully designed to ensure billing accuracy. The checking for sufficient funds as well as the processing of book entries representing the billable events are always done within the same database transaction that performs the actual billable repository change, thus ensuring transactional integrity and account consistency.


10. OT+E and Staging Environment

In addition to the production registry system, Knipp Medien und Kommunikation GmbH provides an independent Operational Test and Evaluation (OT+E) system to give registrars the opportunity to develop and test their client software in a self-contained ʺsandboxʺ environment that does not interfere with production business.

The OT+E system emulates the behaviour of the production system as closely as possible to allow for realistic testing. It also includes a Whois server, as well as a name server fed from the sandbox data, which facilitates the testing of transfer policy and DNSSEC implementations on the registrar side, respectively.

The OT+E system differs, however, from the production system in some respects to further simplify development for the registrars: Firstly, each registrar is granted two independent identities on the OT+E system. This enables each registrar to test domain transfers easily by creating domains with the first identity and transferring them to the second identity (or vice versa). Secondly, to allow short turnaround times for registrars during their tests, most of the periods and deadlines used by the production system are significantly shortened (or entirely disabled) on the OT+E system. For example, the OT+E system – contrary to the production SRS – uses an Add Grace Period shorter than 5 days to allow registrars to test domain name redemption more easily.

Apart from the mentioned differences, the OT+E system will always run the exact same software as the production system. Both systems are updated at the same time whenever a new release is deployed.

To facilitate a smooth roll-out of major software upgrades, especially those that involve protocol or policy changes requiring changes to client systems, a separate so-called ʺStagingʺ system is operated, on which these new software versions are deployed with appropriate lead time before the same changes are applied to the production and OT+E systems. The actual lead time depends on the nature and the extent of the changes involved.

The SRS is routinely adapted to improved standards and to cope with new technical, capacity and organisational demands.

Knipp Medien und Kommunikation GmbH has gained a lot of experience as the main contractor working on the CORE Registration System for CORE Internet Council of Registrars. This system is a unified registration system for members of CORE, granting access to a multitude of top-level domain registries, currently including .com, .net, .org, .info, .biz, .name, .us, .asia, .eu, .coop and .tel domains, via a single entry point. The activities for CORE provide Knipp with a great deal of expertise and know-how regarding the implementation, operation, maintenance and support of a shared registration system, facing a very heterogeneous user group regarding location, language, enterprise size and structure. The TANGO Registration System has been developed by Knipp with peculiarities of the new gTLDs in mind.

Knipp as a vendor for CORE is also handling the technical operation of the .cat and .museum TLDs on behalf of the puntCAT and MuseDoma registries. This proves that Knipp has the knowledge and experience necessary to provide the offered registry services.


1. High-Level System Description

The Shared Registry System for the NetCologne GmbH is a local installation of the TANGO Registration System, developed by Knipp. Consequently, the SRS is compliant with the various relevant standards for EPP (s. Question 25), Whois (s. Question 26), DNS (s. Question 35), DNSSEC (s. Question 43) and IDNs (s. Question 44).

Each registry service is handled by its own server. Overall, the services are set up ensuring n+1 redundancy. It is envisaged that further frontends will be added later, when increasing system usage requires such a step.


1.1 Multiple sites

The NetCologne GmbH as a whole is distributed among a set of independent sites. Besides the geographical diversity of the sites, each site is designed to be independent of other sites. A complete failure of one site or of related infrastructure (i.e. upstream providers) does not affect the operation of the others. No networks or vital base services (like DNS resolvers, LDAP or SMTP servers) are shared among the sites.

For the main registry operation, i.e. all services except the name servers, two sites are designated, the primary one in Dortmund, Germany and the secondary one in Amsterdam, the Netherlands. Name servers, as far as operated by the NetCologne GmbH itself, are located on other sites. Other name servers operated by contractors can be seen to be operated on other sites as well in this context.

To support scalability of the system, the SRS is modularised into components where possible. Components are allowed to run on different machines, so that the overall load of the system can be distributed hardware-wise. This approach also improves the efficiency of cluster technologies and fail-over strategies within a site.

Some components, for example the EPP interfaces to the registrars, are allowed to run in multiple instances if necessary. With the help of load balancers, the incoming requests are distributed to these instances. By directing the load balancers to exclude an instance, this instance can be maintained with respect to both hardware and software. The latter allows minor patches to be applied to the SRS software without interrupting the actual service.

Each of the two NetCologne GmbH sites contains the full set of components that are required for operation and provides for redundancy. Under normal conditions, the primary site is active, while the secondary is inactive (components are in hot standby). In case of failure or maintenance that cannot or should not be compensated by redundant systems on the active site, the inactive site can take over the operation. The full switch-over, however, is not a requirement. Since the system consists of multiple subcomponents, the task of a failed subcomponent on one site can be transferred to the mirror subcomponent on the other site, while the other subcomponents remain on the first site. This gives the administration team freedom and flexibility to react to an incident and to minimise the impact on users. Switching of services is done using HSDNS pointers, see the answer to Q32, System and Network Architecture, for details.

The various sites are interconnected by virtual private networks (VPNs). This ensures the security and confidentiality of the communication. The VPNs are used both for data transferred between the sites as part of the NetCologne GmbH operations (e.g. zone files to the name servers, replication data between the databases, data feed of the Whois servers) and for administrative purposes, including monitoring.

In the unlikely event of a simultaneous outage of multiple components that makes it impossible to provide the service at the SRSʹs main operating site (data centre) in spite of the redundancy provided within each site, or in case of natural⁄man-made disaster at that main site, a switch-over to a different site is possible. Thanks to continuous database replication, the other site is equipped with the entire data of the repository.

Figure Q24-F1 presents a ʺbird viewʺ on the registryʹs sites, the services hosted at these sites (as described above), as well as the connections between them. The meanings of the graphical elements and symbols is described in Figure Q24-F2 (which provides a legend for all graphics attached to the answers throughout this gTLD application).

Figure Q24-F3 shows the overall structure of the registry systems per site. The various depicted resources and the relationship between them are described in detail in the answer to Question 31, Technical Overview of Proposed Registry, et seqq.


1.2 Software Development

Like all crucial components of Knippʹs registry system, the SRS has been developed from scratch by Knipp staff. The custom-built main server component consists of 100% Java code. While it utilises a couple of proven, open-source third-party libraries and products (such as SLF4J for logging and PrimeFaces for the web applications), the core registry functionality remains fully under Knippʹs control and may thus be customised as needed.


1.2.1 Change Control

All Java code comprising Knippʹs SRS is maintained in a repository managed by Subversion (SVN), the leading open-source revision control system. All code check-ins into this repository — either into the SVN trunk or into dedicated development branches (for larger additions or changes) — are closely monitored by senior developers.

Software releases meant to be deployed on staging, OT+E or production environments (see below and answer to Question 23, Registry Services) are always built from so-called ʺreleaseʺ branches within the SVN repository, i.e. not from the SVN trunk or development branches. Such branches are essentially snapshots of the code known to offer stable functionality with regard to a certain specification of the system. The exclusive use of these release branches ensures that no inadvertent changes from SVN trunk or development branches are affecting code deployed on systems used by registrars or the public.


1.2.2 Quality Assurance

Each release scheduled to be deployed undergoes a series of extensive tests by an internal QA team within Knipp. This includes functional tests, but also stress tests to evaluate the systemʹs behaviour under extreme load conditions.

Any issues found during these tests are reported back to the developers via JIRA, a widely used, enterprise-grade ticketing and issue system. Only after all issues were fixed to the satisfaction of the testers, a release is deployed — usually on the staging system first (also to give registrars an early opportunity to test their client systems against the new version), then on OT+E and production.

In addition to functional and stress testing, Knippʹs developers also write so-called unit tests with JUnit, a widely used Java unit testing framework that greatly facilitates regression testing.


1.3 Synchronisation Scheme

The synchronisation scheme is designed to enable any of the two sites to act as the master. However, in all cases except emergency and short annual fail-over tests, the system in Dortmund is the master. Data is synchronised on database level in real time.

The database software used will be PostgreSQL 9 (current version). There are four database systems altogether: two at the primary site (Dortmund) and two at the secondary site (Amsterdam). At any time, one of these four systems is active. Its data is replicated to the other three systems: locally to the other system at the same site and remotely to the other site, where a local copy is maintained, too.


2. System Reliability, Stability and Performance


2.1 Outage Prevention


2.1.1 Data Centre Precautions

The data centres hosting the system components of the NetCologne GmbH have taken various precautions to ensure a continuous operation, such as backup power supply, technical and facility security. Please refer to the answer to Question 31, Technical Overview of Proposed Registry, for more details.


2.1.2 Availability by Design

The general system design includes various features to reduce the risk of outages. These are summarised in the following paragraphs.

The network infrastructure of the SRS is designed to compensate a failure of one of its components. This is achieved by doubling each of these components, i.e. the firewall⁄VPN system, the load balancer and the switches that represent the internal backbone. They are operated in an active-active configuration. All servers within the system are equipped with two Ethernet interfaces for each logical connection. Where applicable, the components themselves are equipped with redundant power supplies. The interconnection between the servers and the network components provides redundant paths between each two nodes without a single point of failure. For more details please refer to Question 32, System and Network Architecture.

For the database system used by the SRS, double redundancy is provided. Firstly, there are two database servers, a primary and a secondary one. The secondary database is operated as a hot-standby solution. Secondly, there are two more database servers at the secondary site. The database data at the active site is replicated to the non-active site.

To process the EPP requests of the registrars, multiple systems are provided, which run the SRS software simultaneously. A load balancer distributes the incoming requests to these systems. An outage of one server does not interrupt the service. Although the available computing power is reduced by such an outage, the provisioned spare capacities ensure that the overall performance does not violate the service level agreement.

In the unlikely event of a simultaneous outage of multiple components that makes it impossible to provide the service, or in case of natural⁄man-made disaster at the ʺmainʺ site, a switch-over to the ʺmirrorʺ site is performed. Thanks to continuous database replication, the mirror site is equipped with the entire data of the repository. Depending on the nature of the main siteʹs failure, a limited data loss regarding transactions that were performed in the last few minutes of main site uptime may occur. Compared to the damage caused by a long-term outage, this is considered negligible.

The actual switch-over procedure consists mainly of the following steps: Complete shutdown of the main site if necessary. Despite the failure, some components may still be in an operative state. To avoid interference with the mirror site, these are deactivated. IP address change of the DNS address records belonging to externally visible servers to the corresponding servers on the mirror site. To facilitate this, a short time-to-live (TTL) setting will be used, and registrars are advised to use solely domain names to connect (not IP addresses). Name servers and Whois servers are reconfigured to use the mirror site as their data source. The registrars are informed about the switch-over, enabling them to adapt or restart their clients if necessary.

The Whois subsystem has the intrinsic ability to run an arbitrary number of Whois instances in geographically diverse locations (all fed from the same data source in a near-realtime fashion). The Whois servers operate their own databases for managing the Whois data. Load balancers are used to distribute the incoming requests to these instances. In such a setup, the outage of a single Whois instance will not disrupt Whois services for Internet users. Additional Whois servers can be added quickly to the existing setup if need be.

The huge number of different name server locations used by Knipp and the involved diversity (in terms of both geography and network topology) provide a high degree of inherent protection against DNS outages. In particular, the use of state-of-the-art Anycast methodology ensures that a server will be able to respond to requests as long as at least one of the sites in its Anycast cloud is available. In addition, reliable facilities with sufficient redundancy are provided at the individual sites hosting the name servers.


2.1.3 Hardware supplies and Software Availability

The data centres will keep spare parts for all critical hardware involved, which allows fast replacement in case of hardware failures. In addition, continuous 24⁄7 phone and on-site support from the vendors ensures the availability of hardware and software, including operating systems. Contracts guarantee that out-of-stock components are delivered within hours.


2.2 Performance Specifications

All components of the registry system (SRS, Whois, DNS) are operated in full compliance with ICANNʹs performance requirements as set forth in Specification 10 of the gTLD Applicant Guidebook. In particular, the SRS will meet the following specifications.


2.2.1 SRS Performance

Upper bounds for the round-trip time (RTT) of EPP requests have to be met by at least 90 per cent of all commands. The upper bound for session commands (login, logout) is four seconds, for query commands (check, info, poll, transfer) it is two seconds and for transform commands (create, delete, renew, transfer, update) it is four seconds. The downtime of the EPP service will be not more than 12 hours per month.


2.2.2 Registration Data Directory Services (RDDS) Performance

The upper bound for the round-trip time (RTT) of RDDS queries and for the RDDS update time has to be met by at least 95 per cent of all queries⁄updates. The upper bound for the collective of ʺWhois query RTTʺ and ʺWeb-based-Whois query RTTʺ is two seconds. The upper bound for the update time (i.e. from the reception of an EPP confirmation to a domain⁄host⁄contact transform command until the RDDS servers reflect the changes made) is 60 minutes. The downtime of the RDDS service will be not more than 8 hours per month, where non-availability of any service counts as downtime.


2.2.3 DNS Performance

The upper bound for the round-trip time (RTT) of DNS queries and for the DNS update time has to be met by at least 95 per cent of all queries⁄updates. The upper bound for the TCP DNS resolution RTT is 1500 milliseconds, for the UDP DNS resolution RTT it is 500 milliseconds. The upper bound for the DNS update time (i.e. from the reception of an EPP confirmation to a domain transform command until the name servers of the parent domain name answer DNS queries with data consistent with the change made) is 60 minutes. The downtime of the DNS service will be zero, i.e. continuous availability of this service is assured.


2.3 Operational Scalability

Operational scalability is primarily achieved by the underlying architecture of the components comprising the TANGO Registration System.

The software used for the processing of EPP commands is designed to run on multiple systems simultaneously. Due to the fact that the software makes extensive use of Javaʹs multi-threading capabilities, it scales well with the number of processors in each system. Therefore, long-term scalability due to increased registry activity can be accomplished by extending the system with additional processors and⁄or machines.

The SRS is dimensioned to run with about ten per cent load during regular operation. The initial system is able to handle the additional load resulting from increased domain numbers. To further cope with temporary unexpected load peaks, Knipp ensures that at least 100 per cent spare capacity is available all the time.

The above measures can be applied to scale the system from handling 20000 names to up to 20 million names and beyond. The initial capacity will be 1 million names and can be increased in steps of at least 1 million names within a mutually agreed time frame.

An important point is fair and acceptable use of system resources by registrars. As far as transaction numbers are concerned, the NetCologne GmbH subjects registrars’ access to acceptable use policies that forbid wasteful use of system resources. The registry systematically avoids situations where registrars or potential registrants find themselves under pressure to enter into a race against one another with respect to registry system resources. This applies in particular to launch phases, where a contention resolution mechanism (including the use of auctions) replaces time priority. The NetCologne GmbH furthermore imposes acceptable use restrictions to prevent the abuse of grace periods.

Additionally, the number of concurrent EPP connections per registrar is limited to a certain maximum, which is initially set to 10. Rate limiting is also implemented by limiting the EPP requests within a sliding window of one minute to a configurable number, in order to prevent monopolisation of the service by one registrar.

Thanks to these measures, the NetCologne GmbH avoids disproportionate demand for registry resources.


3. Employed Hardware

For server and storage systems, products of HP are to be used. Network equipment products of CISCO, HP, Juniper and Foundry are to be used. Employment of upgradable blade and RAID systems as well as ensuring redundancy of network components, power supplies and such increases not only scalability, but also availability and data integrity.

The database server as the central system component is dimensioned to be able to keep the relevant database content in memory to avoid slow disk I⁄O operations. An HP server system with 2 six-core 3 GHz CPUs and 48 GB RAM will be used. All other servers will be equipped with 24 GB of RAM. The database server is connected to a storage attached network (SAN), which is connected to a high-performance RAID system, namely HP P6300 EVA 2.4 TB SFF SAS.


4. Resourcing Plans


4.1 Implementation

Since the TANGO Registration System itself has already been implemented, no resources are necessary for the initial implementation. For setting up and configuring database servers, firewalls and so on, the following resource allocations are estimated:

System Administrator: 25 man hours;

Network Operation Center Officer: 25 man hours;

DNSSEC Signing Operator: 5 man hours.


4.2 Ongoing Maintenance

For ongoing maintenance and occasional adaption of the system, the following resource allocations are estimated:

System Administrator: 5 man hours per month;

Network Operation Center Officer: 5 man hours per month;

Software Developer: 2 man hours per month;

Quality Assurance Agent: 1 man hour per month;

DNSSEC Signing Operator: 1 man hour per month.

Employees already working for Knipp Medien und Kommunikation GmbH will be handling these tasks. The numbers above were determined by averaging the effort required for comparable tasks conducted by Knipp in the past over the course of 12 months.

1. Experience

The EPP interface for registrars of the NetCologne GmbH is a part of the TANGO Registration System by Knipp Medien und Kommunikation GmbH. The employees of Knipp have years of experience in operating EPP-based registries. As a vendor for CORE Internet Council of Registrars, Knipp has developed the CORE Registration System, a shared registration system that has been used successfully for several registries.

Since 2006, Knipp handles the backend registry operation for puntCAT (responsible for the .cat top-level domain). Right from the start, the .cat Shared Registration System (SRS) offered an EPP frontend fully compliant with RFCs 3730-3734 (updated to compliance with 5730-5734 in the meantime), using various EPP extensions to cope with puntCATʹs special requirements. The SRS also fully supports the provisioning of DNSSEC data in accordance with RFC 5910; for backward compatibility, the previous DNSSEC EPP extension (RFC 4310) is also supported.

In addition, based on the same technology, Knipp Medien und Kommunikation GmbH as a technical provider for CORE is currently in the process of taking over back-end operations for a country code top-level domain managing between 200,000 and 500,000 domain names. The details of this cooperation cannot be disclosed at the time of writing. While this registryʹs DNS services have already been transitioned to Knipp at this point, the migration of SRS and Whois operations are currently being finalised.

Knipp Medien und Kommunikation GmbH has gained a lot of experience as the main contractor developing the CORE Registration System and as part of the technical operation of CORE Internet Council of Registrars. This system is a unified registration system for members of CORE, granting access to a multitude of top-level domain registries, currently including .com, .net, .org, .info, .biz, .name (with support for domain name and e-mail forwarding addresses), .us, .asia, .cn, .tw, .eu, .mobi, .aero, .me, .tel, .coop, .ch and .li domains, via a single entry point. CORE members can access all supported registries using a single, unified protocol. The CORE Registration System maps the commands issued by the user to the corresponding EPP commands, sends them to the appropriate registry server and translates back the received results. Members do not need to cope with problems regarding registry communication (like different flavours of EPP, SSL⁄TLS certificate handling or Punycode conversion for internationalised domain names) themselves.

Since the CORE Registration System acts as a client regarding all the supported registries, its implementation also allowed Knipp Medien und Kommunikation GmbH to gain considerable experience concerning all client side aspects of (different versions of) EPP. In particular, client-side EPP support had already started with the introduction of EPP by Afilias and Neulevel. On the server side, EPP has been in use since starting the operation of the puntCAT registry some five years ago. At the heart of the EPP implementation lies the so-called Unikit, Knippʹs own EPP toolkit implementation. The Unikit includes code for the client side and for the server side. In the context of the NetCologne GmbH, the server-side part of the Unikit will be used.

In the person of Klaus Malorny, Knipp also actively participated in the IETF Provisioning Registry Protocol (provreg) working group and contributed to some RFCs (see Acknowledgements in RFCs 5730-5733 and RFC 5910).

The software implementing the actual shared registry system, including its EPP interface, was entirely built by Knipp, involving an international team of developers — thus demonstrating the software development skills at Knippʹs disposal.


2. Standards Compliance

The EPP interface of the NetCologne GmbH, provided by the TANGO Registration System, is fully compliant with RFCs 5730-5734. These define mappings for the provisioning and management of Internet domain names, Internet host names and individual or organisational social information identifiers (ʺcontactsʺ) stored in a shared central repository.

Apart from these standards, the NetCologne GmbH also supports the proposed standard for DNSSEC (RFC 5910). This is an EPP extension mapping for the provisioning and management of Domain Name System security (DNSSEC) extensions for domain names stored in a shared central repository.

The proposed standard for an EPP extension for ʺgrace periodʺ policies defined by the Internet Corporation for Assigned Names and Numbers (ICANN) is fully supported also (RFC 3915). Such grace period policies exist to allow protocol actions to be reversed or otherwise revoked during a short period of time after the protocol action has been performed.

Furthermore, a few proprietary EPP extensions are used by the NetCologne GmbH to allow registrars to provide trademark information during the Sunrise phase, auction information during Sunrise and Landrush phases as well as language information. Documentation consistent with RFC 3735 for these proprietary EPP extensions can be found below.

All incoming requests will be validated against the schema definitions in the relevant RFCs and the ones of the proprietary EPP extensions, if applicable. This adds to security and stability, as invalid requests are dismissed early on. The EPP implementation of the NetCologne GmbH is compatible with existing toolkits that produce valid EPP requests.

Pending, asynchronous operations are fully supported by the registry implementation. The SRS returns an EPP result code of 1000 if a command has succeeded synchronously, i.e. immediately. In contrast, a result code of 1001 is returned if a command was accepted but requires asynchronous processing before it can be completed.


3. Stability

A stable EPP interface is very important for smooth operation of a shared registry system. To ensure this, the TANGO Registration System contains a multi-threaded, asynchronous communication implementation allowing a high number of concurrent EPP connections.

The incoming requests are filtered by their IP addresses via firewall rules in order to disallow access from unauthorised sites. This increases not only the security of the system, but also its stability, since the load on the EPP servers is reduced.


4. Equal opportunity

EPP access limitations for registrars are enforced by the TANGO Registration System, allowing a certain number of concurrent connections only. This further enhances the stability of the system and is an important ingredient for equal opportunity as well. Registrars cannot effectively hinder their competitors from connecting by simply opening a great many connections themselves.

For the sake of equal opportunity, the NetCologne GmbH also avoids first-come, first-served (FCFS) policies where possible. This is why the general availability (GA) phase is the only one using this principle. All popular domain names will probably have been registered already when GA starts (during previously conducted launch phases not using FCFS), so FCFS during GA does not contradict the idea of equal opportunity.


5. Proprietary Extensions

Knipp Medien und Kommunikation GmbH has already shown its ability to design, specify and implement proprietary EPP extensions in the context of the puntCAT registry. There, extensions exist for the specification of promotion codes, sponsor e-mail addresses, application objects (used during the Sunrise phase) and poll messages to notify registrars about application outcomes, for example. In the following, the proprietary EPP extensions planned to be used for .koeln are described.


5.1 Extension for Trademark Information during Launch Phases

The TANGO Registration System used to operate the NetCologne GmbH provides a proprietary EPP extension for submitting special data needed during launch phases.


5.1.1 Introduction

This part of this answer describes an extension mapping for version 1.0 of the Extensible Provisioning Protocol (EPP) described in RFC 5730. This mapping is an extension of the domain name mapping described in RFC 5731. It is specified using the Extensible Markup Language (XML) and XML Schema notation.

This extension serves the purpose of supplying and querying information for special phases, usually at the beginning of registry operation. A typical use case is a ʺSunriseʺ phase during which trademark holders have a prerogative to register a domain name related to their trademark. In particular, this extension allows the provisioning of trademark information and the querying of the current status of a domain name application.

In addition, the extension allows the specification of additional information about the application, such as the intended use for the domain name, a URL demonstrating prior use of similar names in other TLDs etc.; the registryʹs Sunrise policy determines whether and how this information is utilized.

An extension to the 〈poll〉 command is not included. Registrars are notified of application results via the poll message mechanism already included in EPP.

This extension has been developed along the lines of the Internet draft by Tan and Brown (see http:⁄⁄tools.ietf.org⁄html⁄draft-tan-epp-launchphase-01). Even though that document is currently only a draft, it serves the purpose needed for the NetCologne GmbH and is clearly a step forward regarding the standardisation of launch phase handling in EPP. Since this draft does not supply a schema definition at the moment, the TANGO Registration System implements its own, which can be found in attachment Q25-Ext-LP.pdf, Section 1. Once the draft was augmented by a concrete schema definition, the TANGO Registration System will be adapted to utilise it, retaining the custom XML namespace identifier. Once the draft becomes an RFC, a transition will be conducted to adopt the standard.


5.1.2 Object Attributes

This extension for launch phases adds additional elements to the EPP domain name mapping. Only new element descriptions are documented here.

Since registries usually allow multiple applications for a particular domain name during launch phases, an application object is used internally. Such an object has a unique ID that is returned upon creation and is used to refer to this application in further requests. Within this extension, an 〈lp:applicationID〉 element is used to specify this ID.


5.1.2.1 Phase

The 〈lp:phase〉 element can be used to distinguish multiple simultaneous launch phases. Its content is a server-defined identifier corresponding to a particular launch phase.


5.1.2.2 Application Status

The 〈lp:status〉 element is used to communicate extended status(es) of the application object, beyond what is specified in the object mapping to which this application object belongs.

The following status values are defined: ʺpendingʺ, the initial state of a newly-created application object; ʺvalidatedʺ, the application meets relevant registry rules; ʺinvalidʺ, the application does not validate according to registry rules; ʺallocatedʺ, the object corresponding to the application has been provisioned (one of two possible end states of an application object); ʺrejectedʺ, the object was not provisioned (the other possible end state).


5.1.2.3 Claim Data

An application may have one or more 〈lp:claim〉 elements. An 〈lp:claim〉 element describes the applicantʹs prior right to the domain name.

The 〈lp:claim〉 element has the boolean ʺpreValidatedʺ attribute, which indicates whether a third party validation agency has already validated the claim. When this attribute has a true value, the 〈lp:pvrc〉 element must always be present.

Several child elements of the 〈lp:claim〉 element are defined. 〈lp:pvrc〉, the Pre-Validation Result Code, is a string issued by a third-party validation agent. 〈lp:claimIssuer〉 contains the ID of a contact object (as described in RFC 5733) identifying the contact information of the authority which issued the right (for example, a trademark office or company registration bureau). 〈lp:claimName〉 identifies the text string in which the applicant is claiming a prior right. 〈lp:claimNumber〉 contains the registration number of the right (i.e. trademark number or company registration number). 〈lp:claimType〉 indicates the type of claim being made (e.g. trademark, symbol, combined mark, company name). 〈lp:claimEntitlement〉 indicates the applicantʹs entitlement to the claim (i.e. owner or licensee). 〈lp:claimRegDate〉 contains the date of registration of the claim. 〈lp:claimExDate〉 contains the date of expiration of the claim. 〈lp:claimCountry〉 indicates the country in which the claim is valid. 〈lp:claimRegion〉 indicates the name of a city, state, province or other geographic region in which the claim is valid. This may be a two-character code from World Intellectual Property Organization (WIPO) standard ST.3.


5.1.2.4 Additional Application Information

An application may carry a 〈lp:applicationInfo〉 element. If present, it contains additional information (beyond the claim) about the application, such as the domain nameʹs intended use.


5.1.3 EPP Command Mapping

This section deals with the specific command mappings for the NetCologne GmbH EPP extension for launch phases.


5.1.3.1 EPP Query Commands

There are four EPP commands to retrieve object information: 〈check〉 to find out whether an object is known to the server, 〈info〉 to ask for detailed information associated with an object, 〈poll〉 to discover and retrieve queued service messages for individual clients and 〈transfer〉 to get transfer status information for an object.


5.1.3.1.1 EPP 〈check〉 Command

This extension does not add any elements to the EPP 〈check〉 command or to the 〈check〉 response described in the EPP domain mapping (s. RFC 5731).


5.1.3.1.2 EPP 〈info〉 Command

This extension adds elements to the EPP 〈info〉 command and response described in the EPP domain mapping for launch phase processing.

The EPP 〈extension〉 element of the 〈info〉 command contains a child 〈lp:info〉 element to indicate that an application object should be queried. It identifies the registry launch phase namespace and the location of the registry launch phase schema. The 〈lp:info〉 element contains the following child elements: 〈lp:applicationID〉, the application identifier for which the client wishes to query, and 〈lp:phase〉 (optional), the phase the application is associated with.

When such an 〈info〉 command has been processed successfully, the EPP 〈extension〉 element in the response contains a child 〈lp:infData〉 element that identifies the registry launch phase namespace and the location of the registry launch phase schema. The 〈lp:infData〉 element contains the following child elements. 〈lp:applicationID〉 contains the application identifier of the returned application. 〈lp:phase〉 (optional) contains the phase the application is associated with. 〈lp:status〉 (optional) contains the status of the application. One or more 〈lp:claim〉 elements (optional) give the submitted data establishing the applicantʹs prior right to the domain name.

If any 〈lp:claim〉 element is present, each of them may contain the following child elements. 〈pvrc〉 gives the Pre-Validation Result Code. 〈claimIssuer〉 contains the ID of a contact object representing the issuing authority. 〈claimName〉 contains the textual representation of the right. 〈claimNumber〉 contains the registration number. 〈claimType〉 contains the type of claim being made. 〈claimEntitlement〉 contains the entitlement. 〈claimRegDate〉 contains the registration date. 〈claimExDate〉 contains the expiry date.

If additional information about the application was specified when the application was created, an 〈applicationInfo〉 element will be present containing that information.

Examples of an 〈info〉 command and corresponding response can be found in attachment Q25-Ext-LP.pdf, Section 2.1. EPP 〈info〉 command, since the TLD Application System (TAS) is not well suited to pre-formatted text.


5.1.3.1.3 EPP 〈poll〉 Command

This extension does not add any elements to the EPP 〈poll〉 command or to the 〈poll〉 response described in the EPP domain mapping (s. RFC 5731).


5.1.3.1.4 EPP 〈transfer〉 Command

This extension does not add any elements to the EPP 〈transfer〉 command or to the 〈transfer〉 response described in the EPP domain mapping (s. RFC 5731).


5.1.3.2 EPP Transform Commands

There are five EPP commands to transform objects: 〈create〉 to create an instance of an object, 〈delete〉 to delete an instance of an object, 〈renew〉 to extend the validity period of an object, 〈transfer〉 to manage object sponsorship changes and 〈update〉 to change information associated with an object.


5.1.3.2.1 EPP 〈create〉 Command

This extension adds elements to the EPP 〈create〉 command and response described in the EPP domain mapping for launch phase processing.

The EPP 〈extension〉 element of the 〈create〉 command contains a child 〈lp:create〉 element to indicate that an application object for a launch phase should be created. It identifies the registry launch phase namespace and the location of the registry launch phase schema. The 〈lp:create〉 element contains the following child elements: 〈lp:phase〉 (optional), the phase the application should be associated with, zero or more 〈lp:claim〉 elements to substantiate the prior rights of the applicant, and an optional 〈lp:applicationInfo〉 element providing additional information about the application, such as the intended use of the domain name.

When such a 〈create〉 command has been processed successfully, the EPP 〈extension〉 element in the response contains a child 〈lp:creData〉 element that identifies the registry launch phase namespace and the location of the registry launch phase schema. The 〈lp:creData〉 element contains a child 〈lp:applicationID〉 element, which informs the registrar about the application ID the server has assigned.

Examples of a 〈create〉 command and corresponding response can be found in attachment Q25-Ext-LP.pdf, Section 2.2. EPP 〈create〉 command, since the TLD Application System (TAS) is not well suited to pre-formatted text.


5.1.3.2.2 EPP 〈delete〉 Command

This extension defines additional elements to extend the EPP 〈delete〉 command described in the EPP domain mapping for launch phase processing. No additional elements are defined for the 〈delete〉 response.

Clients may withdraw an application if permitted by registry policy. To do so, clients submit an EPP 〈delete〉 command along with an 〈lp:delete〉 element to indicate the application object to be deleted. The 〈lp:delete〉 element contains the following child elements: 〈lp:applicationID〉, the identifier of the application to be deleted, and 〈lp:phase〉 (optional), the phase the application is associated with.

An example of a 〈delete〉 command can be found in attachment Q25-Ext-LP.pdf, Section 2.3. EPP 〈delete〉 command, since the TLD Application System (TAS) is not well suited to pre-formatted text.

The TANGO Registration System supports the withdrawal of an application using this extension to the 〈delete〉 command. Note, however, that support for the withdrawal of an application depends on the NetCologne GmbH Sunrise policy, which is described elsewhere.


5.1.3.2.3 EPP 〈renew〉 Command

This extension does not add any elements to the EPP 〈renew〉 command or to the 〈renew〉 response described in the EPP domain mapping (s. RFC 5731).


5.1.3.2.4 EPP 〈transfer〉 Command

This extension does not add any elements to the EPP 〈transfer〉 command or to the 〈transfer〉 response described in the EPP domain mapping (s. RFC 5731).


5.1.3.2.5 EPP 〈update〉 Command

This extension defines additional elements to extend the EPP 〈update〉 command described in the EPP domain mapping for launch phase processing. No additional elements are defined for the 〈update〉 response.

Clients may modify an application if permitted by registry policy. To do so, clients submit an EPP 〈update〉 command along with an 〈lp:update〉 element to indicate the application object to be modified. The 〈lp:update〉 element contains the following child elements: 〈lp:applicationID〉, the identifier of the application to be modified, and 〈lp:phase〉 (optional), the phase the application is associated with.

An example of an 〈update〉 command can be found in attachment Q25-Ext-LP.pdf, Section 2.4. EPP 〈update〉 command, since the TLD Application System (TAS) is not well suited to pre-formatted text.

The TANGO Registration System supports the modification of an application using this extension to the 〈update〉 command. Note, however, that support for the modification of an application depends on the NetCologne GmbH Sunrise policy, which is described elsewhere.


5.1.4 Formal Syntax

The formal syntax of this EPP extension is a complete schema representation of the object mapping suitable for automated validation of EPP XML instances. The schema definition is listed in attachment Q25-Ext-LP.pdf, Section 1. Schema Definition (Formal Syntax), since the TLD Application System (TAS) is not well suited to pre-formatted text.


5.2 Extension for Auction Information

The TANGO Registration System used to operate the NetCologne GmbH provides a proprietary EPP extension for submitting special data needed for auctions as they occur after launch phases (e.g. Sunrise and Landrush).


5.2.1 Introduction

This part of this answer desribes an extension mapping for version 1.0 of the Extensible Provisioning Protocol (EPP) described in RFC 5730. This mapping is an extension of the domain name mapping described in RFC 5731. It is specified using the Extensible Markup Language (XML) and XML Schema notation.

This extension serves the purpose of supplying and querying information for special phases, usually at the beginning of registry operation. A typical use case is a ʺSunriseʺ phase during which trademark holders have a prerogative to register a domain name related to their trademark.

Registries usually allow multiple applications for a particular domain name during launch phases. This extension helps to resolve such situations by means of an auction in an automated way. This is not a normal auction, however, insofar as every application has a ʺbidʺ associated with it. Bids cannot be modified after the phase the application belongs to has ended. Among all valid applications for a given domain name, the one with the highest bid wins the auction.


5.2.2 Object Attributes

This extension for auctions adds additional elements to the EPP domain name mapping. Only new element descriptions are documented here.

This extension allows the provisioning of auction information in the form of bids. A bid can be made when applying for a domain name. In case there is more than one valid application, an auction mechanism is used as a tie-breaker. The highest bid submitted for the domain name in question will win the auction.


5.2.2.1 Bid

The 〈auction:bid〉 element is used to set and inform about a bid for a domain name. Its content is the amount of money the applicant is willing to pay for the domain name in case of an auction. The currency is given in the required currency attribute, specified by the corresponding ISO 4217 currency code.

Note that the amount is given as a non-negative number. This allows to submit a bid of zero in case the applicant is not interested in an auction at all.


5.2.3 EPP Command Mapping

This section deals with the specific command mappings for the NetCologne GmbH EPP extension for auctions.


5.2.3.1 EPP Query Commands

There are four EPP commands to retrieve object information: 〈check〉 to find out whether an object is known to the server, 〈info〉 to ask for detailed information associated with an object, 〈poll〉 to discover and retrieve queued service messages for individual clients and 〈transfer〉 to get transfer status information for an object.


5.2.3.1.1 EPP 〈check〉 Command

This extension does not add any elements to the EPP 〈check〉 command or to the 〈check〉 response described in the EPP domain mapping (s. RFC 5731).


5.2.3.1.2 EPP 〈info〉 Command

This extension does not add any elements to the EPP 〈info〉 command described in the EPP domain mapping. Additional elements are defined for the 〈info〉 response.

When an 〈info〉 command has been processed successfully, the EPP 〈extension〉 element in the response, if present, contains a child 〈auction:infData〉 element that identifies the registry auction namespace and the location of the registry auction schema. The 〈auction:infData〉 element contains an 〈auction:bid〉 element, which informs about the amount and currency of the currently set bid as described above.

An example of an 〈info〉 response can be found in attachment Q25-Ext-Auction.pdf, Section 2.1. EPP 〈info〉 command, since the TLD Application System (TAS) is not well suited to pre-formatted text. The included example simply retrieves the current bid for the given domain name.


5.2.3.1.3 EPP 〈poll〉 Command

This extension does not add any elements to the EPP 〈poll〉 command or to the 〈poll〉 response described in the EPP domain mapping (s. RFC 5731).


5.2.3.1.4 EPP 〈transfer〉 Command

This extension does not add any elements to the EPP 〈transfer〉 command or to the 〈transfer〉 response described in the EPP domain mapping (s. RFC 5731).


5.2.3.2 EPP Transform Commands

There are five EPP commands to transform objects: 〈create〉 to create an instance of an object, 〈delete〉 to delete an instance of an object, 〈renew〉 to extend the validity period of an object, 〈transfer〉 to manage object sponsorship changes and 〈update〉 to change information associated with an object.


5.2.3.2.1 EPP 〈create〉 Command

This extension defines additional elements to extend the EPP 〈create〉 command described in the EPP domain mapping for auction processing. No additional elements are defined for the 〈create〉 response.

The EPP 〈extension〉 element of the 〈create〉 command contains a child 〈auction:create〉 element to indicate that auction information should be submitted. It identifies the registry auction namespace and the location of the registry auction schema. The 〈auction:create〉 element must contain an 〈auction:bid〉 element, which specifies the amount and currency as described above.

An example of a 〈create〉 command can be found in attachment Q25-Ext-Auction.pdf, Section 2.2. EPP 〈create〉 command, since the TLD Application System (TAS) is not well suited to pre-formatted text. The included example sets the bid when applying for the given domain name to the specified amount.


5.2.3.2.2 EPP 〈delete〉 Command

This extension does not add any elements to the EPP 〈delete〉 command or to the 〈delete〉 response described in the EPP domain mapping (s. RFC 5731).


5.2.3.2.3 EPP 〈renew〉 Command

This extension does not add any elements to the EPP 〈renew〉 command or to the 〈renew〉 response described in the EPP domain mapping (s. RFC 5731).


5.2.3.2.4 EPP 〈transfer〉 Command

This extension does not add any elements to the EPP 〈transfer〉 command or to the 〈transfer〉 response described in the EPP domain mapping (s. RFC 5731).


5.2.3.2.5 EPP 〈update〉 Command

This extension defines additional elements to extend the EPP 〈update〉 command described in the EPP domain mapping for auction processing. No additional elements are defined for the 〈update〉 response.

The EPP 〈extension〉 element of the 〈update〉 command contains a child 〈auction:update〉 element to indicate that auction information should be updated. It identifies the registry auction namespace and the location of the registry auction schema. The 〈auction:update〉 element must contain an 〈auction:bid〉 element, which specifies the new amount and currency as described above.

Whether all modifications of bids are allowed, only certain ones (e.g. only increases) or none at all depends on the NetCologne GmbH auction policy, which is described elsewhere.

An example of an 〈update〉 command can be found in attachment Q25-Ext-Auction.pdf, Section 2.3. EPP 〈update〉 command, since the TLD Application System (TAS) is not well suited to pre-formatted text. The included example modifies the bid for the given domain name.


5.2.4 Formal Syntax

The formal syntax of this EPP extension is a complete schema representation of the object mapping suitable for automated validation of EPP XML instances. The schema definition is listed in attachment Q25-Ext-Auction.pdf, Section 1. Schema Definition (Formal Syntax), since the TLD Application System (TAS) is not well suited to pre-formatted text.


5.3 Extension for Language Information

The TANGO Registration System used to operate the NetCologne GmbH provides a proprietary EPP extension for internationalised domain names (IDNs).


5.3.1 Introduction

This part of this answer desribes an extension mapping for version 1.0 of the Extensible Provisioning Protocol (EPP) described in RFC 5730. This mapping is an extension of the domain name mapping described in RFC 5731. It is specified using the Extensible Markup Language (XML) and XML Schema notation.

This extension serves the purpose of supplying and querying information for internationalised domain names. In particular, the language or script used and domain name variants are addressed.


5.3.2 Object Attributes

This extension for IDNs adds additional elements to the EPP domain name mapping. Only new element descriptions are documented here.


5.3.2.1 Languages and Scripts

This extension allows the specification of either a language tag or a script tag when registering a domain name. The language or script defines the characters allowed for use in the domain name as specified in the IDN tables (see Question 44, Support for Registering IDN Domains). It is not allowed to specify more than one language or more than one script.

For the time being, the NetCologne GmbH expects the value of a language tag element to be a an ISO 639-1 language code referring to a supported language. The value of a script tag is expected to be an ISO 15924 script code referring to a supported script.


5.3.2.2 Variants

This extension allows to specify a number of variants of the domain name to be registered together with the supplied domain name.

At the moment, the NetCologne GmbH does not support any languages with variants. Nevertheless, the IDN EPP extension already provides a means to specify variants. This feature allows the introduction of further languages with variants in the future without having to extend this EPP extension or even introduce another. An important motivation for the TANGO Registration System to put the language tag and the variants together in one extension is to limit the number of extensions. This improves adoption and acceptance by registrars and reduces their EPP extension-related work, especially if they connect to multiple registries run by the TANGO Registration System, some of which offer variants while others do not.

Until languages with variants are introduced, the variants part of this extension is required to be empty by registry policy.


5.3.3 EPP Command Mapping

This section deals with the specific command mappings for the NetCologne GmbH EPP extension for IDNs.


5.3.3.1 EPP Query Commands

There are four EPP commands to retrieve object information: 〈check〉 to find out whether an object is known to the server, 〈info〉 to ask for detailed information associated with an object, 〈poll〉 to discover and retrieve queued service messages for individual clients and 〈transfer〉 to get transfer status information for an object.


5.3.3.1.1 EPP 〈check〉 Command

This extension defines additional elements to extend the EPP 〈check〉 command described in the EPP domain mapping for IDN processing. No additional elements are defined for the 〈check〉 response.

The EPP 〈check〉 command is used to determine if an object can be provisioned within a repository. This IDN extension modifies base check processing to support language and script tags.

The EPP 〈extension〉 element, if present, contains a child 〈idn:check〉 element that identifies the registry IDN namespace and the location of the registry IDN schema. If at least one of the checked domains is an IDN, the 〈idn:check〉 element must contain either an 〈idn:lang〉 element or an 〈idn:script〉 element. The 〈idn:lang〉 element contains the language whose characters may be used in the checked domain names; the 〈idn:script〉 element contains the script whose characters may be used in the checked domain names. The language or script specification applies to all domain names specified in the command. The results of the check (i.e., the domains namesʹ availability for provisioning) are governed by the validity of the names with respect to the specified language or script.

Examples of 〈check〉 commands can be found in attachment Q25-Ext-IDN.pdf, Section 2.1. EPP 〈check〉 command, since the TLD Application System (TAS) is not well suited to pre-formatted text. Two examples are included, one with a language tag (Section 2.1.1), one with a script tag (Section 2.1.2).


5.3.3.1.2 EPP 〈info〉 Command

This extension does not add any elements to the EPP 〈info〉 command described in the EPP domain mapping. Additional elements are defined for the 〈info〉 response.

When an 〈info〉 command has been processed successfully, the EPP 〈extension〉 element in the response, if present, contains a child 〈idn:infData〉 element that identifies the registry IDN namespace and the location of the registry IDN schema. The 〈idn:infData〉 element contains either an 〈idn:lang〉 element or an 〈idn:script〉 element. The 〈idn:lang〉 element contains the language that is set for the domain name object; the 〈idn:script〉 element contains the script that is set for the domain name object.

The 〈idn:infData〉 element also contains an 〈idn:variants〉 element, which in turn contains a (possibly empty) sequence of 〈idn:nameVariant〉 elements. The 〈idn:nameVariant〉 elements represent the variants that are registered together with the actual domain name.

Examples of 〈info〉 responses can be found in attachment Q25-Ext-IDN.pdf, Section 2.2. EPP 〈info〉 command, since the TLD Application System (TAS) is not well suited to pre-formatted text. Three examples are included, one with a language tag only (Section 2.2.1), one with a script tag only (Section 2.2.2) and one with a language tag and variants (Section 2.2.3).


5.3.3.1.3 EPP 〈poll〉 Command

This extension does not add any elements to the EPP 〈poll〉 command or to the 〈poll〉 response described in the EPP domain mapping (s. RFC 5731).


5.3.3.1.4 EPP 〈transfer〉 Command

This extension does not add any elements to the EPP 〈transfer〉 command or to the 〈transfer〉 response described in the EPP domain mapping (s. RFC 5731).


5.3.3.2 EPP Transform Commands

There are five EPP commands to transform objects: 〈create〉 to create an instance of an object, 〈delete〉 to delete an instance of an object, 〈renew〉 to extend the validity period of an object, 〈transfer〉 to manage object sponsorship changes and 〈update〉 to change information associated with an object.


5.3.3.2.1 EPP 〈create〉 Command

This extension defines additional elements to extend the EPP 〈create〉 command described in the EPP domain mapping for IDN processing. No additional elements are defined for the 〈create〉 response.

The EPP 〈create〉 command provides a transform operation that allows a client to create an instance of a domain object. This IDN extension modifies base create processing to support language tags, script tags and domain name variants.

The EPP 〈extension〉 element, if present, contains a child 〈idn:create〉 element that identifies the registry IDN namespace and the location of the registry IDN schema. The 〈idn:create〉 element must contain either an 〈idn:lang〉 element or an 〈idn:script〉 element. The 〈idn:lang〉 element contains the language whose characters may be used in the domain name; the 〈idn:script〉 element contains the script whose characters may be used in the domain name.

The 〈idn:create〉 element must also contain an 〈idn:variants〉 element, which in turn contains a (possibly empty) sequence of 〈idn:nameVariant〉 elements. The 〈idn:nameVariant〉 elements represent the variants that are to be registered together with the actual domain name.

Note that the NetCologne GmbH restricts the number of domain name variants given in the 〈idn:variants〉 element to at most 10. Submitting an empty 〈idn:variants〉 element is allowed; this will not register any domain name variants.

Examples of 〈create〉 commands can be found in attachment Q25-Ext-IDN.pdf, Section 2.3. EPP 〈create〉 command, since the TLD Application System (TAS) is not well suited to pre-formatted text. Three examples are included, one with a language tag only (Section 2.3.1), one with a script tag only (Section 2.3.2) and one with language tags and variants (Section 2.3.3).


5.3.3.2.2 EPP 〈delete〉 Command

This extension does not add any elements to the EPP 〈delete〉 command or to the 〈delete〉 response described in the EPP domain mapping (s. RFC 5731).


5.3.3.2.3 EPP 〈renew〉 Command

This extension does not add any elements to the EPP 〈renew〉 command or to the 〈renew〉 response described in the EPP domain mapping (s. RFC 5731).


5.3.3.2.4 EPP 〈transfer〉 Command

This extension does not add any elements to the EPP 〈transfer〉 command or to the 〈transfer〉 response described in the EPP domain mapping (s. RFC 5731).


5.3.3.2.5 EPP 〈update〉 Command

This extension defines additional elements to extend the EPP 〈update〉 command described in the EPP domain mapping for IDN processing. No additional elements are defined for the 〈update〉 response.

The EPP 〈update〉 command provides a transform operation that allows a client to change the state of a domain object. This IDN extension modifies base update processing to support domain name variants.

The EPP 〈extension〉 element, if present, must contain a child 〈idn:update〉 element that identifies the registry IDN namespace and the location of the registry IDN schema. The 〈idn:update〉 element may contain an 〈idn:add〉 element and an 〈idn:rem〉 element. Each of these contain a (possibly empty) sequence of 〈idn:nameVariant〉 elements. Similar to the 〈update〉 commandʹs elements 〈domain:add〉 and 〈domain:rem〉, these are used to specify the domain name variants that are to be added to and removed from the domain object, respectively. If the EPP 〈extension〉 element is missing in the 〈update〉 command, no change to the domain name variants will be made.

Note that the NetCologne GmbH restricts the number of domain name variants given in the 〈idn:add〉 and 〈idn:rem〉 elements to at most 10.

An example of an 〈update〉 command can be found in attachment Q25-Ext-IDN.pdf, Section 2.4. EPP 〈update〉 command, since the TLD Application System (TAS) is not well suited to pre-formatted text. The included example adds some variants to be associated with the given domain name while removing existing ones at the same time (Section 2.4.1).


5.3.4 Formal Syntax

The formal syntax of this EPP extension is a complete schema representation of the object mapping suitable for automated validation of EPP XML instances. The schema definition is listed in attachment Q25-Ext-IDN.pdf, Section 1. Schema Definition (Formal Syntax), since the TLD Application System (TAS) is not well suited to pre-formatted text.


6. Resourcing plans


6.1 Initial Work

No resources are necessary for the initial implementation, since the TANGO Registration System (including the EPP extensions) has already been implemented.


6.2 Ongoing Work

For registrar support regarding the EPP extensions, the following resource allocations are estimated:

First Level Support: 4 man hours per month.

Employees already working for Knipp Medien und Kommunikation GmbH will be handling these tasks. The numbers above were determined by averaging the effort required for comparable tasks conducted by Knipp in the past over the course of 12 months.

1. Overview

The TANGO Registration System used by Knipp Medien und Kommunikation GmbH to operate the .koeln TLD will offer Registration Data Directory Services (RDDS) in compliance with Specification 4 of the Registry Agreement, consisting of a Whois Service, Zone File Access and Bulk Registration Data Access.


2. Whois Service


2.1 Interfaces


2.1.1 Port 43 Whois Service

Whois data for .koeln will be accessible via an interface on TCP port 43 at whois.nic.koeln, using the ʺWhoisʺ protocol (as defined in RFC 3912).

While the interface is publicly available, general use is rate limited to prevent data mining and mitigate denial of service attacks. Registrars may request to be exempted from the rate limiting measures by specifying IP addresses or address ranges to be put on a whitelist. Clients sending Whois requests from whitelisted IP addresses have unlimited access to the service.


2.1.1.1 Input Format

The input sent by Whois clients to the port 43 Whois server consists of two parts: the query options (starting with a hyphen character) and the query itself.

By default, the port 43 Whois service searches for domain names and name server names matching the query string. By the following keywords, the search type can be specified explicitly:

* ʺdomainʺ: Search for domains with matching names or IDs.
* ʺnameserverʺ: Search for name servers with matching names, IDs or IP addresses.
* ʺcontactʺ: Search for contacts with matching IDs.
* ʺregistrarʺ: Search for registrars with matching IDs or organisation names.

The remaining tokens in the input are taken as the search parameter. It may contain the percent sign (‘%’) as a wildcard for any number (including zero) of characters or the underscore character (‘_’) for a single character. For data mining prevention and resource protection, the number of objects returned for wildcard searches is limited to 50.

Evidently, the query format resulting from this input format specification is fully compliant with Specification 4, since it allows querying

* domains via: whois example.koeln,
* registrars via: whois ʺregistrar Example Registrar, Inc.ʺ,
* name servers via: whois ʺns1.example.koelnʺ and
* name servers via: whois ʺnameserver (IP Address)ʺ.


2.1.1.2 Output Format

The Whois implementation used by Knipp follows a template-based approach for its output to achieve maximum flexibility with regard to the desired format. Key-value output templates containing well-defined placeholders (e.g., for domain name, registrar name, name servers, or contact fields) for variable data allow customising the output for each response type to meet ICANNʹs demands. To supply values for the placeholders in the templates, the local Whois database is fed with all properties of registrars, domains, contacts and name servers that need to be present in the Whois output. Metadata such as the ʺlast Whois updateʺ date, is also available for use in templates. Thanks to this template mechanism, adjustments for changing requirements over time may be implemented easily.

Additionally, the Whois implementation supports internationalised output. If a contact uses ʺlocalisedʺ address fields in addition to ʺinternationalisedʺ data (as supported by RFC 5733), some data fields may contain non-US-ASCII characters. Also, internationalised domain names (IDN) allow the use of non-US-ASCII characters.

The results of a Whois query are encoded using either the US-ASCII character set, or, if a valid character set has been specified via the -C query option, the selected character set. If the output contains characters for which no encoding exists in the selected character set, they are replaced with a question mark, and a warning comment is added to the beginning of the output. Please see the answer to question 44 for more information about IDN support.

The format for values such as dates, times and phone⁄fax numbers in the Whois output conforms to the mappings specified in the EPP RFCs 5730-5734, since the SRS enforces compliant values for requests from registrars, stores them as received and feeds them to the Whois instances unmodified.

Overall, this means that the response formats for domains, registrars, and name servers, as described in ICANNʹs Specification 4 of the Registry Agreement, are fully supported by the Whois implementation used by Knipp.


2.1.2 Web-based Whois Service

The web Whois service operated at whois.nic.koeln shares the same functionality as the port 43 service, but receives query input via an HTML form. The output format is the same as for the port 43 service.

To prevent the Web interface from being abused for data mining, a CAPTCHA test (ʺCompletely Automated Public Turing test to tell Computers and Humans Apartʺ) must be passed upon each web Whois query before any response data is displayed.


2.2 Searchable Whois

Knippʹs Whois implementation offers search capabilities in accordance with Specification 2, Section 1.8. They allow complex searches for Whois database records based on the content of various data fields, thereby considerably exceeding common Whois query functionality.

This provides powerful means of information retrieval, such as finding all domain names registered by a certain person or company. When made available to unauthorised parties, this data may be abused for undesirable activities such as data mining (e.g. for advertising purposes) or social profiling. Restrictions must be imposed to prevent such abuse.

Consequently, this feature is offered exclusively on the web-based Whois interface (not the port 43 Whois), and is only available to authenticated users after they logged in by supplying proper credentials (i.e., user name and password). The NetCologne GmbH will issue such credentials exclusively to eligible users and institutions that supply sufficient proof of their legitimate interest in extended Whois searches, like e.g. law enforcement agencies. Authorisation policies and procedures are established in close collaboration with ICANN, and in compliance with any privacy laws and policies that may apply.

The search capabilities offered meet and exceed the requirements of Specification 2:

* Searches using the wildcards ʹ%ʹ and ʹ_ʹ (with semantics as described above) are possible on the following fields (thus allowing partial matches):
** domain name
** contact data (across all contact types, including the registrant):
*** name
*** organisation
*** address fields (street, city, state⁄province, postal code, country code)
* Exact match searches are possible on the following fields:
** registrar ID
** name server name
** name server IPv4 or IPv6 address (if stored in the registry for glue records)
* Multiple such search criteria may be joined by the logical operators (listed in descending precedence):
** NOT
** AND
** OR

The web interface offers a graphical editor for convenient creation of complex searches, allowing to group sets of search criteria in order to override the defined precedence of operators (thus providing the equivalent of parentheses in classic boolean expressions).

The search results are presented as a list of domain names matching the criteria. If more than 50 results are found, only the first 50 matches are presented on the initial result page, along with an indication of the total number of matches. Links allow the user to navigate through pages of search results.


2.3 Whois Data Distribution

The Whois implementation used by Knipp is written as an autonomous system component running in its own server instance, i.e. it is not part of the server running the SRS component. Multiple Whois instances, all serving the same SRS data, are run in parallel; these instances may be located in diverse locations (both geographically and in terms of network topology).

All instances of the Whois service operate on their own databases. This ensures a load decoupling between the SRS and the Whois servers - high request rates on the Whois servers will not affect the main registry systemʹs performance, and vice versa.

The database of a Whois server is continuously synchronised with the registryʹs database via a VPN connection. A special communication protocol (ʺWhois feedʺ) is used to supply information about objects that have been created, modified or deleted in the SRS to all connected Whois servers.

As soon as changes to the registryʹs database have been made persistent, these changes are forwarded to all Whois servers. The Whois servers update their own databases with the data and publish the new information. This way, changes to the registry will become visible on the Whois server typically in less than a minute, resulting in an RDDS update time well under the 60 minutes permitted by Specification 10.

The Whois feed protocol has been carefully designed to allow a graceful recovery from temporary SRS⁄Whois disconnections. In case of a communication problem or a maintenance of the Whois instance, changes that occurred since the last successful update are automatically identified and transferred.


2.4 Network Structure

The Whois network structure (for queries and the feed) is depicted in Figure Q26-F1.

The green path shows how a Whois instance is continuously fed with data from the SRS. To obtain updates, a Whois server instance (D) in the Demilitarised Zone (DMZ) maintains a TCP connection to the EPP backend (B) in the Trust zone through a firewall (C) which separates the two zones. The EPP backend fetches the required data from the primary SRS database (A) and sends a corresponding feed data stream to the Whois instance.

The yellow path illustrates the data flow of Whois queries. A port 43⁄web query coming in from the Internet enters the Untrust zone via a network router (1) and passes a firewall (2) into the DMZ. A load balancer (3) dispatches the request to one of the available Whois instances (4), which processes the requests and sends the response back to the Whois client or web browser.

As the server hardware and network setup planned for the Whois subsystem is part of the overall registry infrastructure, it shares its design principles and implementation. Please see the answers to Questions 31 and 32 for further details.


2.5 Inner Workings of a Whois Server Instance

The inner structure of a Whois server instance is depicted in Figure Q26-F2. It shows how incoming port 43 or web traffic from a load balancer (at the top) is processed internally.

Port 43 queries are handled by the RFC 3912 protocol implementation. A rate limiter component ensures that query limits are enforced for connections not originating from whitelisted IP addresses. Non-blocked requests are passed on to a query evaluator component, which parses the request, fetches required data from the instanceʹs local database engine and prepares the response based on the configured output templates. A separate statistics collector module gathers query statistics (such as query type and response time) in dedicated database tables; this data is used to create monthly ICANN reports.

Web-based queries are handled in a similar fashion. Clients connect to the Whois web frontend; if both the CAPTCHA and the rate limiter component are passed, the query from the web form is processed and answered (as well as included in statistics) just like port 43 requests. For this purpose, the web application container hosting the web Whois has direct access to the local database engine, i.e. it does not utilise the port 43 implementation, but processes requests autonomously. In contrast to the port 43 server, the web Whois also contains an LDAP authentication component; it is used to validate the credentials of users logging in for accessing the extended search features described above.

The bottom of the diagram shows the Whois feed client component, which is responsible for maintaining a connection to the Whois feed service of the EPP backend, processing the feed data and updating the local Whois database.


2.6 Whois Data Privacy Measures

The Whois server implementation used by Knipp is designed to support various levels of privacy regarding the content of query responses.


2.6.1 Consideration of EPP Data Disclosure Preferences

The EPP 1.0 standard, particularly its contact mapping as described in RFC 5733, provides means for registrars to specify their preferences concerning the handling of contact data submitted to the registry. Using optional 〈contact:disclose〉 elements when creating or modifying contacts, the registrar is able to identify contact fields that require special handling regarding their disclosure to third parties.

The Whois service is designed to respect the data disclosure preferences specified by registrars using these mechanisms. Unless registry policy dictates otherwise, contact fields will be included in or excluded from the Whois output according to the respective disclosure setting. The governing registry policy will be carefully tuned to be in line with applicable data protection laws.


2.6.2 Web Whois

The Whois serverʹs web interface uses the same output restrictions as the port 43 interface.

The CAPTCHA mechanism used to let only humans (as opposed to machines) access the Web whois provides protection against Whois data abuses like data mining or spam. As an additional guard against spam, any e-mail addresses within the Whois output can optionally be displayed as images only (instead of HTML text).


2.7 Support for Emerging Technologies

Knipp is aware of the shortcomings in todayʹs RDDS technology. The Whois protocol, as defined in RFC 3912, only defines the basic exchange between client and server, without any specification of input and output formats. This has led to a large number of different output formats among registries, posing problems for automated Whois clients.

In September 2011, ICANN’s Security and Stability Advisory Committee (SSAC) published SAC 051, a Report on Domain Name Whois Terminology and Structure. It contains recommendations for a domain name registration data access protocol suitable for replacing the current Whois technology. In February 2012, ICANN published a draft roadmap for the implementation of these recommendations. Knipp is committed to participate in this process, and to comply with and fully support any future RDDS technologies (such as an XML-based, RESTful Whois) emerging from it.


2.8 Whois Resiliency and Performance

Thanks to the Whois subsystemʹs intrinsic ability to run an arbitrary number of Whois instances in geographically diverse locations (all fed from the same data source in a near-realtime fashion), it offers considerable resiliency. In such a setup, the outage of a single Whois instance will not disrupt Whois services for Internet users.

The same feature also guarantees a high level of scalability and performance. Should the monitoring system operated by Knipp suggest an increased demand for Whois queries for names in the .koeln TLD, additional Whois servers can quickly be added to the existing setup. The decoupling of SRS and Whois services described above ensures that bursts in Whois usage will not impact SRS performance. Using such scaling measures if need be, even unusual peak volumes can be handled.

Please see the answer to question 34 (Geographic Diversity) for details about the locations planned for .koeln Whois instances.

In the initial setup, each Whois instance is capable of handling up to 500 queries per second. It is assumed that the average load will be at most 100 queries per second, so there is sufficient headroom for future load increases and bursts.


2.9 Compliance with Specification 10 of the Registry Agreement

The technical features described above ensure that the RDDS (Whois) implementation provided by the TANGO Registration System for .koeln will be in full compliance with Specification 10 of the Registry Agreement. RDDS availability, query round trip time (RTT) and update time will be maintained well within the permissible limits.

Due to the unpredictable complexity of searches conducted using wildcards or boolean operators, it is assumed that they are not used in queries for measuring RDDS availability and query RTT. Also, the service levels for these two metrics are only guaranteed for queries returning a maximum of 10 results.


3. Zone File Access

Knipp will enter into standardised agreement with Internet users seeking access to .koeln zone file data by following the procedures laid out in Specification 2, Section 2. For this purpose, the SRS prepares a .koeln zone data file compliant with the specified File Format Standard, which is made available at the ICANN-specified and managed URL (i.e. ftp:⁄⁄koeln.zda.icann.org). Through facilitation of the CZDA provider, users presenting sufficient credentials will be granted access to this data. Full cooperation and assistance will be provided to ICANN and the CZDA provider in this context.

In addition, bulk access to the zone files for .koeln will also be provided to ICANN or its designee, as well as to the Emergency Operators on a continuous basis.


4. Bulk Registration Data Access

As described in the answer to question 38 (Data Escrow), the Escrow module of the TANGO Registration System is capable of creating files containing Thin Registration Data, as well as Thick Registration Data restricted to the domain names of a single registrar. Using this facility, Knipp will grant ICANN periodic access to Thin Registration Data, as well as exceptional access to a failing registrarʹs Thick Registration Data, in a format and on a schedule fully compliant with Specification 2, Section 3.


5. Experience in providing ICANN-compliant Whois services

As a technical provider for CORE Internet Council of Registrars, Knipp designs, develops and operates Whois services as part of COREʹs SRS, which is used to supply registry backend services for the .cat and .museum registries. In this function, Knipp has continuously provided (and still provides) reliable Whois services for these registries, helping CORE to be in full compliance with RFC 3912 and ICANN registry agreements.

The experience gathered from these previous Whois related activities enables Knipp to develop and operate a Whois subsystem for the NetCologne GmbH that is fully compliant with all ICANN requirements.


6. Resourcing Plans

The TANGO Registration System already supports the Whois services as described above at the time of writing. Since the system is designed to be highly configurable, the realisation of different privacy policies merely requires changing the respective settings within the system configuration.

This means that no development resources will be needed for the Whois service during the initial setup of the system. However, the staff on duty at Knipp will need to define the related policies and configure the system accordingly.


6.1 Initial implementation

For the initial setup, the following resources are allotted:

* Registry Policy Officer: finalising policies, creating documentation: 1.5 man days
* System Administrator: configuring system for policies: 4 man hours
* First Level Support: training: 2 man hours per person


6.2 Ongoing maintenance

For the ongoing system maintenance, the following resources are allotted:

* System Administrator: system maintenance: 0.5 man days per month
* First Level Support: support: 6 man hours per month
* Second Level Support: access authorisation: 5 man hours per month

Employees already working for Knipp Medien und Kommunikation GmbH will be handling these tasks. The numbers above were determined by averaging the effort required for comparable tasks conducted by Knipp in the past over the course of 12 months.

The TANGO Registration System used by Knipp Medien und Kommunikation GmbH to operate the .koeln TLD implements a registration life cycle that conforms with best practices and procedures widely used by existing top level domain registries. While the life cycle fully complies with all relevant EPP RFCs, it also simplifies the processing of automatic domain renewals in order to ease domain data management for registrars.

The attached state diagram (Figure Q27-F1) depicts the typical life cycle of a .koeln domain during the General Availability phase, from its creation to its release. In the following, the various triggers, states and transitions involved in the registration life cycle (denoted by capital letters in parentheses) are described in detail. Blue boxes denote domain states, yellow boxes denote actions caused by registrar commands, grey boxes denote automatic actions by the system, white boxes denote timed conditions reached at some point in the life cycle.


1. Domain Creation

(A) After receiving a 〈domain:create〉 command from the registrarʹs EPP client, the specified domain name is checked for availability and compliance with the registryʹs rules and policies. If these checks are passed, a corresponding domain object is created in the repository. Its expiration date is set according to the registration period specified in the 〈domain:create〉 command (1-10 years) and the EPP commandʹs time stamp.

With its creation, the domain also enters the Add Grace Period (AGP), which lasts 5 days; during this time frame, the registrar may delete the domain for a full refund of the registration fee (as long as the limits specified by the AGP Limits Policy are not exceeded). Also, a domain deleted during the AGP will not enter the Redemption Grace Period (RGP), but will instead be released immediately. To indicate the AGP, the domainʹs Grace Period (GP) status according to RFC 3915 is set to ʺaddPeriodʺ; this status is automatically removed after the end of the AGP. The AGP does not apply to Sunrise and Landrush Periods. 

(B) The domain is registered. Provided that at least two name servers are present in the domain and the domain has not been put into status ʺclientHoldʺ or ʺserverHoldʺ, it is published in the TLD zone and carries the EPP status ʺokʺ. If no name servers are associated with the domain, the domain carries the EPP status ʺinactiveʺ to indicate that no delegation information is present. Note that a .koeln domain may either have zero name servers or 2-13 name servers; the case of exactly one name server is prohibited by server policy. In any case, the domainʹs current data is published on the Whois server (according to the disclosure settings set by the registrar).


2. Domain Update

(C) After receiving an EPP 〈domain:update〉 command, the domain is modified in the repository according to the data specified in the command. The domain returns to the registered state (B). Should the update change the domainʹs name servers or its ʺclientHoldʺ status, its publication in the TLD zone is affected according to the condition described in state (B). An update command may set other domain status values, such as ʺclientDeleteProhibitedʺ; see below for a full list of all supported status values. The TLD name servers and Whois servers are updated to reflect the domainʹs new data.


3. Domain Renewal (Automatic or Explicit)

(D) If a domain reaches its expiration date, it is automatically renewed; it will not be deleted, but remains in the registered state. Note that, in order to avoid unduly disruption of the domainʹs operation, this automatic renewal will even take place if the domain carries the status ʺclientRenewProhibitedʺ; this status will only disallow the explicit renewal of domains.

(E) With reaching its expiration date, the domain enters the so-called ʺAuto Renew Grace Periodʺ (ARGP), which lasts 45 days. During this time period, the registrar has the opportunity of deleting the domain name without being charged for the renewal. In order to avoid the necessity of a refund in this case, the TANGO Registration System only charges the registrar with the renewal fee after the end of the ARGP (i.e., when the renewal is final). If the registrar deletes the domain during the Auto Renew Grace Period, nothing has been charged yet, so no refund is required either. Note that this differs from the commonly used practice of charging the renewal fee already at the beginning of the Auto Renew Grace Period, which requires complicated refunds in case the domain is deleted or transferred in this period. During the Auto Renew Grace Period, the domain carries the ʺautoRenewPeriodʺ GP status, which is also displayed in the Whois along with the previous expiration date (now in the past). Only after the end of the Auto Renew Grace Period, the expiration date is increased.

(F) If the end of the ARGP is reached before the registrar deletes the domain, the registrar is charged with the renewal fee. The domainʹs ʺautoRenewPeriodʺ GP status is removed.

(G) After explicit renewal (or final automatic renewal), the domainʹs expiration date is increased. The domainʹs Whois output is changed to reflect this.

(H) If the registrar explicitly renews a domain by sending a 〈domain:renew〉 EPP command, the TANGO Registration System increases the domainʹs expiration date according to the period value specified in the command. Note that a domainʹs remaining registration period may not last more than 10 years; renewal requests that would make a domain exceed this limit are rejected. The registrar is charged with the corresponding renewal fee. The domainʹs ʺRenew Grace Periodʺ is started, which lasts 5 days; during this period, the domain may be deleted for a full refund of the renewal fee. This is indicated via the ʺrenewPeriodʺ GP status, which is automatically removed when the Renew Grace Period ends.


4. Domain Deletion

(I) After receiving an EPP 〈domain:delete〉 command, the deletion of the domain from the repository is initiated.

(J) If the domain is in its AGP when the delete command is received, it will be released immediately, i.e. it will be available for new registrations right away. The domain will not enter the Redemption Grace Period (RGP) in this case, and the registrar receives a refund of the registration fee (as long as the limits specified by the AGP Limits Policy are not exceeded).

(K) The domain is released (i.e., purged from the repository) and available for new registrations. This marks the end of the domainʹs life cycle. If the domain was in its Add, Auto Renew, Renew or Transfer Grace Period when the delete command was received, the related charges are refunded to the sponsoring registrar.


5. Domain Restore After Deletion - the Redemption Grace Period (RGP)

(L) If the domain is not in its AGP when the delete command is received, it enters the Redemption Grace Period (RGP), which lasts 30 days. This means that the domain is not released immediately, but is only put into the EPP status ʺpendingDeleteʺ (which is also displayed in the domainʹs Whois output) and withheld from DNS publication.

The TANGO Registration System fully supports the Redemption Grace Period procedures and protocols, as defined by RFC 3915. During the RGP, the domain may be restored by the previous registrar by sending a 〈domain:update〉 command carrying an EPP RGP extension according to the RFC.

(M) The domain is in the Redemption Grace Period (RGP). During this phase, it is not present in the TLD zone. The domain carries the EPP status ʺpendingDeleteʺ and the RGP status ʺredemptionPeriodʺ according to RFC 3915.

(N) If the domain is not restored by the previous registrar before the end of the RGP, the domain will be scheduled for release. The EPP status ʺpendingDeleteʺ is retained, the domainʹs RGP status is changed to ʺpendingDeleteʺ.

(O) The domain is no longer restorable by the registrar and due for release. It will remain in this state for a time period defined by registry policy; this could, for example, be a variable time period with a random offset in order to make the release date and time less predictable for domain snipers. Once this time period ends, the domain is released and put into the final state (K).

(P) If the previous registrar restores the domain before the end of the RGP (by sending a 〈domain:update〉 command carrying an EPP RGP extension according to RFC 3915), the domainʹs RGP status is changed to ʺpendingRestoreʺ. If the registrar also sends the RGP restore report within 5 days (or along with the update command), the ʺpendingDeleteʺ status value is removed from the domain and the domain will be put back into the registered state (B). If the conditions described under (B) are met, the domain will be re-added to the TLD zone. If, however, the restore report is not received within 5 days, the domain goes back into the RGP (RGP status ʺredemptionPeriodʺ), i.e. into state (M); the RGP is not restarted in this case, but is resumed at the point when the restoration was initiated by the registrar.


6. Domain Transfer

(Q) Upon request by a domainʹs registrant, a registrar (called ʺgainingʺ registrar in this case) may request to transfer a domain name currently sponsored by a different registrar (the so-called ʺlosingʺ registrar) into its own domain portfolio. This is done by sending an EPP 〈domain:transfer〉 command with operation ʺrequestʺ. After receiving such a command, the domain is marked with a ʺpendingTransferʺ EPP status value. 〈domain:trnData〉 EPP poll messages are placed in the message queues of both gaining and losing registrar to inform them about the transfer request. The gaining registrar is charged with the transfer fee.

A request for a domain transfer will only succeed if certain conditions are met. In particular, the provided authorisation information must be correct, and the domain must not have the ʺclientTransferProhibitedʺ or ʺserverTransferProhibitedʺ status values set. Note that the status ʺserverTransferProhibitedʺ is automatically set and maintained for 60 days by the SRS after a domain is first created, as well as after each successful registrar transfer. This is common practise among registries and avoids the problem of ʺregistrar hoppingʺ, i.e. frequent registrar changes (after e.g. hijacking a domain name) in order obstruct takedown procedures.

(R) The domain transfer is pending. The TANGO Registration System waits for either the transfer to time out (after 5 days), or for the reception of an approval, rejection or cancellation before the time-out. The losing registrar may approve or reject the transfer by sending an EPP 〈domain:transfer〉 command with operation ʺapproveʺ or ʺrejectʺ, respectively. The gaining registrar may cancel the transfer by sending an EPP 〈domain:transfer〉 command with operation ʺcancelʺ.

(S) The transfer was completed successfully, either by approval of the losing registrar or by time-out (which by default automatically approves the transfer; this behaviour is configurable). The ʺpendingTransferʺ EPP status value is removed from the domain. The domain is assigned to the gaining registrar and removed from the losing registrarʹs portfolio. 〈domain:trnData〉 poll messages are placed in the message queues of both gaining and losing registrar. The domain returns to status (B). A successful transfer starts the domainʹs ʺTransfer Grace Periodʺ (TGP) which lasts 5 days; during the TGP (which is indicated by the ʺtransferPeriodʺ GP status), the domain may be deleted by the gaining registrar for a full refund of the transfer fee.

(T) The transfer was unsuccessful, i.e. it was rejected by the losing registrar or cancelled by the gaining registrar. The EPP status ʺpendingTransferʺ is removed from the domain. 〈domain:trnData〉 poll messages are placed in the message queues of both gaining and losing registrar. The domain returns to status (B). The transfer fee previously charged to the gaining registrar is refunded.


7. EPP and Grace Period Status Values

As described above, the .koeln domain life cycle involves various EPP Domain and Grace Period status values and uses them in compliance with RFCs 5730-5733 and 3915 (note that RFC 5910 does not specify any status values). This section provides an overview of the status values and describes whether and how they are used in the life cycle.

In general, status values starting with ʺclientʺ may only be set or removed by the registrar, while all other status values (including those starting with ʺserverʺ) may only be set or removed by the registry, either automatically or manually by registry staff.


7.1 EPP Domain Status Values (from RFC 5731)

* clientDeleteProhibited: Indicates that the domain cannot be deleted by a 〈domain:delete〉 command.
* clientHold: Indicates that the domain is not published in the .koeln zone.
* clientRenewProhibited: Indicates that the domain cannot be renewed by an explicit 〈domain:renew〉 command; the status does not prevent automatic renewal.
* clientTransferProhibited: Indicates that the domain cannot be transferred.
* clientUpdateProhibited: Indicates that the domain cannot be modified.
* inactive: The domain has no delegation information, i.e. no name servers are associated. The domain is not published in the .koeln zone.
* ok: The domain is active, i.e. it resolves, has no pending operations or prohibitions, and carries no other status values.
* pendingCreate: Indicates that the domainʹs creation is pending, i.e. that an asynchronous process is in progress to finish the domainʹs creation. This status is supported, e.g. for use during launch phases such as Sunrise and Landrush (to indicate that a domain applicationʹs asynchronous review is pending); please refer to the answer to question 29 (Rights Protection Mechanisms) for more information about the special life cycle support offered by the TANGO Registration System for launch phases.
* pendingDelete: Indicates that the domain is being deleted; depending on its RGP status (see below), it may be restorable or not.
* pendingRenew: Indicates that the domain is pending a renewal. While supported by the TANGO Registration System, this status not used in the designated .koeln domain life cycle.
* pendingTransfer: Indicates that the domain is in the process of being transferred from one registrar to another registrar.
* pendingUpdate: Indicates that an update to the domain is pending, i.e. that an asynchronous process is in progress to finish the domainʹs modification. While supported by the TANGO Registration System, this status not used in the designated .koeln domain life cycle.
* serverDeleteProhibited: Indicates that the domain cannot be deleted.
* serverHold: Indicates that the domain is not published in the .koeln zone.
* serverRenewProhibited: Indicates that the domain cannot be renewed by an explicit 〈domain:renew〉 command; the status does not prevent auto-renewal.
* serverTransferProhibited: Indicates that the domain cannot be transferred. This status is automatically set and maintained for 60 days by the SRS after a domain is first created, as well as after each successful registrar transfer.
* serverUpdateProhibited: Indicates that the domain cannot be modified.


7.2 EPP Grace Period Status Values (from RFC 3915)

* addPeriod: Indicates that the domain is in the Add Grace Period.
* autoRenewPeriod: Indicates that the domain is in the Auto Renew Grace Period.
* renewPeriod: Indicates that the domain is in the Renew Grace Period.
* transferPeriod: Indicates that the domain is in the Transfer Grace Period.
* pendingDelete: Indicates that a deleted domain is scheduled for release, i.e. it can no longer be restored by the registrar.
* pendingRestore: Indicates that a request to restore a deleted domain has been received, and that the registry awaits the restore report from the registrar.
* redemptionPeriod: Indicates that a deleted domain is in its Redemption Grace Period, i.e. it may be restored by the registrar.


8. Consistence with Commitments to Registants

The registration life cycle described above is consistent with the registryʹs commitments to registrants, as laid out in the answer to Question 30a. In particular, the handling of auto-renewals and the Redemption Grace Period ensures the ʺProtection of Investmentʺ part of that commitment, since it protects the domain from vanishing unintendedly.


9. Resourcing Plans

The TANGO Registration System already supports the life cycle described above at the time of writing. Since the system is highly configurable, the adjustment of any variables and flags defining the process (such as name validity policies, or the durations of involved grace periods and time-outs) merely requires changing the respective settings within the system configuration. No coding is required for this, which means that no special developing resources will be needed. However, the staff on duty at Knipp Medien und Kommunikation GmbH will need to define the related policies and set up the system to support and maintain the desired registration life cycle.

For the initial setup, the following resources are allotted:

* Registry Policy Officer: finalising policies, creating documentation: 3 man days
* System Administrator: configuring system for policies: 4 man hours
* First Level Support: training: 3 man hours per person

For the ongoing maintenance, the following resources are allotted:

* System Administrator: 4 man hours per month

Employees already working for Knipp Medien und Kommunikation GmbH will be handling these tasks. The numbers above were determined by averaging the effort required for comparable tasks conducted by Knipp in the past over the course of 12 months.

As the registry backend provider for .koeln, Knipp Medien und Kommunikation GmbH will work in close cooperation with the NetCologne GmbH to establish thorough and effective methods to prevent abuse of .koeln domain names, .koeln registrant data or the associated infrastructure, as well as to mitigate any impact from such abuse (should it occur despite the preventive measures). In order to achieve this, the NetCologne GmbH and Knipp Medien und Kommunikation GmbH are committed to deploy extensive organisational and technical measures; these are described in the following.


1. Rapid Takedown Policy for Cases of Malicious Activity

The NetCologne GmbH (and Knipp Medien und Kommunikation GmbH as its technical provider) are committed to closely collaborate with law enforcement authorities and security agencies in order to take quick action in case a .koeln name is reported to be involved in malicious activity. For this purpose, a ʺRapid Takedown Policyʺ is established that

* identifies cases of malicious activity,
* defines ways for the registry to be notified of such activity (e.g. via a dedicated web site, e-mail address or phone hotline),
* defines clear and consistent procedures to quickly stop the malicious activity (after the activity was confirmed and impact of the measures has been assessed),
* defines related service levels (e.g. with respect to the maximum time the registry may take to respond to takedown requests),
* defines rules regarding the notification of involved parties (registrant, administrative contact, technical contact, registrar, informant, the public),
* defines ways to appeal against any measures taken,
* defines how cases covered by the policy need to be documented and reported.

In this context, cases of malicious activity may include (but are not limited to)

* wrong, invalid or harmful DNS setup (e.g. pointers to false IP addresses),
* use of trademarked or otherwise reserved names without proper rights,
* use of the domain in actions that affect the stability and security of the Internet (e.g. in Denial of Service (DoS), Distributed Denial of Service (DDoS) attacks or botnets),
* use of the domain for the distribution of malware (such as computer viruses, worms, Trojan horses, spyware or rootkits),
* use of the domain for phishing or scamming,
* use of the domain for spamming (affecting e-mail or other forms of electronic messaging),
* maintaining invalid registrant contact data in the domain.

Where applicable, the policy includes metrics and thresholds for finding quantitative indications of malicious conduct.

Procedures to stop malicious activity may include (but are not limited to)

* notifying the domainʹs sponsoring registrar, specifying a deadline until which the activity needs to be ceased,
* notifying the domainʹs registrant, administrative or technical contact directly (again specifying a deadline until which the activity needs to be ceased),
* locking the domain and putting it on hold in order to prevent changes to the domain and to remove it from the .koeln zone (ʺtakedownʺ),
* deleting the domain name and blocking it from further registration if need be.

Escalation rules (defining which steps are to be taken in which order and conditions for moving on to the next, more drastic measure) are part of the policy.

Since removing a domain name from the .koeln zone usually has serious consequences (such as rendering web sites and e-mail addresses utilising the domain name unusable), the NetCologne GmbH (and Knipp Medien und Kommunikation GmbH as its technical provider) will, in accordance with the policy, exercise extreme caution with regard to any takedown decision. At the same time, the NetCologne GmbH is aware that malicious activity potentially affects a large number of Internet users, which sometimes warrants drastic measures. The Rapid Takedown Policy aims at finding appropriate measures, taking the interests of all involved parties into consideration.

The Rapid Takedown Policy will be announced to both .koeln registrars and .koeln registrants and be part of the Registry-Registrar Agreement (RRA) and the .koeln registration terms.


1.1 Specifics for .koeln

In addition to the above, the following applies.

According to NetCologne abusive behaviour comprises

* Trademark infringement
* Lack of legitimate interest
* Proof of bad faith

Cases of trademark infringement will in any case be handled in compliance with the resolution processes set out by ICANN and through the respective service providers. Therefore the definition of trademark infringement also rests upon ICANN.

A legitimate interest is considered as given if:

* The registrant has used the name in relation with the offer of goods or services or has verifiably made respective preparations prior to the announcement of the dispute resolution proceeding
* The registrant is a company, organisation or natural person that is generally known under this name, even though no registered right exists
* The registrant uses the name in a legitimate, non-commercial or fair manner without causing user confusion or corrupting the name’s image

Many of these guidelines are also in line with ICANN’s perception.

Lastly, NetCologne will declare a registrant to act in bad faith if:

* It becomes evident that the registrant acquired the domain name mainly with the purpose of selling, renting or in any other form assigning the domain to the proper owner or a public institution
* The domain name was registered in order to prevent the proper owner or a public institution from using this name as a domain name
* The domain name was primarily registered with the goal of disturbing the professional or organisational activity ⁄ activities of a competitor
* The domain name is used in order to attract Internet users to one’s own website with the goal of profit maximisation (more detailed information with regard to phishing and pharming will be provided in the answer to question 29 “Rights Protection Mechanism”)


1.1.1 Policies for handlings complaints regarding abusive behaviour

Requests and complaints submitted via the contact form will be received by NetCologne as well as the technical service provider. Thereby, the technical service provider will immediately become informed as to the problem brought forward. Requests and complaints brought forward by phone will be directed towards our technical service provider, who offers a 24⁄7 hotline. This allows for immediate reporting in urgent cases.

The contact provided can be used by registrants as well as third parties to report abusive registrations. In general NetCologne expects the respective registrars to handle complaints by registrants or third parties. Thus, NetCologne will redirect incoming complaints to the respective registrar who services the allegedly abusive registrant. NetCologne commits to redirect complaints within one working day (Monday through Friday) upon receipt. In return registrars are also obligated to contact the complainant within one working day upon receipt of the complaint from NetCologne.

In handling complaints, NetCologne will obligate registrars to adhere to the relevant resolution procedures set out by ICANN, i.e. the Uniform Domain Name Dispute Resolution Policy (UDRP) and the Uniform Rapid Suspension (URS). This means that in cases of trademark infringement the registrar shall inform the claimant that he⁄she can file a claim with the respective service providers and provide the relevant contact information. NetCologne will then implement all decisions made throughout the resolution process (cf. question 29 “Rights Protection Mechanism”).

Depending on the type of complaint, a proper court proceeding or an extrajudicial conciliation between the two parties will be enforced. This however will only take place as long as there is no special resolution process set out by ICANN. The decision whether a court proceeding or an extrajudicial conciliation will take place will depend on the registrar’s as well as the contending party’s wish.

NetCologne will include all mentioned obligations for the registrars in the Registry Registrar Agreement.


1.1.2 Resolutions for abusive behaviour

NetCologne will lock domains within 24 hours in two cases:

1. A proper court or an arbitration committee has declared that the respective domain name is defamatory or racist or is in breach of public law. As soon as NetCologne receives the verdict, the domain name will be locked within 24 hours and will remain suspended from further registration.

2. NetCologne receives a “Notice of Complaint” from a URS Provider. This process is further elaborated upon in the answer to question 29 “Rights Protection Mechanism”. Besides locking domains in certain cases, NetCologne will withdraw any domain if instructed to do so by relevant service providers (e.g. URS Provider), a proper court or an arbitration committee. The final decision will in any case be with the mentioned decision-making bodies.


2. Abuse Point of Contact

To ensure that the NetCologne GmbH gets notified of any cases of abuse as quickly and easily as possible, an area of the public web site operated by the NetCologne GmbH for the .koeln TLD will be dedicated to the reporting of such cases. The respective web pages establish a single point of contact where abuse cases can be reported via a simple web form. An e-mail address and a phone number will also be provided as alternative means of communication.

Every case reported will raise a high-priority ticket within the .koeln support staffʹs ticket system, examined immediately and treated in accordance with the Rapid Takedown Policy.


3. Prevention of Domain Name Tasting and Domain Name Front Running

The life cycle of a .koeln domain name includes a 5-day Add Grace Period (AGP) during which a newly created domain name may be deleted with a refund of the domain fee. This is common practice and corresponds to the policies of almost all existing generic top level domains.

However, in the past the Add Grace Period has been abused for practices such as domain name tasting and domain name front running. Domain name tasting means that domains were created simply for the purpose of testing whether revenue can be generated by e.g. creating a web page with advertisements for the domain; if this was found feasible within the first few days, the domain was retained, otherwise it was deleted within the add grace period for a full refund, i.e. the domain was ʺtastedʺ for potential revenue without any payment to the registry. Domain name front running refers to the practice of pre-registering domain names somebody has merely expressed interest in (e.g. by searching for them on the Whois web frontend of a registrar) with the purpose of reselling the domain to that person (at an inflated price) afterwards; again, the Add Grace Period has been abused for this purpose, since a registrar could do that without any cost (if the unsold domain was deleted before the end of the add grace period).

In 2008, ICANN introduced the so-called ʺAGP Limits Policyʺ (http:⁄⁄www.icann.org⁄en⁄tlds⁄agp-policy-17dec08-en.htm) which addresses these and other issues resulting from the Add Grace Period. As the registry operator for the .koeln TLD, Knipp Medien und Kommunikation GmbH will fully implement this policy by restricting Add Grace Period refunds to registrars according to the limits specified by the policy. At the end of every month, the registration systemʹs billing module will determine every registrarʹs net domain adds and check whether the add grace period refunds granted during that month exceed the permissible number according to the policy; if this is the case, additional charges to the registrarʹs account will be initiated to effectively revert the excessive refunds.

Any exemption requests by registrars, whether they were granted (as permitted by the policy) or rejected, are documented, and such documentation will be maintained and made available for review by ICANN on request. The registryʹs monthly report to ICANN will contain per-registrar information on the granted add-deletes, as well as additional columns regarding the exemption requests.

The related report columns are (with column header names in parentheses):

* number of AGP deletes (ʺdomains-deleted-graceʺ)
* number of exemption requests (ʺagp-exemption-requestsʺ)
* number of exemptions granted (ʺagp-exemptions-grantedʺ)
* number of names affected by granted exemption request (ʺagp-exempted-domainsʺ)


4. Prevention of Domain Name Sniping (Grabbing)

Domain name sniping (also known as ʺgrabbingʺ) is another common abuse pattern; the name refers to the practice of trying to re-register potentially interesting domain names immediately after they are deleted (sometimes by accident, or because a registrant failed to renew the domain with his registrar in time).

Since .koeln domains are (per registry policy) automatically renewed when they reach their expiration date, no explicit renewals by registrars are required to prevent a domain name from being deleted when they expire. Registrars need to explicitly delete domains in order to release them for re-registration. This substantially reduces opportunities for domain name sniping.

However, registrars may still send unintended domain deletions, i.e. due to clerical errors or miscommunication with the registrants. Even for these cases, measures against domain sniping are in place. Starting in 2002, registries have begun to implement an ICANN proposal, the so-called ʺRedemption Grace Periodʺ (RGP, http:⁄⁄www.icann.org⁄en⁄registrars⁄redemption-proposal-14feb02.htm). The proposal recommends to introduce a 30-day period after a nameʹs deletion during which the name is removed from the TLD zone (in order to give the registrant the chance to take notice of his nameʹs deletion) but is still eligible for being restored by the previous registrar⁄registrant. Supporting the RGP significantly reduces chances for domain grabbers to obtain inadvertently deleted domains, since a registrant gets 30 days to notice the mistake and to restore the domain before it becomes available for re-registration.

The TANGO Registration System used by Knipp Medien und Kommunikation GmbH to operate the .koeln TLD supports the Redemption Grace Period as proposed by ICANN and implements it in full compliance with RFC 3915 (ʺDomain Registry Grace Period Mapping for the Extensible Provisioning Protocol (EPP)ʺ).


5. Prevention of Orphaned Glue Records

According to the definition found in the ʺSSAC Comment on the Orphan Glue Records in the Draft Applicant Guidebookʺ (http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf), a glue record becomes an ʺorphanʺ when the delegation point NS record (the ʺparent NS recordʺ) that references it is removed while retaining the glue record itself in the zone. Consequently, the glue record becomes ʺorphanedʺ since it no longer has a parent NS record. In such a situation, registrars and registrants usually lose administrative control over the record, and the recordʹs attribution to a certain registrar may become unclear, which makes it a potential vector for abuse.

The glue record policy in effect for the .koeln TLD avoids this situation entirely by disallowing orphan glue records altogether. This corresponds to policy #3 mentioned in Section 4.3 (page 6) of the SSAC document mentioned above. The technical implementation within the TANGO Registration System and its associated zone generation process ensures this by the following measures:

* As a general principle, glue records are only created if they are really necessary, i.e. only in the case where a name server (e.g. ʺns.example.koelnʺ) is used for the delegation of a superdomain of its own name, e.g. ʺexample.koelnʺ in this example. If the same name server is used for e.g. ʺexample2.koelnʺ, no glue record is created.
* A host object within the .koeln TLD (like ʺns.example.koelnʺ) cannot exist without its parent domain (ʺexample.koelnʺ). Any attempt to create the host ʺns.example.koelnʺ will be rejected by the SRS if the domain ʺexample.koelnʺ doesnʹt already exist or is not sponsored by the registrar creating the host. Likewise, the domain ʺexample.koelnʺ cannot be deleted by the registrar if subordinate hosts like ʺns.example.koelnʺ still exist. These subordinate hosts have to be deleted before the domain itself may be deleted; if such hosts are used in delegations for other .koeln names, these delegations in turn have to be removed before the host may be deleted.
* If a domain name is put on hold (e.g. as a consequence of the Rapid Takedown Policy described above), this not only means that the delegation for the name itself is removed from the zone; it also means that any occurrences of NS records referencing a name server that is subordinate to the domain are also removed from other .koeln domains, along with any accompanying glue records. The same of course holds true should the domain name have to be deleted entirely by the registry.

Consequently, no glue records can exist for a certain domain in the .koeln zone after that domain is put on hold or deleted as part of abuse prevention or mitigation procedures.

It should be noted that this policy may lead to other domains (not directly involved in the abuse case) being affected by the takedown if they were delegated to a name server subordinate to the offending domain. Depending on their overall DNS architecture, such domains may become unreachable or less reachable after the delegation point is removed. While this could in theory be avoided by a less rigid orphan glue record policy, the overall benefit of adopting the strict policy described above is deemed higher than the potential damage to domains using a DNS infrastructure depending on an offending domain name.


6. Preventing Use of Trademarked, Reserved, Invalid, Illegal or Otherwise Unsuitable .koeln Names

As laid out in the answer to Question 29 (Rights Protection Mechanisms), the NetCologne GmbH takes extensive measures to protect the legal rights of others (such as trademark holders) with regard to .koeln domain names. This includes

* conducting a Sunrise phase to allow trademark holders to secure names related to their trademarks prior to GA,
* accessing a Trademark Clearinghouse to validate trademarks presented by registrants,
* offering a Trademark Claims Service, at least during the first 60 days of general availability,
* taking precautions against phishing and pharming and
* committing to full compliance with established Dispute Resolution and Suspension Procedures, including the Uniform Rapid Suspension (URS), the Trademark Post-Delegation Dispute Resolution Procedure (Trademark PDDRP), and the Uniform Domain Name Dispute Resolution Policy (URDP).

Please refer to the answer to Question 29 for more detailed information on these measures.

In order to prevent from domain name registrations which are defamatory, racist or in breach of public law, NetCologne in collaboration with the city council has compiled a list of 322 names and terms which will be blocked (cf. question 22 “Protection of Geographic Names”). These names and terms will not be available for registration over the entire registry lifespan, i.e. at least for ten years. If however, a domain name happens to be registered which is defamatory, racist or in breach of public law the above mentioned process will set in and the respective name will be added to the existing list of blocked names.

In addition to these specific rights protection measures, the TANGO Registration System provides the following general means to make sure that no .koeln names are registered which are for other reasons deemed invalid, reserved, illegal, offensive or unsuitable.


6.1 Rule Engine

For the most part, this is achieved by the deployment of a complex rule engine that checks each registered name at the time of registration for compliance with a configurable set of rules. Among other things, these rules include

* a test to ensure that the domain name has the proper number of labels (which is two for a traditional registry that allows only second level domains to be registered),
* a test to ensure that no hyphens occur in position 3 and 4 of any of the domainʹs U-labels (to protect ʺxn--ʺ and future ACE prefixes),
* a test to disallow hyphens at the beginning or end of the name,
* a test to find ASCII characters which are neither a letter, nor a digit or a hyphen,
* a test to find invalid IDN characters, i.e. characters not contained in any of the supported IDN tables,
* a test to disallow reserved geopolitical names,
* a test to disallow registry reserved names,
* a test to disallow ICANN reserved names,
* a test to disallow otherwise reserved or unsuitable names.

Please refer to the answer to Question 44 (Internationalised Domain Names) for more information on the rules governing valid IDNs in the .koeln TLD.

For the tests checking for reserved names, custom lists of labels can be conveniently maintained by the NetCologne GmbH to define the disallowed names for each category. Additional categories can also be added as required for enforcing specific policies of the .koeln TLD.

The rules are stored in database tables (rather than static configuration files), which means rules can be added, deleted or altered by authorised registry personnel without requiring a shutdown or restart of the .koeln SRS.

Should eligible parties approach the NetCologne GmbH (via a registrar) providing sufficient evidence of their eligibility for a specific reserved domain name, the NetCologne GmbH can enable the chosen registrar to register the domain name for that specific registrant only (circumventing the rule engine check that would otherwise prevent the registration). Technically, this is done via the registry issuing a special authorisation code to the registrant, who supplies this authorisation code to the registrar of his choice. The registrar then needs to use this specific code as the domain authinfo in the EPP 〈domain:create〉 request, which will let the request bypass the rule engineʹs blocking mechanism and permit the registration.


6.2 Compliance with Specification 5 of the Registry Agreement

The rule engine is the central system component ensuring that the NetCologne GmbH will operate the .koeln TLD in full compliance with Specification 5 (ʺSCHEDULE OF RESERVED NAMES AT THE SECOND LEVEL IN GTLD REGISTRIESʺ) of the Registry Agreement. Unless the NetCologne GmbH is otherwise authorised by ICANN and the Government Advisory Committee (GAC) in writing, the rule engine for .koeln will be set up to prohibit the registration of the labels and label types listed in Specification 5 by registrars.


6.3 Pattern Matching and Fuzzy String Comparison

In addition to the pre-registration checks described above, the rule engine also supports testing registered domain names against a set of configurable string patterns, as well as for their similarity to a set of disallowed strings. The former is implemented by matching names against regular expressions, the latter by calculating the so-called ʺLevenshtein distanceʺ between the registered name and a given disallowed string (which is a measure for their similarity). Prior to performing any of these checks, the registered name is subjected to a number of normalisations in order to maximise its comparability; this includes the mapping of IDN characters with accents to their ASCII counterparts where feasible, the removal of hyphens and the removal of digits.

If a name matches a regular expression, or if the calculated Levenshtein distance falls below a certain threshold, the name is still normally registered, however it is also internally flagged for review. Due to the fuzzy nature of the pattern and Levenshtein matching, a name flagged via these checks may not necessarily be invalid or illegal; this is why the flagged names need to be reviewed manually by the .koeln support staff. Flagged names automatically create tickets within the support teamʹs issue system, which starts a workflow that ultimately decides whether the name is permissible (in which case the flag is removed) or invalid⁄illegal (in which case the name is deleted and the registrar gets notified).


6.4 Handling of IDNs

In the context of abuse prevention, the proper handling of Internationalised Domain Names (IDNs) becomes an important aspect.

If different IDN scripts were allowed to be mixed within one domain name, so-called homographs could be used to make users believe they are looking at a certain web site while it is actually a different one which name just has an identical or very similar visual representation. For example, since the Cyrillic letter ʺErʺ (ʺрʺ in Cyrillic script) in lower case has the same visual appearance as the Latin lower case letter ʺpʺ, mixing Latin and Cyrillic scripts would allow the creation of a domain name like ʺрayрal.koelnʺ, a homograph of the Latin-only name ʺpaypal.koelnʺ which, despite being a different word, looks exactly the same. Such a domain name could thus e.g. be used for spoofing or phishing attacks. The NetCologne GmbH prevents such abuse by implementing an IDN policy that disallows the mixing of scripts; within each label of a registered .koeln, only characters from a single script may be used.

Likewise, the Cyrillic-only second level domain ʺрор.koelnʺ looks identical to its Latin-only counterpart ʺpop.koelnʺ. If only the rule described above (no mixing of scripts) would apply, these two names could coexist for different registrants, and could thus be abused to confuse users. However, the special way the NetCologne GmbH handles such IDN variants while considering respective IDN tables and canonical forms of domain names, as described in detail in the answer to Question 44 (Support for Registering IDN Domains), prevents this situation; only one of these two domains may exist at the same time.

The NetCologne GmbH is aware that even within the same script (e.g., Latin), the use of diacritics may potentially cause similar confusion among users, e.g. if the ASCII-only name ʺpaypal.koelnʺ and a very similar one with diacritics (like ʺpáypàl.koelnʺ) are coexisting as completely separate registrations. However, after thorough consideration, it has been decided that the benefit of allowing situations like this is higher than the potential damage; in many languages, words with completely different meanings are created just via the use of diacritics, so quite useful domains would become blocked if diacritics would be considered for calculating a nameʹs equivalent variants. Consequently, the NetCologne GmbH does not perform this kind of blocking, but allows the names to coexist in such cases. Should the NetCologne GmbH receive reports about names utilising diacritics for abusive behaviour, other countermeasures described in this chapter will be applied to stop the abuse.


7. Domain Data Access Control

One important point of attack that may lead to abuse of .koeln domains and their associated data is the unauthorised or excessive access to data stored within the .koeln repository. This applies to both read access (e.g. via public interfaces such as the port 43⁄web Whois) and write access (such as registrar interfaces like EPP or the web-based Control Panel). The measures taken in the .koeln TLD to properly restrict access are laid out in the following.


7.1 Prevention of Whois Data Mining

The port 43⁄web Whois interfaces grant public access to domain, host and contact data. As such they are a potential target for data mining, i.e. the retrieval of large amounts of postal or e-mail addresses for e.g. the purpose of advertising.

As explained in detail in the answer to Question 26 (Whois), the Whois implementation provided by the TANGO Registration System prevents such data mining attempts, most importantly by the following measures:

* Access to all Whois interfaces is rate-limited (when accessed from IP addresses not whitelisted for unlimited access).
* Web interface users are required to pass a CAPTCHA before access is granted.
* Web interface users seeking access to extended Whois search capabilities are required to authenticate by entering login credentials (which are only issued to eligible parties).
* For improved spam protection, E-mail addresses may be displayed as images only in the web-based Whois.
* Contact disclosure flags as specified in RFC 5733, the Extensible Provisioning Protocol (EPP) Contact Mapping, are fully supported. This gives registrants enhanced control over the contact fields they want to disclose in the Whois. In this respect, the system is configurable and allows restricting the use of EPP contact disclosure settings via rules defined by specific registry policies or legal requirements.


7.2 Prevention of Unauthorised Data Modifications

Domain data within the .koeln is exclusively provisioned by registrars, i.e. registrants have no direct write access to their data within the repository; all their modifications have to be done via the registrar sponsoring the respective domain. In this constellation, registrants needs to trust their registrar and will expect that the management of their domain is conducted in a diligent and correct manner.

This means that the registryʹs interfaces used by registrars need to be secured in order to only allow the sponsoring registrar of a domain (and nobody else) to modify domain data.

The EPP interface provided by the TANGO Registration System does this by

* requiring SSL⁄TLS on the transport layer,
* requiring a strong EPP password (minimum length, mandatory digits and non-alphanumerical characters),
* requiring changing the EPP password on a regular basis,
* requiring registrars to supply lists of IP addresses or subnets from which exclusive access will be granted,
* requiring registrars to use SSL client certificates known to and trusted by the registry, thus providing an additional means of authentication beyond the EPP password.

Likewise, the web-based Control Panel

* requires SSL⁄TLS on the transport layer,
* requires registrars to log in with a user name and password (for which the same rules regarding minimum length, mandatory digits and non-alphanumerical characters apply),
* requires changing the password on a regular basis,
* requires registrars to supply lists of IP addresses or subnets from which exclusive access will be granted,
* requires registrars to install SSL client certificates known to and trusted by the registry in their web browsers, thus providing an additional means of authentication beyond the web password.


8. Whois Accuracy

Since .koeln is operated as a so-called ʺthick registryʺ, the .koeln Whois displays information about the registrant, as well as the administrative, technical and billing contacts of every .koeln domain. In cases of malicious or abusive activity involving a .koeln domain, this Whois contact information usually is the first and most important source of information, e.g. for law enforcement authorities, to determine the people or organisations responsible for the domain in a timely manner. Consequently, it is deemed very important to maximise the accuracy of contact information stored in the registry repository.

The NetCologne GmbH (and Knipp Medien und Kommunikation GmbH as its technical provider) are therefore committed to take diligent measures to promote Whois accuracy, including (but not limited to) the following:

* Contact data completeness policy: The thick registry model used for .koeln mandates the association of each .koeln domain with exactly one registrant, one administrative contact, one technical contact and one billing contact. The data of all used contacts is stored in the registry repository. While RFC 5733, the Extensible Provisioning Protocol (EPP) Contact Mapping, merely requires contact data to contain a name, a city, a country code and an e-mail address for a syntactically complete EPP request, the .koeln TLD policy for contact data mandates the specification of at least one address line (street), a voice phone number and a postal code in addition. This means that, in addition to the XML schema validation conducted by the .koeln SRS for every EPP request received from the registrar (which ensures the presence of all RFC-mandated contact data), the SRS also requires these essential fields to be present and will reject requests lacking them with a ʺparameter value policy errorʺ message. The validation done by the SRS also goes beyond validating against the EPP XML Schema Definitions (XSDs) with respect to field content. For instance, contact e-mail addresses are required to contain an ʹ@ʹ character and a valid domain name; this is not mandated by the XSDs specified in RFC 5733.
* Contact data monitoring: On a regular basis, the registry will run automated plausibility audits on the contact data submitted by registrars. Using publicly available databases, contact address lines will e.g. be mapped to cities and zip codes, which are then compared to the ones provided by the registrant. Likewise, phone and fax numbers will be checked for plausibility.
* Domain data change notifications: The TANGO Registration System used to operate the .koeln TLD can be configured (on a per-registrar basis) to automatically notify certain contacts of a domain (e.g. both the registrant and the administrative contact in order to reach multiple people concerned with the domain) after every change made to the domain (i.e. alterations of associated contacts or name servers). When enabled, this feature allows unauthorised or unintended changes to domain and contact data to be detected immediately. This functionality will however need to be deployed after consultation with .koeln registrars, since many registrars do not endorse direct communication between the registry and registrants, i.e. their customers.
* WDRP auditing: In 2003, ICANN adopted the so-called ʺWhois Data Reminder Policyʺ (WDRP, http:⁄⁄www.icann.org⁄en⁄registrars⁄wdrp.htm) which obliges ICANN-accredited registrars to send yearly Whois data reminder notices to registrants. These notices contain the Whois data currently on file for the respective domain, as well as instructions for the registrant about ways to correct the data if required. While the NetCologne GmbH does not intend to replicate this reminder procedure on the registry level, it will establish an auditing process that monitors the WDRP activities of .koeln registrars to make sure that WDRP responsibilities are honoured.


9. Resourcing Plans

The TANGO Registration System already supports the technical abuse prevention and mitigation measures above at the time of writing. No additional coding is required for this, which means that no special developing resources will be needed. Continuous audits and monitoring, as well as timely reactions to reports of malicious activity will be provided by the staff on duty at Knipp Medien und Kommunikation GmbH.

For the initial setup, the following resources are allotted:

* Registry Policy Officer: finalising policies, creating documentation: 7 man days
* System Administrator: monitoring setup: 3 man days
* First Level Support: training: 1 man day per person
* Second Level Support: training: 1 man day per person

For the ongoing maintenance, the following resources are allotted:

* First Level Support: 10 man hours per month
* Second Level Support: 20 man hours per month
* System Administrator: 3 man hours per month

Employees already working for Knipp Medien und Kommunikation GmbH will be handling these tasks. The numbers above were determined by averaging the effort required for comparable tasks conducted by Knipp in the past over the course of 12 months.

Whenever a new TLD is introduced, the protection of intellectual property, legal rights and trademarks (TMs) is an important objective. Using suitable technical means and appropriate policies and procedures, rights owners and trademark (TM) holders must be protected from abusive domain registrations throughout a TLDʹs launch phase(s), as well as during the period of general availability (GA) which follows these launch phase(s).

The NetCologne GmbH (and Knipp as its technical provider) are committed to make all necessary technical and organisational provisions in order to achieve this objective. This includes, but is not limited to, full compliance with all respective specifications, agreements and ICANN policies. Details about the measures put in place are laid out in the following.


1. Sunrise Period

A proven way to allow eligible rights owners to secure domain names related to their registered TMs is to conduct one or more so-called ʺSunriseʺ phases prior to the TLDʹs GA launch. During Sunrise, domain names are awarded only to registrants supplying appropriate and valid data manifesting their ownership of a TM that matches the desired name.

Technically, Sunrise phases differ from the GA period in some important aspects:

* In addition to the usual domain data, registrars need to collect TM information (such as TM name, number, type, application⁄registration dates) from the registrants and submit this data to the registry when applying for domain names.
* The specified TM information needs to be validated. This involves verifying the data with the help of a so-called ʺTrademark Clearinghouseʺ (TCH), a central repository authenticating, storing and disseminating TM information (providers for this service are to be designated by ICANN). In addition, manual reviews may be part of the validation process, for which appropriate tools should be in place.
* The results of the TM validation need to be received and properly processed. This includes notifying all involved parties (such as the registrar and registrant).
* It is possible that multiple applications for the same domain name are received. To distinguish these applications, a unique ʺapplication IDʺ is assigned to each of them. If more than one of the applications for a domain name carry valid TM data, contention resolution measures need to be taken in order to determine the registrant to whom the domain is awarded.

The TANGO Registration System used by Knipp to operate the .koeln TLD fully supports these and other requirements of Sunrise phases via features described in the following.


1.1 Sunrise EPP Extension Support

The system supports an EPP extension for submission of TM data along with domain applications during launch phases such as Sunrise. For multi-phase Sunrise periods, the extension also supports the specification of the phase for which an application is submitted.

Moreover, the extension offers the possibility to submit additional textual information along with an application, such as e.g. the intended use for the domain name, or a URL demonstrating the previous use of the domain name under other TLDs. The registryʹs Sunrise policy governs whether specifying this information is required, which kind of data this information needs to provide, and how this information affects the decision about whether or not a domain name is awarded.

Please refer to the answer to Question 25 for more information about the launch phase EPP extension.


1.2 Sunrise Whois Support

Knipp provides special Whois services during launch phases like Sunrise. This allows registrants to check the status of their applications independently from information they may obtain from their registrars.

However, the Whois search options and the information returned during Sunrise differs from GA (as described in the answer to Question 26). Only the search for application IDs is enabled, without any support for wildcards. If an application ID exactly matches the Whois clientʹs query string, the applicationʹs data (domain name, registrar, application date, contact data and TM information) is returned, along with information about the applicationʹs status (such as ʺapprovedʺ or ʺunder reviewʺ). See the Sunrise⁄Landrush life cycle specification below for details about possible application states.


1.3 Registration Life Cycle Support for Sunrise (and Other Launch Phases)

The system supports the special steps of the registration life cycle that occur during Sunrise, i.e. the initial asynchronous TM validation and⁄or selection processes.

The registration life cycle described in the answer to Question 27 applies to the GA phase of the .koeln TLD, i.e. the normal ʺFirst-Come, First-Servedʺ (FCFS) period that usually starts after a TLD has finished its initial launch phase(s). Launch phases like Sunrise and Landrush usually involve a special life cycle that adds some complexity to the initial domain creation step.

During Sunrise phases, this step comprises the validation of TM data and the determination of the winning application if multiple ones were received. Depending on the concrete registry policy in place, one or multiple Sunrise phases may be conducted.

So-called ʺLandrushʺ phases are usually conducted after (or in parallel to) Sunrise phases in order to limit the load on the Shared Registration System (SRS) that usually occurs during the initial run on popular, generic names. Their goal is to replace the brute-force FCFS approach of the GA by a fair, controlled domain assignment process that does not encourage registrars to flood the SRS with requests when GA starts. Similar to Sunrise, most Landrush approaches let registrars submit multiple applications for the same domain name, among which a winner is determined by asynchronous contention resolution measures as defined by the registryʹs policies. In contrast to Sunrise, usually no special proof of eligibility needs to be supplied by registrars or validated by the registry during Landrush.


1.3.1 Life Cycle Support for Sunrise

During both Sunrise and Landrush, the first step of the normal domain life cycle (ʺcreate domainʺ, position (A) in the GA life cycle diagram Q27-F1 from the answer to Question 27) consists itself of a number of individual steps representing the registryʹs rights protection workflow. The steps during Sunrise are depicted in Figure Q29-F1:

(A1) Registrars are required to submit Sunrise applications for domain names by sending EPP 〈domain:create〉 commands containing a special EPP extension for the specification of relevant TM data. In addition, a second EPP extension may be used to specify data required to resolve a potential contention with regard to the domain name (e.g. the registrantʹs bid for the case that an auction should be held to decide the final assignment of the domain name).

Application data is stored in the registry database. Checking this data for validity may involve manual evaluation that needs to be done asynchronously. Also, multiple valid applications for the same domain name may be submitted during Sunrise, which is why applications are collected until the end of the Sunrise submission period, after which evaluations (and, if required, contention resolution) take place to determine the final outcome. The final result of the application is later communicated to the registrar via an EPP poll message.

(A2) The registry system accesses the API of the connected TCH in an attempt to validate the submitted TM information in relation to the desired domain name.

(A3) If the check with the TCH fails, i.e. the provided TM information is found to be evidently invalid, the application is rejected immediately without further manual review. An EPP poll message is placed in the registrarʹs message queue to inform the registrar about the negative outcome of the application. The applicationʹs status is now ʺinvalidʺ, which is also displayed in the special launch phase Whois output when the application ID is queried.

This step in the life cycle may also be reached later in the validation process, i.e. after the application was found invalid during a manual review, or when a contention resolution for a name with multiple valid applications was lost by the registrant. In the latter case, the applicationʹs status is ʺrejectedʺ.

(A4) If the check with the TCH succeeds, i.e. the provided TM information is found to be (at least tentatively) valid, the application is added to the pool of automatically validated applications for the given name. The applicationʹs status is now ʺpendingʺ. Such applications are collected in the registry database until the end of the Sunrise submission period. The registrar may withdraw the application by sending an EPP 〈domain:delete〉 before the Sunrise submission period ends.

(A5) At the end of the Sunrise submission period, the application may be further evaluated, potentially involving manual checks. If the outcome of this evaluation is that the application is invalid, the application is rejected by going to step (A3).

(A6) All remaining, valid applications for the given name are examined. If there is only one valid application (left) for the given name, this application may be approved in step (A7). Otherwise, a contention resolution needs to be conducted to determine the final assignee for the application, which is done in step (A8).

(A7) The application is approved, the domain is allocated and assigned to the registrar. An EPP poll message is placed in the registrarʹs message queue to inform the registrar about the positive outcome of the application. The domain proceeds into the registered state. The applicationʹs status is now ʺallocatedʺ.

(A8) Since multiple valid applications for the same name were submitted, a contention resolution is required to determine the registrant to which the domain is awarded (the actual contention resolution used for .koeln is described below). If the resolution is won, the next step is (A7); if it is lost, the next step is (A3). During the contention resolution, the applicationʹs status is ʺvalidatedʺ.


1.3.2 Life Cycle Support for Landrush

The steps during a Landrush phase are quite similar to the ones for Sunrise. As depicted in Figure Q29-F2, the basic approach is the same, except that no TM information is submitted or reviewed in the process; the only aspects governing the assignment of the domain name during Landrush are

* whether more than one application was received for the name and
* if this should be the case, which of these applications wins the contention resolution.

The availability of Landrush support in the TANGO Registration System does not imply that dedicated Landrush phases must be held. While they are technically feasible, registry policy may also dictate that Sunrise and Landrush are conducted in a single phase, or in overlapping phases. The TANGO Registration System is prepared for such cases. A combined Sunrise⁄Landrush phase is e.g. possible by allowing applications during Sunrise to be submitted without carrying any TM data (which marks them as Landrush applications). During the selection process, applications carrying TM data (i.e. proper Sunrise applications) then always take precedence over ones that were submitted without such data; only if no valid Sunrise applications are received for a name, the Landrush applications for the name are considered, and the winning one is determined in accordance with the registryʹs contention resolution policies.

Another alternative to a dedicated Landrush phase is the use of a FCFS approach for GA with staggered pricing; in this approach, a domainʹs initial registration price is relatively high when GA starts, but is decreased over time. Registrants willing to pay the high price may register the domain early on, others will try waiting until the price goes down. Despite the FCFS principle, such staggered pricing will usually prevent a flood of requests from registrars at the beginning of GA. The TANGO Registration System supports this approach by its flexible billing module, which allows the definition of specific prices for certain time periods, e.g. the first day after the start of GA, the second day and so forth.

The billing module, in conjunction with the rule engine described in the answer to Question 28, may also be used to charge individual, higher prices for attractive, generic names (ʺpremiumʺ domains).

See below for more information on the GA approach designated for .koeln.


1.4 Trademark Clearinghouse (TCH) Support

The TANGO Registration System is prepared for accessing APIs of the TCH in order to validate the TM information submitted by the registrar during Sunrise. In addition, the system also contains provisions to make use of the TCH APIs for providing a Trademark Claims Service as soon as .koeln enters a period of general availability (see below for more information on this service).

Since TCH Service Providers have not been assigned by ICANN at the time of writing, the full technical specifications for these APIs are not yet known. While basic provisions have been made in the TANGO Registration System to connect to these providers, the details will therefore have to be finalised once the service providers have been announced and API specifications are available. As described below, appropriate developer resources are allocated to perform this task.


1.5 Support for Multiple Applications for the Same Domain Name

The TANGO Registration System is designed to maintain multiple domain objects representing the same domain name at a given point in time. This feature is required to store multiple applications for the same name during launch phases like Sunrise.

To distinguish between the various applications for the name in the database (as well as in external APIs), each application is assigned a unique application ID. These application IDs are returned to registrars in the responses to domain applications via EPP and may subsequently be used, among other things, to enquire an applicationʹs review status. Also, review results are reported back to registrars via poll messages carrying the unique application ID. Registrars can utilise the ID to clearly associate results with their various applications. Registrants may query the status of their applications from the .koeln Whois server using the ID.


1.6 Issue System

When manual reviews of Sunrise applications are required, this typically involves a specific support team workflow that, among other things, consists of

* storing application data in a database,
* making application data available to the support staff via a web interface,
* assigning the task of reviewing applications for a certain domain name to a specific support member (for the purpose of clear responsibilities),
* having the application reviewed by the assigned person, who in the process may
** request additional information or documentation from the registrant,
** add such documentation, as well as comments concerning the review, to the application,
** make a decision about the applicationʹs outcome or
** forward the task to a different support person with better insight or higher decision privileges (who may then make the final decision).

To support this workflow, the TANGO Registration System is equipped with a built-in Issue System that offers registry personnel a convenient web interface to review domain name applications and approve or reject them accordingly.

The Issue System

* offers an SSL-secured web interface accessible by .koeln registry staff only;
* allows searching for applications by various criteria (e.g. domain name or current workflow⁄approval state);
* allows a registry support person to find newly submitted or otherwise unassigned applications and to take responsibility for them;
* offers a two-level review workflow that allows the delegation of pre-selection tasks to the first level support staff, after which a final decision - if still required - can be made by second level personnel;
* conveniently displays all application details, including registrant information, the supplied TM information, as well as the results of the verification of that TM data with the TCH;
* fully tracks and documents application status and history, allowing for a complete audit in case of disputes or legal enquiries and
* is fully integrated with the registry backend, i.e. it automatically notifies the SRS about the reviewersʹ decisions and immediately activates the respective domain in case of an approval. The Issue System also triggers the creation of appropriate EPP poll messages in order to keep registrars informed about the outcome of their applications.

The Issue System was first employed using puntCATʹs elaborate multi-phase Sunrise period in 2006 and proved to be an invaluable tool for efficiently organising a TLD roll-out process. It ensures that the registry staff reviewing Sunrise applications finds all information relevant to a domain name in one place and comes to well-founded decisions in a timely manner. As a technical provider for CORE Internet Council of Registrars (which conducted the .cat Sunrise phases and still operates the .cat TLD today), Knipp developed the Issue System as part of COREʹs Shared Registry System. The experience gathered from developing and operating the Issue System in that context helped to develop a second-generation version that is now part of the TANGO Registration System.


1.7 Support for Resolving Contention

If multiple valid and eligible applications for a domain name are received, a well-defined and deterministic process is required to nominate the winning application. The details of this contention resolution procedure highly depend on a specific TLDʹs policies. However, even after such policy-based considerations, multiple candidates for the winner of an application may be left in contention. In such a situation, different tie-breaker rules can be applied to make a decision.


1.7.1 First-Come, First-Served (FCFS)

The obvious tie-breaker rule is to simply award the domain to the first application submitted, i.e. the one that carries the earliest time stamp among the ones in the contention set. Since the TANGO Registration System assigns a unique time stamp to each received application in a fair, unbiased manner and makes it available to the review staff of the NetCologne GmbH, this FCFS strategy is a viable, technically supported way to resolve contentions.


1.7.2 Auctions

However, FCFS selection processes based on application submission times have the drawback of potentially encouraging registrants and registrars to submit all their requests as soon as the registry starts accepting applications, which imposes time pressure on the involved parties, puts a considerable load on the involved systems and may cause an unfair advantage for registrars with better connectivity to the SRS.

Therefore, the TANGO Registration System also supports a simple auction-based tie-breaker approach out-of-the-box. It allows the registrar to submit a single, blind bid amount along with the Sunrise or Landrush application (via a special EPP extension). In the case of a contention, the application that was submitted with the highest bid wins. In the unlikely event that two applications were submitted with the exact same bid amount, the one with the earlier time stamp wins. Only the winning applicant pays his bid, i.e. there is no extra fee for placing a bid; this ensures that the process cannot be regarded as a lottery. If no contention should arise (i.e. there is only one applicant left before bids would be considered as a tie-breaker), the bid amount is irrelevant and only the standard application fee is paid.


2. Compliance with Specification 7 of the gTLD Applicant Guidebook

The NetCologne GmbH will fully comply with the rules defined in Specification 7 of ICANNʹs gTLD Applicant Guidebook (ʺMinimum Requirements for Rights Protection Mechanismsʺ). The details of this compliance is outlined in the following.


2.1 Implementation of All Mandated Rights Protection Mechanisms

In particular, this means that the NetCologne GmbH will include all ICANN mandated and independently developed Rights Protection Mechanisms (as described here) in the registry-registrar agreement (RRA) to be signed by all registrars authorised to register names in the .koeln TLD. The NetCologne GmbH will also, in accordance with requirements established by ICANN, implement each of the mandatory Rights Protection Mechanisms set forth in the ICANN-designated TCH.

During the conducted Sunrise phase, which will at least be offered for 30 days prior to entering a GA period, the NetCologne GmbH will consult the ICANN-designated TCH in order to verify TM data submitted by registrants. Details about this process are depicted above.


2.2 Trademark Claims Service

For further compliance with Specification 7, the NetCologne GmbH will implement a continuous Trademark Claims Service (TCS) to ensure that even after Sunrise, registrants are notified whenever their registered domain name potentially violates a TM holderʹs rights as stored in the TCH. Likewise, the service makes the TM holder aware of any domain registrations that potentially infringe on his TMs registered with the TCH.

As required by ICANN, the TCS of .koeln will at least cover the first 60 days of GA; it is considered that the TCS will be provided indefinitely, i.e. on a continuous basis beyond the first 60 days of GA.

When a match of a registered name is found via the API provided by the TCH, the TCS is supposed to provide clear notice to a prospective registrant of the scope of the mark holderʹs rights. The registrant will in turn be required to provide statement that

* he received notification that the mark is included in the TCH,
* he received and understood the notice and
* his registration and use of the requested domain name will not infringe on the rights that are subject of the notice.

The registrant will be directed to the TCH Database information referenced in the Trademark Claims Notice to enhance understanding of the TM rights being claimed by the TM holder.

Also, if a domain name is registered in the TCH, the registry will, through an interface with the TCH, promptly notify the mark holders(s) of the registration after it becomes effective.


2.3 Prevention of Otherwise Unqualified Registrations

In addition to protecting the rights of TM holders as described above, the NetCologne GmbH will also ensure that no registrations will be allowed which are in violation of the registry’s eligibility restrictions or policies. Technically, this is achieved by utilising the advanced domain name rule engine that is part of the TANGO Registration System and described in detail in the answer to Question 28. As laid out there, the underlying set of checks can be tuned to block registrations of .koeln names based on various syntactic rules, multiple reserved names lists, and patterns. Prior to the launch of the .koeln TLD, the rule engine will be configured in accordance with the policies of the NetCologne GmbH. Reserved names lists will be populated as governed by all eligibility restrictions that need to be enforced, which means that such names are not available for registration by registrars.

However, should eligible parties approach the NetCologne GmbH (via a registrar) providing sufficient evidence of their eligibility for a specific reserved domain name, the NetCologne GmbH can enable the chosen registrar to register the domain name for that specific registrant only (circumventing the rule engine check that would otherwise prevent the registration).


2.4 Reducing Opportunities for Phishing and Pharming

The abusive behaviours of phishing and pharming constitute a severe violation of the legal rights of others. Both practises are usually applied to make users enter confidential information on fake web sites pretending to be operated by a certain company or institution. In the case of phishing, the attack is usually done by trying to conceal the real domain name in the URL, or by using a domain name very similar to the one the user originally meant to visit. In the case of pharming, the attack happens on the DNS level, i.e. while the user still sees the correct domain name of the site he meant to visit, the IP address his resolver determined for the domain name somehow gets manipulated to point to the fake web site.

Due to the way these attacks are conducted, neither phishing nor pharming can be entirely prevented on the registry level. However, the registry can put mechanisms and policies in place that will make such exploits harder or limit their duration and impact.


2.4.1 Phishing

One important tool to rapidly address phishing activities shown by a web site operated under the .koeln TLD is the Rapid Takedown Policy described in the answer to Question 28. It allows a fast takedown of an offending site after respective activities were reported and confirmed.

In addition, the flexible rule engine used by the TANGO Registration System to validate permissible .koeln domain names can be utilised in the context of phishing. Should a certain .koeln domain name (or a pattern of such names) be repeatedly involved in attempts to mimic a rights holderʹs legitimate .koeln name for phishing purposes, the set of registration validation rules can be easily augmented to prevent the offending domain name (and, if need be, even an entire pattern of names deemed too similar to a rights holderʹs legitimate domain name) from being registered again after takedown. Of course, this practise will be exercised in close collaboration with ICANN and other parties potentially involved in the definition of names deemed not eligible for registration within the .koeln TLD.

As described in the answer to Question 28, the sophisticated IDN handling implemented by the TANGO Registration System is designed to provide protection against the most common cases of IDN-based phishing attempts, such as IDN homograph attacks. Please refer to the answers to Question 28, as well as Question 44, for more information on this topic.


2.4.2 Pharming

With regard to pharming, neither the quick takedown of offending domain names nor the blocking of such names are suitable as countermeasures. Due to the nature of the attack, the registryʹs approach needs to aim at a robust DNS infrastructure for .koeln, which ideally should guarantee the integrity and authenticity of DNS lookup results all the way from the registry-operated TLD name servers to the userʹs local resolver.

As described in detail in the answer to Question 35, the NetCologne GmbH will deploy a highly reliable and secure DNS subsystem for the .koeln TLD, which is powered by the elaborate DNSSEC setup laid out in the answer to Question 43. The NetCologne GmbH is therefore able to safeguard against any attempts to perform DNS manipulation on the level of the name servers operating the .koeln zone.

However, due to the way the domain name system (and DNSSEC in particular) works, preventing manipulations of the .koeln TLD name servers alone is not sufficient to avoid pharming attacks. In order to provide complete protection, DNSSEC support is required on every level of the domain resolution process, from the root zone via the TLD name servers and the delegated name servers down to a userʹs resolver. This means that registrars need to sign the zones they host on their name servers (and offer this service to their registrants), and resolvers (or other clients looking up .koeln domain names) need to verify the signatures and notify their users when inconsistencies are detected. Consequently, the NetCologne GmbH will encourage and advertise the widespread support and use of DNSSEC among registrars, registrants and end users. Once DNSSEC has been widely adopted, web browsers, e-mail clients and similar applications will increasingly support the verification of the related signatures out-of-the-box (rather than via the extensions available today), which will drastically diminish opportunities for pharming.


2.5 Compliance with Dispute Resolution and Suspension Procedures

In case of complaints put forward by rights holders with regard to domain names registered under .koeln, the NetCologne GmbH will fully comply with all resolution procedures endorsed or mandated by ICANN. In particular, this includes supporting the Uniform Rapid Suspension (URS) procedures and the Trademark Post-Delegation Dispute Resolution Procedure (Trademark PDDRP).

The NetCologne GmbH is committed to implement decisions rendered under the URS. In particular, the NetCologne GmbH will

* readily receive notifications about complaints (“Notice of Complaint”) from URS providers,
* lock the affected domain within 24 hours of receipt of the Notice of Complaint from the URS Provider, blocking all changes to the registration data, including transfer and deletion of the domain name (while retaining the domain name in the .koeln zone, i.e. the name will continue to resolve),
* notify the URS Provider immediately upon locking the domain name (”Notice of Lock”).

Once the complaint was decided upon, the following steps will be taken:

* If registrant was relieved, the NetCologne GmbH will unlock the domain and return full control to the registrant.
* In case of a determination in favour of the complainant, the NetCologne GmbH will, in accordance with the URS rulings, immediately suspend the domain name and keep it suspended for the remainder of its registration period; this means that the domain will remain locked and that the domainʹs name servers are redirected to an information web page supplied by the URS provider. In this situation, NetCologne GmbH will also make sure that the Whois output for the domain keeps displaying the original data (except for the altered name servers) and reflects that the domain name will not be able to be transferred, deleted or modified for the remainder of its registration period.
* The successful complainant will get the option to extend the registration period for one additional year at commercial rates.

In addition to these URS related procedures, the NetCologne GmbH is also committed to take any necessary steps required to support decisions emerging from the Uniform Domain Name Dispute Resolution Policy (UDRP). After a respective complaint has been filed in a court of proper jurisdiction or with an approved dispute resolution service provider, the NetCologne GmbH will implement all required measures arising from its function as a registry, including an immediate transfer of the domain to the legitimate rights holder (if the caseʹs determination is in the complainantʹs favour).

In case the NetCologne GmbH becomes involved in a Trademark Post-Delegation Dispute Resolution Procedure (Trademark PDDRP), it will fully adhere to the general rules of the procedure as set out by ICANN, as well as the individual requirements defined by the Trademark PDDRP Provider. However, it should be noted that the NetCologne GmbH has taken (and will continue to take) thorough precautions to ensure that a Trademark PDDRP will not become necessary. Nevertheless, should it become necessary, the NetCologne GmbH will abide by the remedies recommended by the Expert Panel, and potential fees imposed.

The Registry Restrictions Dispute Resolution Procedure (RRDRP) is not relevant in the context of .koeln, since .koeln is not a community-based gTLD.


3. Sunrise and Landrush Policies for the .koeln TLD


3.1 Sunrise Period


3.1.1 Phases

The sunrise period will comprise four phases. The respective phases will differ by registrantʹs geographic location and by the type of right to a name.

* Phase 1: Regional Trademark Rights Holders
* Phase 2: Supra-Regional Trademark Rights Holders
* Phase 3: Regional Companies, Associations, Communities, Organisations and other rights holders
* Phase 4: Supra-Regional Companies, Associations, Communities, Organisations and other rights holders

During any sunrise phase (except for phase number one) all beneficiaries from previous phases will be eligible to still register their domain name.

The reason to favour regional to supra-regional registrants stems from .koelnʹs mission purpose. In first place, the new TLD is supposed to be for interested parties from the Colognian area. However, NetCologne will of course allow registrants from other regions to register their domain under .koeln, but regional registrants will receive preferential treatment. This approach is also in line with the city councilʹs perception.

In this respect, NetCologne defines regional as having a subsidiary or a trademark registered in the city of Cologne, i.e. not in the administrative district of Cologne.

Family names will not receive any preferential treatment during the sunrise period.


3.1.2 Allocation

In all four sunrise phases domains will be allocated on a ʺFirst-Come, First-Servedʺ basis.

The allocation will only take place if the respective eligibility requirements are met. These requirements will be entirely based on the standards and terms as set out by ICANN: ownership of a mark, representation that all provided information is true and correct as well as provision of data sufficient to document rights in the trademark. Moreover, as ICANNʹs guidelines foresee, NetCologne will honor all word marks which are

* Nationally or regionally registered and for which proof of use was submitted to and validated by the Trademark Clearinghouse
* That have been court-validated
* That are specifically protected by a statute or a treaty currently in effect and that was in effect on or before 26 June 2008

Aside from those standards set out by ICANN, NetCologne will only accept registrations for trademarks, companies or the like, where the domain name represents the nameʹs identical match. Exceptions are some textual elements which can be left out or replaced (e.g. punctuation, spaces, special characters etc.). A complete list of these textual elements will be covered in the final document regarding the sunrise rules. Moreover, during sunrise as well as the normal registration period, only domain names under Standard Latin 1 will be available for registration (cf. Question 27, ʺRegistration Lifecycleʺ).

NetCologne itself will verify registrations by Clearinghouse data and inform trademark holders in the Clearinghouse if someone intends to register the nameʹs identical match. Moreover, NetCologne itself will check if all registrant information is complete and correct. The personnel allocation for this task will be laid out below.


3.1.3 Length

Each sunrise phase will last for six weeks. This way, all relevant partners will have sufficient time to register their domain name. This entire length of NetCologneʹs sunrise period therefore considerably goes beyond the minimum ICANN requirement of 30 days.

Following the fourth phase (ʺsupra-regional companies, associations, communities and organisationsʺ) there will be a four week break before the landrush period commences (elaboration on landrush to follow in this section).


3.1.4 Appeals Process

During the four week break between sunrise and landrush period, decisions that were made during sunrise can be appealed against. The appeals process will follow the rules and procedures from the Sunrise Dispute Resolution Policy (SDRP). Thus, according to the sunrise service rules as articulated by ICANN, the SDRP will allow challenges based on at least one of the following grounds:

* At the time the challenged domain name was registered, the registrant did not hold a trademark registration of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty.
* The domain name is not identical to the mark on which the registrant based its sunrise registration.
* The trademark registration on which the registrant based its sunrise registration is not of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty.
* The trademark registration on which the domain name registrant based its sunrise registration did not issue on or before the effective date of the Registry Agreement and was not applied for on or before ICANN announced the applications received

NetCologne is well aware that the appeals process may extend beyond this four week period in case there are many objections. Nevertheless, after the four week appeals process the landrush period will commence. Outstanding appeals will be resolved simultaneously.


3.2 Landrush Period

During this period all parties interested in a particular domain name will have a special opportunity to register this name, i.e. as long as the name has not justifiably been registered during the sunrise period.

The landrush period will last for 10 days. During these 10 days, the domain name prices will gradually decrease on a daily basis. This way, the most interested beneficiaries will be able to register their domain name by simply registering it early in the process.

The price scaling will be as follows:

* Day 1: €100.000
* Day 2: €50.000
* Day 3: €25.000
* Day 4: €10.000
* Day 5: €2.500
* Day 6: €1.000
* Day 7: €500
* Day 8: €250
* Day 9: €100
* Day 10:€50

As of day eleven, the normal domain registration process will commence and thus normal domain prices (cf. Question 18, ʺMission Purposeʺ, and Question 46, ʺFinancial Template 1ʺ) will be charged.

NetCologne believes that the implementation of such a scaling model will prevent from fraudulent registrations. In the early registration period, such as the landrush, especially popular, highly demanded domains might become targets to domain grabbers. However, the setup of the landrush period is intended to prevent domain grabbers from registering such highly demanded domains with the goal of reselling them. The comparably high prices at the beginning of the period are supposed to discourage domain grabbers from registering domains other registrants might have a true interest in.


4. Resourcing Plans

The TANGO Registration System already supports the rights protection features described above at the time of writing. No coding is required for this, which means that no special developing resources will be needed. The staff on duty at Knipp will be in charge of performing manual reviews of TM data where required.

Since the TCH API is not fully defined at the time of writing, some software development will have to be done in order to integrate it into the Sunrise workflow and the TCS.

For the initial setup, the following resources are allotted:

* Registry Policy Officer: finalising policies, creating documentation: 5 man days
* System Administrator: configuring system for policies: 1 man day
* First Level Support: training: 4 man hours per person
* Software Developer: integration of TCH API: 10 man days

For the Sunrise phase, the following resources are allotted:

* First Level Support: 30 man days per month
* Second Level Support: 30 man days per month

For the ongoing maintenance, the following resources are allotted:

* System Administrator: 1 man day per month

Employees already working for Knipp Medien und Kommunikation GmbH will be handling these tasks. The numbers above were determined by averaging the effort required for comparable tasks conducted by Knipp in the past over the course of 12 months.

This chapter presents an abstract, high-level description of the security principles governing the operation of the .koeln TLD by the NetCologne GmbH. Since this part of the response is published, detailed information is not included in this part of the answer, however an exhaustive description of the employed security measures is presented in the answer to Question 30 b).

Knipp Medien und Kommunikation GmbH is currently in the process of being certified according to the ISO 27001 standard. The completion of the certification process is estimated for Q4⁄2012.


1. Security Policy

As NetCologne GmbH does not perform the technical operation of the registry itself, but has contracted Knipp Medien und Kommunikation GmbH for that purpose, NetCologne GmbH defines a general security policy framework that is imposed on itself, Knipp and all further contractors and subcontractors. All participating entities have to ensure that their security policies meet the requirements of the framework.

The security policy framework has the following key objectives:

* confidentiality
* access
* accountability
* availability

These objectives are further explained in the following.


1.1 Confidentiality

Confidentiality means the protection of private, proprietary and other sensitive information from entities that neither have a right or a need to gain access to it. Information includes, but is not limited to, registration data, registrar data, financial data, contracts, human resources data, and other business and technical data. To achieve this, all managed data are categorised into the classes ʺhighly sensitiveʺ, ʺconfidentialʺ and ʺpublicʺ, which then define the base levels for the respective protective measures. With respect to the determined classification, for each set of data it is defined

* where the data is stored,
* how it is backed up,
* what protective measures are taken both for the data itself and its backups,
* how long the data is retained and how it is safely destroyed once the information is no longer required,
* how it is protected from illicit access,
* how legitimate access and modification is controlled,
* to which extent the data has to be auditable and
* which regular audits are performed.


1.2 Access

Access defines the rights, privileges and the mechanisms by which assets of the NetCologne GmbH are being protected. Assets may refer to physical items like desktop computers, notebooks, servers, network devices and other equipment, or to logical items like registration data, e-mails and communication logs, passwords or cryptographic key material. For each entity (i.e., person or machine) that is granted access, it is clearly defined

* for which purpose the access is granted,
* to which level the entity can view or change the data, partially or in whole,
* which obligations are imposed on the holder of the access rights,
* at which frequency the grant is revisited, i.e. checked whether it is still required to uphold the grant.


1.3 Accountability

Accountability defines the responsibilities of staff members and management with respect to security aspects. This includes

* handling of passwords and security tokens,
* reviewing audit logs and identifying potential security violations,
* management of security and access control and
* reporting of potential security breaches.

Staff members are made aware of their responsibilities on the assignment of duties and on a regular basis.


1.4 Availability

For each facet of the registry operation, beyond the requirements of ICANN, it is determined which service level is required, i.e.

* the availability requirements, defining the desired relative availability over a period of time (typically one month), including the allowed maximum planned and unplanned outage times,
* the recovery time objective and
* the recovery point objective, if applicable.


1.5 Security Role Concept

For the NetCologne GmbH, the considerations above manifest themselves in an exhaustive security role concept, which defines roles carrying certain access privileges and responsibilities. Employees at the NetCologne GmbH are assigned one or multiple roles identified by this concept, which clearly defines their duties and access rights.


2. Security Commitments to Users of the .koeln TLD


2.1 Abuse Prevention and Mitigation

As discussed in detail in the answer to Question 28, the registry has taken various precautions to reduce the probability that the domain names within .koeln are being used in connection with abusive or criminal activities.


2.2 Reliability and Availability of DNS

Various technical measures ensure a 100% availability of the DNS, as well as reliable, accurate and fast responses. A highly protected DNSSEC infrastructure ensures that the digital signatures contained in the DNS are trustworthy.


2.3 Technical Progress

The NetCologne GmbH is committed to employ state-of-the-art security measures on an ongoing basis. This includes, for example, the use of current and secure software, fast patches of security affecting bugs, and the adoption of new security related technologies as they become available.


3. Security Commitments to Registrants


3.1 Protection of Investment

With the commercialisation of the Internet, domain names have become valuable assets. Domain names are no longer simply a more or less convenient handle for cryptic IP addresses, but as brands they have become the base for whole businesses worth millions to billions. Also, with domain names, lifestyles (ʺtwitterʺ, ʺfacebookʺ generations) and communities are associated. Therefore, the loss, abuse or unavailability of a domain name, be it temporary or permanently, may cause significant damage to the domain name registrant.

The NetCologne GmbH fully recognises this. With its highly developed technical and administrative security framework, NetCologne GmbH has taken the necessary measures to protect the investments of registrants in their names. Due to the domain auto-renew mechanism, a valid domain is never deleted by the registry itself. In addition, the Redemption Grace Period provides extra protection if a request to delete the domain is inadvertently issued by the registrant himself or by the entrusted registrar. Also, if it can be proven that a domain has been illegally moved to a different registrant, this is reverted by the registry to to original state.


3.2 Adherence to Registration Policy

The registration policy clearly defines the conditions by which potential registrants may register domain names. The registrants can rest assured that the registry strictly adheres to these rules. In detail,

* The registry guarantees equal opportunity if multiple registrants meet the registration conditions in the same way.
* The registry applies a clear procedure for handling violations of the registration policy. The registrant has the ability to correct the violations before further actions are taken by the registry; he has also the right to appeal if he believes that the grounds for the registryʹs decisions are invalid.
* The registry maintains its neutrality in conflicts, unless forced by ICANNʹs Uniform Dispute Resolution Policy (UDRP) and Uniform Rapid Suspension (URS).


3.3 Privacy of Registrant Data

While the registry is strongly committed to data protection and privacy, only limited commitments can be made with respect to registrant data. This is owed to various requirements imposed by ICANN for the right to operate the registry.

First, the registry is required to provide so-called Registration Data Directory Services (RDDS). On the one hand, this allows the anonymous public to retrieve information on the registrant of a domain name. The registry tries to mitigate the impact by taking measures against data mining and by fully supporting EPPʹs disclosure settings, which allow the registrant (via the registrar) to restrict the exposure of specific data fields (within the limits of ICANN requirements).

On the other hand, as part of the RDDS, the registry is also required to grant access to the data to eligible users and institutions with legitimate interest, not limited to law enforcement agencies. The registry will monitor the activities of these entities and will withdraw the access if there are indications of excessive or abusive use.

Second, the registry has to give access to the registrant data to ICANN as part of the escrow requirement. While the data is encrypted by a public key of ICANN and thus safe from access by third parties, no guarantees can be given about the data handling by ICANN.

The registry adds a declaration about the data handling to the registration agreement in order to make a potential registrant aware of the limited privacy.