Application number: 1-864-71021 for .CLUB DOMAINS, LLC

.CLUB DOMAINS, LLC

1640 West Oakland Park Boulevard #304
Oakland Park Florida 33311
US

1 954 530 2580

1 888 886 0462

http:⁄⁄dotclub.com

Mr. Peter Augustine LaMantia

Consultant

+011 416 821 3225

+011 1 866 591 9562

peter@dotclub.com

Mr. Colin Christopher Campbell

CEO and Chairman

1 954 707 1013

colin@dotclub.com

Limited Liability Corporation

Florida, USA

Not Available

not applicable

not applicable

Colin Christopher Campbell
CEO and Chairman

Colin Christopher Campbell
CEO and Chairman

Colin Christopher Campbell
CEO and Chairman

Colin Christopher Campbell
CEO and Chairman

club

Not Available

.CLUB DOMAINS, LLC is partnering with Neustar Inc. who have extensive experience as a technical registry services provider. This string is not an IDN and we are partnered with a premier registry services partner. We foresee no operational or rendering problems with this string.

Mission and Purpose

This response provides an overview of our mission and purpose. It is supplemented by further detail in the responses in questions 45-50 which quantify our assumptions and goals relative to the ‘most likely’ projection and addresses contingencies in the ‘worst case’ projection to deliver on our mission and purpose. Following is an overview of the following areas;

- Business Goals,
- Mission and Purpose,
- About .CLUB,
- Strategic Overview, and
- Market Need, Size and Character.

Business Goals
Secure the leadership position, providing domain registration and web service offerings to club niche markets, delivering indispensable value to clubs and strong returns for investors.

Mission and Purpose
.CLUB Domains, LLC d⁄b⁄a .CLUB is a new company entering the Domain Name Registry and Web Service space with a mission to provide domain registration and relevant EASY-TO-USE web services to meet the online needs of clubs, similar societies and associations of all types and sizes. 

- .CLUB will provide services to the highest service level in the domain registry space and as such will be known for our professional management, customer care excellence and service performance.

- .CLUB will deliver niche-focused web services designed to help clubs establish engaging and effective online club membership experiences.

- .CLUB will foster innovation to help clubs grow and manage their membership base. 

At .CLUB we help your club;
1. Secure a great domain name
2. Grow club membership
3. Improve member involvement and value
4. Reduce management costs


About .CLUB
.CLUB DOMAINS, LLC is a Fort Lauderdale, Florida based company formed for the purpose of becoming the “.CLUB” registry. We intend to become the leading provider of relevant easy-to-use web services to club markets. The Company is founded by a proven successful Internet entrepreneur, Colin Campbell.

An Internet pioneer since 1993, Mr. Campbell, built several Internet companies including; Tucows Interactive, Internet Direct Canada Inc. (merged with Look Communications in 1999), and Hostopia.com Inc. (IPO TSX: H in 2006 and sold to Deluxe Corporation in 2008).

Under Colin’s leadership, Hostopia.com established itself as the market leader in its space, delivering white-label web services to its communication service provider customers. Services included domain name services, hosting, email and web applications designed to meet the needs of small and medium sized businesses. Additionally, Hostopia operated several retail brands, selling directly to its’ markets. At the time of Colin’s departure, Hostopia hosted more than 500,000 websites, served more than 4,500,000 email addresses and managed close to 1,000,000 domain names both as a registrar (through wholly owned subsidiary, Abacus of America) and as a reseller of registrar partners, including Tucows and Register.com.

Colin has been an active member of the Internet community in the past, serving as director for the Canadian Association of Internet Providers (CAIP), and the Canadian Internet Registration Authority (CIRA), and undertakes guest speaking engagements at a number of universities speaking on Entrepreneurship.

Colin’s leadership, entrepreneurial spirit and track record of success make him a compelling business leader. As a result, upon approval of the .CLUB TLD application, Colin will bring aboard an experienced leadership and operating team with many years of experience in the space. This team will form and help Colin realize the .CLUB DOMAINS, LLC mission and purpose. 



Strategic Overview
The following provides an overview of .CLUB’s strategic approach to the market. 

A CLUB is; a: an association of persons for some common object, usually jointly supported and meeting periodically; also : a group identified by some common characteristic b: the meeting place of a club c : an association of persons participating in a plan by which they agree to make regular payments or purchases in order to secure some advantage d : a nightclub e : an athletic association or team. 

Market Need
Club membership communities share common interests, band together to a common purpose, provide for their members a forum for the expression and sharing of ideas, coordination and management of events, launch of membership programs and provide services to serve their Club’s community of interests.

Today clubs do not have a gTLD that addresses their specific identity needs and are forced to select domain names which do not most accurately represent themselves. For example; BoyScouts of America could not select scouting.com since it is owned by a fantasy football organization. .CLUB will provide for these groups a unique and representative online address that is clearly recognized as a club entity. Similarly, there are no web service providers who offer a service suite that addresses specific club needs. Clubs must source various web services and adapt them to their club purpose. In summary, there is need for; 

- Unique domain name identities for clubs, and
- Web service suite designed to address online club needs.

.CLUB - The Registry
First and foremost .CLUB is a Domain Registry business. We will focus to launch the registry and sell through established registrar channels, building upon our extensive experience and relationships in the industry. Second, we will establish the business as a registrar to facilitate the operation as a direct selling and servicing organization centered at www.my.club.

.CLUB - The Web Service Provider
Our vision includes the introduction and expansion of a niche focused web service suite over time, designed to serve the needs of club markets. Our mission is to make it EASY to help clubs set up and manage their club on the web, help them be discovered, deliver engaging functions for their membership, manage and grow their club. 

.CLUB DOMAINS, LLC will always make domain name registrations available for purchase separately from any of our web service offerings. 


Market Need, Size and Character
Club, similar society and association markets are considerable in number, dynamic in their state of evolution and diverse in their core purpose. What they have in common are people who share common interests, seek to share experiences, learn and benefit through their club memberships. 

The niches in this market ecosystem for which our gTLD and value proposition is designed includes a number of club categories, including; 1. Social Clubs, 2. Sporting Clubs 3. Special Interest⁄Hobby Clubs, 4. Country Clubs 5. Buying Clubs, 6. Fraternities and Sororities, 7. Personal Clubs, 8. Professional Clubs, 9.School Clubs, 10. Service Clubs, and 11. Night Clubs.

In addressing each of these niches within the club market, we will employ various research methods through outreach to further quantify, characterize and profile members, obtain contacts and engage operators and members both through direct outreach and by promoting .CLUB online.

While the niches are diverse, their needs share common traits and it is to these needs we see a large underserved market need that we will design and deploy services. Further market need, size and character information and research supporting this plan are submitted in our response to Question 46. 

In addition, we provide a description of our market approach and our operational approach for Sales, Marketing, Product and Customer Care in our response to Question 46.

In 18b and 18c we provide information and our vision of how .CLUB will promote competition, consumer trust and choice and how we intend to set policies, processes and practice safeguards to mitigate issues involved in the introduction and expansion of .CLUB. 

Benefits to Registants and the Internet Community

For this response, we provide a high level overview of how the .CLUB gTLD will benefit registrants and the Internet community as a whole. We describe our area of specialty, provide a vision on our service level and reputation goals, discuss how .CLUB will aid the competitive landscape with both a differentiated and innovative service offering which will in turn, enable our club market registrants to differentiate and innovate their own service offerings to their members. In addition, we will include an overview of our registration policies and commitments to protect registrant privacy of their confidential information. Overviews are provided in the following areas;

- Benefit to Registrants, Internet Users and Others
- Goals in areas of Specialty, Service Levels, or Reputation.
- Promoting Competition, Consumer Trust and Choice
- Differentiation and Innovation
- Goals in terms of User Experience
- Privacy and Confidential Information
- Policies, Terms and Conditions
- Safeguards to Mitigate Issues with Introduction 
- Outreach to Achieve Market Benefits


Benefit to Registrants, Internet Users and Others

Benefits to the .CLUB registrants and Internet community will include; 
1. Ability for clubs to secure a domain name that best matches and represents their identity,
2. Offer easy-to-use web services for clubs that meet their needs, and
3. Establish for Internet users the nature of the entity when they search or go to a .CLUB address.


Goals in areas of Specialty, Service Levels, or Reputation
.CLUB will focus all efforts to address the specific market needs of the club niche markets. We recognize that to be successful .CLUB must deliver a quality service level and we will back that up with a Service Level Agreement as a component of our terms and conditions, with 100% uptime for DNS services as specified in the ICANN Agreement and at 99.5% uptime guarantee for web services. Our specialty, service level standards and reputation represent our brand promise to the market articulated as the .CLUB identity with Easy-To-Use web services for clubs to set up and manage their online presence. Consistent with our mission, .CLUB will be known as a reputable trusted provider to club markets.


Promoting Competition, Consumer Trust and Choice
.CLUB services will provide additional competition in the domain identity and web service markets. Clubs and club-like associations will have available not only an ample new supply of intuitive, marketable and reasonably available domain names, but also a new service suite designed to meet their online needs. Services will be more effective compared to existing gTLDs and web services on the market since they will be designed to meet the specific requirements of clubs. Additionally, since .CLUB is solely focused on the club market it is imperative the Company gain the trust of our market in all our interactions. We will do so by; 
1. Recognizing and protect pre-existing registered clubs as having priority rights to a .CLUB domain during the Sunrise and Landrush periods. 
2. Partnering with the best in the industry registry service and web service providers, 
3. Conducting business in a professional manner and deliver service levels at or better than industry norms, 
4. Designing and delivering focused and Easy-to-Use services that are demanded in our niche market, 
5. Implementing outreach programs to bring awareness to and educate the market on the new, focused domain identity and club-centered web service suite; and 
6. Using outreach to establish ongoing registrant and subscriber relationships and to inform our product roadmaps to ensure future service introductions address club pain points. 

By all these measures we will promote competition, consumer trust and choice in the market.


Differentiation and Innovation
Based on needs discovery responses from club operators, we will design innovative services to satisfy those needs and build a reputation as the web service provider who is the most innovative, differentiated and responsive to the club market. .CLUB believes this market is currently underserved without a web service provider addressing their specific needs. .CLUB will fill this service vacuum with easy-to-use services to help clubs grow and manage their club. Focusing on the club category we will differentiate our suite of services by being focused specifically on our category needs. This is new, better and different than any other web service provider to clubs today and as such will help clubs themselves bring innovative services to their members. 


Goals in Terms of User Experience
It is critical that domain registration, renewal and other registry services, along with all our web services, are easy for club operators and their members to use and derive value. .CLUB management’s proven track record and experience building successful web service businesses provides us with the expertise required to deliver positive user experiences which include: simple value proposition messaging, ease of purchase, intuitive graphical user interface, elegant application design, easy and effective access to support services and valued best practice guideance. We know great user experiences results in business success and as such will prioritize this element of our service designs and deployments.


Privacy and Confidential Information
Protection of privacy and confidentiality is extremely important in the operation of a registry and any web service business. The company intends for users to perceive the TLD as a trustworthy source of online information, products and services. User trust is enhanced when users are confident that their private or confidential information is securely protected. The Company intends to provide a safe and legitimate Internet space, enhancing user experience by mitigating security-associated risks. With respect to WHOIS data, the Company intends to comply with ICANN policies and otherwise to ensure that complete and accurate WHOIS information is readily accessible for every .CLUB domain name.

The Company intends to deploy DNSSEC and to comply with all of the other policies and practices required by ICANN in the Registry Agreement and⁄or via any Consensus Policy. And of course, the Company complies with all applicable laws and regulations relating to internet security and the privacy of users’ confidential information. Furthermore, the Company will employ all commercially reasonable practices with respect to the security of online transactions and users’ private or confidential information.


Policies, Terms and Conditions
The .CLUB TLD will be open and unrestricted, allowing anyone to select an appropriate .CLUB domain name for their own legitimate purposes. Bad faith and other illegal uses of .CLUB domain names will not be tolerated. The Company will implement an Acceptable Use Policy as further described in response to Question 28, and also will implement the UDRP, URS and all other ICANN-required rights protection mechanisms. Further, the Company will implement additional rights protection mechanisms as described in response to Questions 28 and 29.

.CLUB will institute clear policies, terms and conditions to support our goals. Policies, terms and conditions will include but not be limited to those identified above and elsewhere in the application. No policy will be in conflict with ICANN Registry Agreement or any ICANN Consensus Policy. .CLUB will evaluate new policies as necessary to address emerging security or other threats. 


Safeguards to Mitigate Issues with Introduction
.CLUB DOMAINS, LLC seeks to mitigate issues of abusive domain registrations. The following describes a few of our approaches to achieve this objective.

A goal of .CLUB is to ensure existing registered clubs worldwide are able to secure the most relevant domain name to best represent their identity. While the .CLUB gTLD will not be restricted, we have identified the challenge of domain squatting on pre-existing registered club names and will discourage this activity. In an effort to ensure clubs secure their most relevant domain to represent themselves online, we will conduct targeted marketing communication and outreach to as many clubs as is possible to offer them corresponding names during and after Sunrise and Landrush periods. 

A second major way that we will focus on mitigating issues with the introduction is through our partnership with a top tier registry services partner, Neustar, Inc. This will ensure best practice handing and world class systems available to the Company to ensure efficient operation of the registry back-end systems designed and well tested to handle abuse complaints expeditiously.

We provide further detailed description of all of our intended rights protection mechanisms in response to Questions 26, 28 and 29.


Outreach to Achieve Market Benefits
.CLUB will employ an aggressive outreach to club and club-like association markets to; 
1. Make clubs aware of the new gTLD offering, 
2. Educate clubs on the value of a .club domain identity and the services that will benefit their online presence and membership, 
3. Offer Sunrise and Landrush processes, and 
4. Conduct club needs analysis to inform web service product roadmap requirements. 

After the initial launch period, estimated at approximately one year, we will continue to engage in regular communications to our gTLD registrants to; 
1. Ensure satisfaction with the value of our services, 
2. Inform our product roadmap innovation strategy, and 
3. Inform the community on trends in web services best practices as a purely value added information to help registrants learn and improve their club operations and relevance to their membership. 

Registration Phases Overview and Minimization of Social Costs.

This response provides an overview of .CLUB DOMAINS, LLC operating rules to minimize the social costs and negative consequences or costs imposed on consumers in particular how multiple applications will be resolved, cost benefits for registrants and our intentions and commitments on pricng policies. Overviews are provided in the following areas;

- Sunrise, Landrush Applications, Auctions, Premium Names and General Availability Overview
- Advantageous Pricing, Introductory Offers and Bulk Registration
- Minimize Social Costs
- Price Change Policy

Sunrise, Landrush Applications, Auctions, Premium Names and General Availability Overview
The Company will offer a phased launch consistent with many prior gTLD domain name launches. First, a Sunrise Period will be offered as required by ICANN, for trademark holders to register domain names that correspond to their marks. If there is more than one qualified Sunrise applicant, then they will be invited to participate in an auction to select the registrant of the contested domain name. After the close of the Sunrise Period, the Company will offer a Landrush period where it will take applications for domain names. In the event more than one applicant contends for any domain during the Landrush period, applicants will be invited to participate in an auction to select the registrant of the contested name. The Company intends to reserve premium names to be held by the Company for offfer and sale at the registry’s discretion while complying with all ICANN rules and regulations. After the Landrush period the Company intends to take an estimated ten (10) to thirty (30) day break prior to General Availability to ensure resolution of contested or trademark related names coming out of Sunrise and Landrush. After that break, the Company will make unreserved and unregistered names generally available for open registration by any interested person or entity, on a first-come⁄first-served basis to register for one and up to ten years. 


Advantageous Pricing, Introductory Offers and Bulk Registration
At launch we intend to offer domains during Sunrise and Landrush at a price point designed to support the costs of the outreach programs required to build awareness and education in our target market. Upon general release, our plan is to make domains available at a discounted rate through our retail channel and to our registrar partners. We will recommend and encourage introductory offerings in our channel.


Minimize Social Costs
The cost of a .CLUB domain will not be price prohibitive to new or existing clubs and over the long run will provide additional value to the clubs, due to the identifiable nature of the gTLD and the vertical-focused services designed to address clubs’ needs. Our pricing will be competitively set within the price range of existing gTLDs to ensure take up and affordability of this top level domain. 


Price Change Policy
Our approach to suggested listed retail and wholesale registrar prices for domain registry services is to launch and maintain our price points at a consistent and competitive level. Our view is that a competitive price point is required to ensure affordablity in our target market and to compete effectively with other gTLD options currently in market and those coming to market. Our view is that while .CLUB domains do offer added value to the target niche and affords a premium, we must be competitively priced. The price point decision drivers are; 

1. Price is not an objection to end-user purchase in that it does not impose a high cost on consumers, and 
2. We price to build and maintain a registry that is economically sustainable over the long-term.

Our intent is to maintain suggested retail and registrar list prices for the foreseeable future. However, the Company must reserve the right to increase pricing under certain circumstances including market forces which may negatively impact our margins and business viability. Additionally, we may periodically adjust for inflation. While we cannot fully predict all future cost input changes, we have no plans to increase suggested retail or registrar list prices beyond ten percent per year. Should market forces require us to increase domain registration or renewal prices to either maintain business viability of the registry or enable launch of new services, we will notify registrants and⁄or partners in accord with the ICANN Registry Agreement. 

No

Not Available

No

.CLUB DOMAINS, LLC has engaged Neustar, Inc to deliver registry services for the .CLUB TLD. This response describes measures for protection of geographic names at the second and other levels in the applied for gTLD and includes applicable rules and procedures for reservation and⁄or release of such names.

1. PROTECTION OF GEOGRAPHIC NAMES

1.1 Initial Reservation
.CLUB DOMAINS, LLC (.CLUB) is committed to complying with all of its obligations under the New gTLD Registry Agreement and as such will meet its obligations to initially reserve all of the enumerated geographic names. More specifically, in accordance with Specification 5 of the New gTLD Registry Agreement, the Registry Operator will initially reserve all geographic names at the second level and at all other levels within the TLD at which the Registry Operator provides for registrations.

.CLUB will support this requirement by using the following internationally recognized lists to develop a comprehensive master list of all geographic names that will be initially reserved:

-The 2-letter alpha-2 code of all country and territory names contained on the ISO 3166-1 list, including all reserved and unassigned codes [http:⁄⁄www.iso.org⁄iso⁄support⁄country_codes⁄iso_3166_code_lists⁄iso-31661_ decoding_table.htm];

-The short form (in English) of all country and territory names contained on the ISO 3166-1 list, including the European Union, which is exceptionally reserved on the ISO 3166-1 List, and its scope extended in August 1999 to any application needing to represent the name European Union [http:⁄⁄www.iso.org⁄iso⁄support⁄country_codes⁄iso_3166_code_lists⁄iso-31661_ decoding_table.htm#EU];

-The United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardization of Geographical Names, Part III Names of Countries of the World. This lists the names of 193 independent States generally recognised by the international community in the language or languages used in an official capacity within each country and is current as of August 2006 [http:⁄⁄unstats.un.org⁄unsd⁄geoinfo⁄ungegn%20tech%20ref%20manual_M87_combined.pdf]; and

-The list of UN member states in 6 official UN languages prepared by the Working Group on Country Names of the United Nations Conference on the standardization of Geographical Names [http:⁄⁄unstats.un.org⁄unsd⁄geoinfo⁄UNGEGN⁄docs⁄9th-uncsgndocs⁄ econf⁄9th_UNCSGN_e-conf-98-89-add1.pdf]

1.2 Release Mechanism
Notwithstanding the above, .CLUB believes that the use of geographic designations in connection with the .CLUB TLD will significantly benefit end users and the global Internet community in that it will assist them in locating registrants’ services and locations by physical geography. Given .CLUB registrants’ locations throughout the world, there is little likelihood of confusion between the second-level geographic registration and the country or country-code designation. For example, few consumers would be confused into thinking that the us.CLUB domain name is associated with the country-code TLD of the United States administered by the United States Department of Commerce, or otherwise confused about an association with the United States government. Therefore, although the geographic names will initially be reserved, .CLUB does believe that geographic names should be able to be released from reservation. 

This is especially true of the two character second level domain names. .CLUB recognizes that there have been many successful and non-misleading use of two character second level names by gTLD operators such as AA.com, ge.com, and my.biz -- to name only a few. In the event that .CLUB wishes to register the two character strings, we shall propose to ICANN the release of such strings as required by the Registry Agreement.

In the event that .CLUB desires to use geographic reserved names, we will propose a release mechanism for ICANN approval as required by the Registry Agreement. 

23.1 Introduction 

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

23.2 Standard Technical and Business Components

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

-Registry-Registrar Shared Registration Service (SRS)
-Extensible Provisioning Protocol (EPP)
-Domain Name System (DNS)
-WHOIS
-DNSSEC
-Data Escrow
-Dissemination of Zone Files using Dynamic Updates
-Access to Bulk Zone Files
-Dynamic WHOIS Updates
-IPv6 Support
-Rights Protection Mechanisms

The following is a description of each of the services. 

23.2.1 SRS 

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

23.2.2 EPP

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

23.2.3 DNS

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

23.2.4 WHOIS

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

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

23.2.5 DNSSEC

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

23.2.6 Data Escrow

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

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

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

23.2.7 Dissemination of Zone Files using Dynamic Updates

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

23.2.8 Access to Bulk Zone Files

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

23.2.9 Dynamic WHOIS Updates

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

23.2.10 IPv6 Support

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

23.2.11 Required Rights Protection Mechanisms

.CLUB DOMAINS, LLC, will provide all ICANN required Rights Mechanisms, including: 

-Trademark Claims Service
-Trademark Post-Delegation Dispute Resolution Procedure (PDDRP)
-Registration Restriction Dispute Resolution Procedure (RRDRP)
-UDRP
-URS
-Sunrise service.
More information is presented in the response to Question 29.

23.3 Unique Services 

.CLUB DOMAINS, LLC will not be offering services that are unique to .CLUB.

23.4 Security or Stability Concerns 

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

24.1 Introduction

.CLUB DOMAINS, LLC has partnered with NeuStar, Inc (ʺNeustarʺ), an experienced TLD registry operator, for the operation of the .CLUB Registry. The applicant is confident that the plan in place for the operation of a robust and reliable Shared Registration System (SRS) as currently provided by Neustar will satisfy the criterion established by ICANN.

Neustar built its SRS from the ground up as an EPP based platform and has been operating it reliably and at scale since 2001. The software currently provides registry services to five TLDs (.BIZ, .US, TEL, .CO and .TRAVEL) and is used to provide gateway services to the .CN and .TW registries. Neustar’s state of the art registry has a proven track record of being secure, stable, and robust. It manages more than 6 million domains, and has over 300 registrars connected today. 

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

24.2 The Plan for Operation of a Robust and Reliable SRS

24.2.1 High-level SRS System Description

The SRS to be used for .CLUB will leverage a production-proven, standards-based, highly reliable and high-performance domain name registration and management system that fully meets or exceeds the requirements as identified in the new gTLD Application Guidebook. 

The SRS is the central component of any registry implementation and its quality, reliability and capabilities are essential to the overall stability of the TLD. Neustar has a documented history of deploying SRS implementations with proven and verifiable performance, reliability and availability. The SRS adheres to all industry standards and protocols. By leveraging an existing SRS platform, .CLUB DOMAINS, LLC is mitigating the significant risks and costs associated with the development of a new system. Highlights of the SRS include:

-State-of-the-art, production proven multi-layer design
-Ability to rapidly and easily scale from low to high volume as the .CLUB TLD grows
-Fully redundant architecture at two sites
-Support for IDN registrations in compliance with all standards 
-Use by over 300 Registrars
-EPP connectivity over IPv6
-Performance being measured using 100% of all production transactions (not sampling).

24.2.2 SRS Systems, Software, Hardware, and Interoperability 

The systems and software that the registry operates on are a critical element to providing a high quality of service. If the systems are of poor quality, if they are difficult to maintain and operate, or if the registry personnel are unfamiliar with them, the registry will be prone to outages. Neustar has a decade of experience operating registry infrastructure to extremely high service level requirements. The infrastructure is designed using best of breed systems and software. Much of the application software that performs registry-specific operations was developed by the current engineering team and a result the team is intimately familiar with its operations.

The architecture is highly scalable and provides the same high level of availability and performance as volumes increase. It combines load balancing technology with scalable server technology to provide a cost effective and efficient method for scaling.

The Registry is able to limit the ability of any one registrar from adversely impacting other registrars by consuming too many resources due to excessive EPP transactions. The system uses network layer 2 level packet shaping to limit the number of simultaneous connections registrars can open to the protocol layer.

All interaction with the Registry is recorded in log files. Log files are generated at each layer of the system. These log files record at a minimum:

-The IP address of the client
-Timestamp
-Transaction Details
-Processing Time.

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

24.2.3 SRS Design

The SRS incorporates a multi-layer architecture that is designed to mitigate risks and easily scale as volumes increase. The three layers of the SRS are:

-Protocol Layer
-Business Policy Layer
-Database. 

Each of the layers is described below. 

24.2.4 Protocol Layer

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

The EPP servers authenticate against a series of security controls before granting service, as follows:

-The registrar’s host exchanges keys to initiates a TLS handshake session with the EPP server.
-The registrar’s host must provide credentials to determine proper access levels.
-The registrar’s IP address must be preregistered in the network firewalls and traffic-shapers.

24.2.5 Business Policy Layer 

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

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

The SRS today processes over 30 million EPP transactions daily. 

24.2.6 Database

The database is the third core components of the SRS. The primary function of the SRS database is to provide highly reliable, persistent storage for all registry information required for domain registration services. The database is highly secure, with access limited to transactions from authenticated registrars, trusted application-server processes, and highly restricted access by the registry database administrators. A full description of the database can be found in response to Question 33.

Figure 24-1 attached depicts the overall SRS architecture including network components.

24.2.7 Number of Servers

As depicted in the SRS architecture diagram above Neustar operates a high availability architecture where at each level of the stack there are no single points of failures. Each of the network level devices run with dual pairs as do the databases. For the .CLUB registry, the SRS will operate with 8 protocol servers and 6 policy engine servers. These expand horizontally as volume increases due to additional TLDs, increased load, and through organic growth. In addition to the SRS servers described above, there are multiple backend servers for services such as DNS and WHOIS. These are discussed in detail within those respective response sections. 

24.2.8 Description of Interconnectivity with Other Registry Systems

The core SRS service interfaces with other external systems via Neustar’s external systems layer. The services that the SRS interfaces with include:

-WHOIS 
-DNS 
-Billing
-Data Warehouse (Reporting and Data Escrow).
 
Other external interfaces may be deployed to meet the unique needs of a TLD. At this time there are no additional interfaces planned for .CLUB.

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

24.2.9 WHOIS External Notifier

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

24.2.10 DNS External Notifier

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

24.2.11 Billing External Notifier

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

24.2.12 Data Warehouse

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

24.2.13 Frequency of Synchronization between Servers

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

24.2.14 Synchronization Scheme (e.g., hot standby, cold standby) 

Neustar operates two hot databases within the data center that is operating in primary mode. These two databases are kept in sync via synchronous replication. Additionally, there are two databases in the secondary data center. These databases are updated real time through asynchronous replication. This model allows for high performance while also ensuring protection of data. See response to Question 33 for greater detail. 

24.2.15 Compliance with Specification 6 Section 1.2

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

Additional information on the EPP implementation and compliance with RFCs can be found in the response to Question 25.

24.2.16 Compliance with Specification 10

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

To properly measure the technical performance and progress of TLDs, Neustar collects data on key essential operating metrics. These measurements are key indicators of the performance and health of the registry. Neustar’s current .biz SLA commitments are among the most stringent in the industry today, and exceed the requirements for new TLDs. Table 24-2 compares the current SRS performance levels compared to the requirements for new TLDs, and clearly demonstrates the ability of the SRS to exceed those requirements.

Their ability to commit and meet such high performance standards is a direct result of their philosophy towards operational excellence. See response to Question 31 for a full description of their philosophy for building and managing for performance.

24.3 Resourcing Plans 

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

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

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

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

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

The resources are more than adequate to support the SRS needs of all the TLDs operated by Neustar, including the .CLUB registry. 

25.1 Introduction

.CLUB DOMAINS, LLC’s back-end registry operator, Neustar, has over 10 years of experience operating EPP based registries. They deployed one of the first EPP registries in 2001 with the launch of .biz. In 2004, they were the first gTLD to implement EPP 1.0. Over the last ten years Neustar has implemented numerous extensions to meet various unique TLD requirements. Neustar will leverage its extensive experience to ensure .CLUB DOMAINS, LLC is provided with an unparalleled EPP based registry. The following discussion explains the EPP interface which will be used for the .CLUB registry. This interface exists within the protocol farm layer as described in Question 24 and is depicted in Figure 25-1 attached.

25.2 EPP Interface

Registrars are provided with two different interfaces for interacting with the registry. Both are EPP based, and both contain all the functionality necessary to provision and manage domain names. The primary mechanism is an EPP interface to connect directly with the registry. This is the interface registrars will use for most of their interactions with the registry. 

However, an alternative web GUI (Registry Administration Tool) that can also be used to perform EPP transactions will be provided. The primary use of the Registry Administration Tool is for performing administrative or customer support tasks. 
The main features of the EPP implementation are: 

-Standards Compliance: The EPP XML interface is compliant to the EPP RFCs. As future EPP RFCs are published or existing RFCs are updated, Neustar makes changes to the implementation keeping in mind of any backward compatibility issues.

-Scalability: The system is deployed keeping in mind that it may be required to grow and shrink the footprint of the Registry system for a particular TLD. 

-Fault-tolerance: The EPP servers are deployed in two geographically separate data centers to provide for quick failover capability in case of a major outage in a particular data center. The EPP servers adhere to strict availability requirements defined in the SLAs.

-Configurability: The EPP extensions are built in a way that they can be easily configured to turn on or off for a particular TLD.

-Extensibility: The software is built ground up using object oriented design. This allows for easy extensibility of the software without risking the possibility of the change rippling through the whole application. 

-Auditable: The system stores detailed information about EPP transactions from provisioning to DNS and WHOIS publishing. In case of a dispute regarding a name registration, the Registry can provide comprehensive audit information on EPP transactions.

-Security: The system provides IP address based access control, client credential-based authorization test, digital certificate exchange, and connection limiting to the protocol layer. 

25.3 Compliance with RFCs and Specifications

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

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

Neustar has a long history of providing exceptional service that exceeds all performance specifications. The SRS and EPP interface have been designed to exceed the EPP specifications defined in Specification 10 of the Registry Agreement and profiled in Table 25-2 attached. Evidence of Neustar’s ability to perform at these levels can be found in the .biz monthly progress reports found on the ICANN website.

25.3.1 EPP Toolkits

Toolkits, under open source licensing, are freely provided to registrars for interfacing with the SRS. Both Java and C++ toolkits will be provided, along with the accompanying documentation. The Registrar Tool Kit (RTK) is a software development kit (SDK) that supports the development of a registrar software system for registering domain names in the registry using EPP. The SDK consists of software and documentation as described below.

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

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

25.4 Proprietary EPP Extensions

The .CLUB registry will not include proprietary EPP extensions. Neustar has implemented various EPP extensions for both internal and external use in other TLD registries. These extensions use the standard EPP extension framework described in RFC 5730. Table 25-3 attached provides a list of extensions developed for other TLDs. Should the .CLUB registry require an EPP extension at some point in the future, the extension will be implemented in compliance with all RFC specifications including RFC 3735.

The full EPP schema to be used in the .CLUB registry is attached in the document titled “EPP Schema Files.”

25.5 Resourcing Plans

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

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

-Development⁄Engineering – 19 employees
-Quality Assurance - 7 employees.

These resources are more than adequate to support any EPP modification needs of the .CLUB registry.

26.1 Introduction

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

Some of the key features of .CLUBʹs solution include: 

-Fully compliant with all relevant RFCs including 3912

-Production proven, highly flexible, and scalable with a track record of 100% availability over the past 10 years

-Exceeds current and proposed performance specifications 

-Supports dynamic updates with the capability of doing bulk updates 

-Geographically distributed sites to provide greater stability and performance

-In addition, .CLUB DOMAINS, LLC thick-WHOIS solution also provides for additional search capabilities and mechanisms to mitigate potential forms of abuse as discussed below. (e.g., IDN, registrant data).

26.2 Software Components

The WHOIS architecture comprises the following components:

-An in-memory database local to each WHOIS node: To provide for the performance needs, the WHOIS data is served from an in-memory database indexed by searchable keys. 

-Redundant servers: To provide for redundancy, the WHOIS updates are propagated to a cluster of WHOIS servers that maintain an independent copy of the database. 

-Attack resistant: To ensure that the WHOIS system cannot be abused using malicious queries or DOS attacks, the WHOIS server is only allowed to query the local database and rate limits on queries based on IPs and IP ranges can be readily applied.

-Accuracy auditor: To ensure the accuracy of the information served by the WHOIS servers, a daily audit is done between the SRS information and the WHOIS responses for the domain names which are updated during the last 24-hour period. Any discrepancies are resolved proactively.

-Modular design: The WHOIS system allows for filtering and translation of data elements between the SRS and the WHOIS database to allow for customizations.

-Scalable architecture: The WHOIS system is scalable and has a very small footprint. Depending on the query volume, the deployment size can grow and shrink quickly.

-Flexible: It is flexible enough to accommodate thin, thick, or modified thick models and can accommodate any future ICANN policy, such as different information display levels based on user categorization.

-SRS master database: The SRS database is the main persistent store of the Registry information. The Update Agent computes what WHOIS updates need to be pushed out. A publish-subscribe mechanism then takes these incremental updates and pushes to all the WHOIS slaves that answer queries.

26.3 Compliance with RFC and Specifications 4 and 10

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

Table 26-1 attached describes Neustar’s compliance with Specifications 4 and 10.

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

26.4 High-level WHOIS System Description

26.4.1 WHOIS Service (port 43)

The WHOIS service is responsible for handling port 43 queries. Our WHOIS is optimized for speed using an in-memory database and master-slave architecture between the SRS and WHOIS slaves.

The WHOIS service also has built-in support for IDN. If the domain name being queried is an IDN, the returned results include the language of the domain name, the domain name’s UTF-8 encoded representation along with the Unicode code page.

26.4.2 Web Page for WHOIS queries

In addition to the WHOIS Service on port 43, Neustar provides a web based WHOIS application (www.whois.club). It is an intuitive and easy to use application for the general public to use. WHOIS web application provides all of the features available in the port 43 WHOIS. This includes full and partial search on:

-Domain names
-Nameservers
-Registrant, Technical and Administrative Contacts
-Registrars

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

1. Redemption Grace Period calculation: Based on the registry’s policy, domains in pendingDelete can be restorable or scheduled for release depending on the date⁄time the domain went into pendingDelete. For these domains, the web based WHOIS displays “Restorable” or “Scheduled for Release” to clearly show this additional status to the user.

2. Extensive support for international domain names (IDN)

3. Ability to perform WHOIS lookups on the actual Unicode IDN

4. Display of the actual Unicode IDN in addition to the ACE-encoded name

5. A Unicode to Punycode and Punycode to Unicode translator

6. An extensive FAQ

7. A list of upcoming domain deletions

26.5 IT and Infrastructure Resources

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

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

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

Figure 26-1 attached depicts the different components of the WHOIS architecture.

26.6 Interconnectivity with Other Registry System

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

26.7 Frequency of Synchronization between Servers

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

26.8 Provision for Searchable WHOIS Capabilities

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

-Domain name

-Registrar ID

-Contacts and registrant’s name

-Contact and registrant’s postal address, including all the sub-fields described in EPP (e.g., street, city, state or province, etc.)

-Name server name and name server IP address

-The system will also allow search using non-Latin character sets which are compliant with IDNA specification.
The user will choose one or more search criteria, combine them by Boolean operators (AND, OR, NOT) and provide partial or exact match regular expressions for each of the criterion name-value pairs. The domain names matching the search criteria will be returned to the user.

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

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

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

To mitigate the abuses noted above, Neustar will implement any or all of these mechanisms as appropriate:

-Username-password based authentication 
-Certificate based authentication
-Data encryption
-CAPTCHA mechanism to prevent robo invocation of Web query
-Fee-based advanced query capabilities for premium customers.

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

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

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

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

27.1 Registration Life Cycle

27.1.1 Introduction

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

27.1.2 Domain Lifecycle - Description

The registry will use the EPP 1.0 standard for provisioning domain names, contacts and hosts. Each domain record is comprised of three registry object types: domain, contacts, and hosts.

Domains, contacts and hosts may be assigned various EPP defined statuses indicating either a particular state or restriction placed on the object. Some statuses may be applied by the Registrar; other statuses may only be applied by the Registry. Statuses are an integral part of the domain lifecycle and serve the dual purpose of indicating the particular state of the domain and indicating any restrictions placed on the domain. The EPP standard defines 17 statuses, however only 14 of these statuses will be used in the .CLUB registry per the defined .CLUB business rules.

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

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

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

-Domain may be updated
-Domain may be deleted, either within or after the add-grace period
-Domain may be renewed at anytime during the term
-Domain may be auto-renewed by the Registry
-Domain may be transferred to another registrar. 
 
Each of these actions may result in a change in domain state. This is described in more detail in the following section. Every domain must eventually be renewed, auto-renewed, transferred, or deleted. A registrar may apply EPP statuses described above to prevent specific actions such as updates, renewals, transfers, or deletions.

27.2 Registration States

27.2.1 Domain Lifecycle – Registration States

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

-Active 
-Inactive
-Locked
-Pending Transfer
-Pending Delete.

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

27.2.2 Active State

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

27.2.3 Inactive State

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

27.2.4 Locked State

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

27.2.5 Pending Transfer State

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

27.2.6 Pending Delete State

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

27.3 Typical Registration Lifecycle Activities

27.3.1 Domain Creation Process

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

1. Contact objects are created in the SRS database. The same contact object may be used for each contact type, or they may all be different. If the contacts already exist in the database this step may be skipped.

2. Nameservers are created in the SRS database. Nameservers are not required to complete the registration process; however any domain with less than 2 name servers will not be resolvable.

3. The domain is created using the each of the objects created in the previous steps. In addition, the term and any client statuses may be assigned at the time of creation.

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

27.3.2 Update Process

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

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

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

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

27.3.4 Renew Process 

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

27.3.5 Transfer Process

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

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

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

1. The gaining (new) Registrar submits a Transfer command, which includes the AuthInfo code of the domain name.

2. If the AuthInfo code is valid and the domain is not in a status that does not allow transfers the domain is placed into pendingTransfer status

3. A poll message notifying the losing Registrar of the pending transfer is sent to the Registrar’s message queue

4. The domain remains in pendingTransfer status for up to 120 hours, or until the losing (current) Registrar Acks (approves) or Nack (rejects) the transfer request

5. If the losing Registrar has not Acked or Nacked the transfer request within the 120 hour timeframe, the Registry auto-approves the transfer

6. The requesting Registrar may cancel the original request up until the transfer has been completed.

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

27.3.6 Deletion Process

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

27.4 Applicable Time Elements

The following section explains the time elements that are involved. 

27.4.1 Grace Periods

There are six grace periods:

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

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

27.4.2 Add-Delete Grace Period 

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

27.4.3 Renew-Delete Grace Period 

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

27.4.4 Transfer-Delete Grace Period 

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

27.4.5 Auto-Renew-Delete Grace Period 

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

27.4.6 Auto-Renew Grace Period 

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

27.4.7 Redemption Grace Period 

The RGP is a special grace period that enables Registrars to restore domains that have been inadvertently deleted but are still in pendingDelete status within the Redemption Grace Period. All domains enter the RGP except those deleted during the AGP. 

The RGP period is 30 days, during which time the domain may be restored using the EPP RenewDomain command as described below. Following the 30day RGP period the domain will remain in pendingDelete status for an additional five days, during which time the domain may NOT be restored. The domain is released from the SRS, at the end of the 5 day non-restore period. A restore fee applies and is detailed in the Billing Section. A renewal fee will be automatically applied for any domain past expiration.

Neustar has created a unique restoration process that uses the EPP Renew transaction to restore the domain and fulfill all the reporting obligations required under ICANN policy. The following describes the restoration process.

27.5 State Diagram

Figure 27-1 attached provides a description of the registration lifecycle. 

The different states of the lifecycle are active, inactive, locked, pending transfer, and pending delete. Please refer to section 27.2 for detailed descriptions of each of these states. The lines between the states represent triggers that transition a domain from one state to another.  

The details of each trigger are described below:

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

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

27.5.1 EPP RFC Consistency

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

27.6 Resources

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

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

-Development⁄Engineering – 19 employees
-Registry Product Management – 4 employees

These resources are more than adequate to support the development needs of all the TLDs operated by Neustar, including the .CLUB registry. 

28.1 Abuse Prevention and Mitigation
Strong abuse prevention within a new gTLD is an important benefit to the internet community. .CLUB and its registry operator and back-end registry services provider, Neustar, intend to implement resources and policies designed to minimize the negative effects of any abusive domain name registrations. Neustar brings extensive experience establishing and implementing registration anti-abuse policies. This experience will be leveraged to help .CLUB combat abusive domain registrations and malicious domain activity within this new TLD, including, but not limited to:

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

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

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

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

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

28.2 Policies Regarding Abuse Complaints
.CLUB will implement and enforce an Acceptable Use Policy that clearly delineates the types of activities that constitute “abuse” -- and the repercussions associated with any abusive domain name registration or malicious activity. In addition, the policy will be incorporated into the applicable Registry-Registrar Agreement and will reserve the right for the registry to take the appropriate actions based on the type of abuse. This may include locking down the domain name, thus preventing any changes to the contact and nameserver information associated with the domain name, placing the domain name “on hold” rendering the domain name non-resolvable, transferring the domain name to another registrar, and⁄or in cases in which the domain name is associated with an existing law enforcement investigation and at the request of such law enforcement entity, substituting name servers to collect information about the DNS queries to assist the investigation.
 
.CLUB will adopt an Acceptable Use Policy that clearly defines the types of activities that will not be permitted in the TLD and reserves the right of the registry operator to lock, cancel, transfer or otherwise suspend or take down domain names violating the Acceptable Use Policy. Furthermore, it will allow the Registry to share information with law enforcement. Each ICANN-Accredited Registrar must agree to pass through the Acceptable Use Policy to its Resellers (if applicable) and ultimately to all domain name registrants within the .CLUB TLD. Below is the Registry’s draft Acceptable Use Policy intended for use in connection with the .CLUB.

.CLUB Acceptable Use Policy
This Acceptable Use Policy gives the Registry the ability to quickly lock, cancel, transfer or take ownership of any .CLUB domain name, either temporarily or permanently, if the domain name is being used in a manner that appears to threaten the stability, integrity or security of the Registry, or any of its registrar partners – and⁄or that may put the safety and security of any registrant or user at risk. The Acceptable Use Policy also allows the Registry to take preventive measures to avoid any such criminal or security threats.

The Acceptable Use Policy may be triggered through a variety of channels, including, among other things, private complaint, public alert, government or enforcement agency outreach, and the on-going monitoring by the Registry or its contractors. In all cases, the Registry or its designees will alert Registry’s registrars about any identified threats, and will work closely with them to bring offending domains registered by them into compliance.

The following are some (but not all) activities that may be subject to rapid compliance actions:

- Phishing: the attempt to trick Internet users into divulging personal data such as usernames, passwords, or financial data.
- Pharming: the redirection of Internet users to websites other than those the user intends to visit, usually through unauthorized changes to the Hosts file on a victim’s computer or DNS records in DNS servers.
- Dissemination of Malware: the intentional creation and distribution of ʺmaliciousʺ software designed to infiltrate a computer system without the owner’s consent, including, without limitation, computer viruses, worms, key loggers, and Trojans.
- Fast Flux Hosting: a technique used to shelter Phishing, Pharming and Malware sites and networks from detection and to frustrate methods employed to defend against such practices, whereby the IP address associated with fraudulent websites are changed rapidly so as to make the true location of the sites difficult to find.
- Botnetting: the development and use of a command, agent, motor, service, or software which is implemented: (1) to remotely control the computer or computer system of an Internet user without their knowledge or consent, (2) to generate direct denial of service (DDOS) attacks.
- Malicious Hacking: the attempt to gain unauthorized access (or exceed the level of authorized access) to a computer, information system, user account or profile, database, or security system.
- Child Pornography: the storage, publication, display and⁄or dissemination of pornographic materials depicting individuals under the age of majority in the relevant jurisdiction.

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

The Registry is committed to ensuring that those domain names associated with abuse or Malicious conduct in violation of the Acceptable Use Policy is intended to be dealt with in a timely and decisive manner. Compliance actions may be taken against those domain names that are being used to threaten the stability and security of the TLD and⁄or the internet, or is part of an investigation by law enforcement. 

Once a complaint is received from a trusted source, law enforcement entity or any other third-party, or malicious activity is detected by the Registry or registrar, the Registry will use commercially reasonable efforts to verify the malicious activity and⁄or other information in the complaint. If that information can be verified in a commercially reasonable fashion by the Registry, then the sponsoring registrar will be notified and will be given 12 hours to investigate the activity and either 1) take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or 2) provide a compelling argument to the Registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), then the Registry may place the domain on “ServerHold”. 

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

In the event such request involves any of the activities which can be validated by the Registry and involves the type of activity set forth in the Acceptable Use Policy, the sponsoring registrar is then given 12 hours to investigate the activity further and either 1) take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or 2) provide a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), the Registry may place the domain on “serverHold”. Although this action removes the domain name from the TLD zone, the domain name record still appears in the TLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved.

Monitoring for Malicious Activity
In addition to ICANN-required RPMs primarily intended to address intellectual property concerns, .CLUB sees great value in continually monitoring all .CLUB domains for websites or servers that are hosting malware which might infect visitors to such domains. Therefore, .CLUB intends to perform a periodic malware scan of the TLD zone, to analyse all websites hosted within the TLD zone, scan for malware, then determine if there is malicious content that may infect visitors, and report same to the affected registrar and registrant with remediation instructions. We believe this will help mitigate damage from ‘drive by downloads’ that cause a great deal of identity theft and computer system damage today.

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

With the assistance of Neustar as its back-end registry services provider, .CLUB can meet its obligations under Section 2.8 of the Registry Agreement where required to take reasonable steps to investigate and respond to reports from law enforcement and governmental and quasi-governmental agencies of illegal conduct in connection with the use of its TLD. .CLUB and⁄or Neustar will endeavor to respond to legitimate law enforcement inquiries within one business day from receiving the request. Such response shall include, at a minimum, an acknowledgement of receipt of the request, questions or comments concerning the request, and an outline of the next steps to be taken by .CLUB and⁄or Neustar for rapid resolution of the request.
 
In the event such request involves any of the activities which can be commercially reasonably validated by .CLUB and⁄or Neustar and involves the type of activity set forth in the Acceptable Use Policy, the sponsoring registrar is then given 12 hours to investigate the activity further and either 1) take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or 2) provide a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), Neustar may place the domain on “serverHold”. 

28.3 Measures for Removal of Orphan Glue Records
As the Security and Stability Advisory Committee of ICANN (SSAC) rightly acknowledges, although orphaned glue records may be used for abusive or malicious purposes, the “dominant use of orphaned glue supports the correct and ordinary operation of the DNS.” See http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf. 

While orphan glue records often support correct and ordinary operation of the DNS, we understand that such glue records can be used maliciously to point to name servers that host domains used in illegal phishing, bot-nets, malware, and other abusive behaviors. Problems occur when the parent domain of the glue record is deleted but its children glue records still remain in DNS. Therefore, when the Registry has written evidence of actual abuse of orphaned glue, the Registry will take action to remove those records from the zone to mitigate such malicious conduct. 

Neustar runs a daily audit of entries in its DNS systems and compares those with its provisioning system. This serves as an umbrella protection to make sure that items in the DNS zone are valid. Any DNS record that shows up in the DNS zone, but not in the provisioning system, will be flagged for investigation and removed if necessary. This daily DNS audit serves to not only prevent orphaned hosts but also other records that should not be in the zone.
 
In addition, if either .CLUB or Neustar become aware of actual abuse of any orphaned glue record after receiving notification by a third party through its Abuse Contact or through its customer support, then such glue records will be removed from the zone. 

28.4 Measures to Promote WHOIS Accuracy 
.CLUB acknowledges that ICANN has developed a number of mechanisms over the past decade that are intended to address the issue of inaccurate WHOIS information. .CLUB intends to do more than ICANN’s current minimum requirements, in order to better reflect current and accurate WHOIS information for every .CLUB domain. .CLUB will offer a mechanism whereby third parties can submit complaints directly to the Registry Operator (as opposed to ICANN or the sponsoring Registrar) about inaccurate or incomplete WHOIS data. Such information shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Twenty days after forwarding the complaint to the registrar, .CLUB will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, the Registry Operator may suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.

28.4.1 Authentication of Registrant Information 
.CLUB intends to authenticate registrant information as complete and accurate with measures executed at the time of registration and through other verification measures taken after registration and described below. In particular, through our direct sales channel and through participating registrars, .CLUB will screen incoming registration requests for common and current indicia of fraud, through algorithmic technology commonly referred to as a “fraud engine.” This is a step not taken today by many registrars and registries, yet is employed by some of them, and by many other online businesses as a means to reduce fraudulent registrations and other abuse.

Furthermore, the provision of Searchable WHOIS, as described in Response to Question 26, will allow security researchers, IP professionals and law enforcement to more quickly determine if a known bad actor has also registered names in .CLUB, and thus notify us of false WHOIS information that has been supplied by .CLUB registrants.

28.4.2 Monitoring of Registration Data
.CLUB intends to conduct regular monitoring of registration data for accuracy and completeness, employing authentication methods, and establishing policies and procedures to address domain names with inaccurate or incomplete WHOIS data. .CLUB intends on its own initiative, no less than twice per year, perform a manual review of a random sampling of .CLUB domain names to test the accuracy of the WHOIS information. Although this will not include verifying the actual information in the WHOIS record, .CLUB will be examining the WHOIS data for prima facie evidence of inaccuracies. In the event that such evidence exists, it shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Twenty days after forwarding the complaint to the registrar, .CLUB will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, .CLUB may suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.

This audit will occur more often and with more effectiveness than ICANN’s annual WHOIS data verification policy applicable in the existing gTLDs. Specifically, the existing policy does not require affirmative response from the WHOIS email addresses, merely to ensure that they are still valid and monitored. .CLUB’s audit policy will generally require this periodic verification.

28.4.3 Policies and Procedures Ensuring Compliance
When .CLUB or any .CLUB registrar receives a notice of false WHOIS information or other activity which violates our Acceptable Use Policy, the relevant registrar will be required to promptly acknowledge the notice, conduct a reasonable investigation, and report to the complainant and to .CLUB the results of such investigation – whether appropriate action was taken, whether further information is required in order to evaluate the complaint, or whether the complaint was found invalid.

28.5 Resourcing Plans 
Responsibility for abuse mitigation rests with a variety of functional groups. Neustar’s Abuse Monitoring team is primarily responsible for providing analysis and conducting investigations of reports of abuse. Neustar’s customer service team also plays an important role in assisting with the investigations, responded to the registry operator and registrars, and notifying registrars of abusive domains. Finally, Neustar’s Policy⁄Legal team, in conjunction with Registry Operator, is responsible for developing the relevant policies and procedures. 

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

Customer Support – 12 employees
Policy⁄Legal – 2 employees

These Neustar resources, coupled with .CLUB’s own resources, are more than adequate to support the abuse mitigation procedures of the .CLUB registry. 

The necessary .CLUB resources will be pulled from the pool of available employee and contract (FTE) Full Time Equivalent resources who will be available to support this activity;

Development⁄Technology - 5 FTEs in Y1, expanding to 7 FTEs by Y3.
Customer Support and Compliance - 6FTEs in Y1, expanding to 11 FTEs Yr3.

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

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

A. Trademark Clearinghouse Including Sunrise and Trademark Claims

The first mandatory rights protection mechanism (“RPM”) required to be implemented by each new gTLD Registry is support for, and interaction with, the trademark clearinghouse. The trademark clearinghouse is intended to serve as a central repository for information to be authenticated, stored and disseminated pertaining to the rights of trademark holders. The data maintained in the clearinghouse will support and facilitate other RPMs, including the mandatory Sunrise Period and Trademark Claims service. Although many of the details of how the trademark clearinghouse will interact with each registry operator and registrars are yet to be developed, .CLUB is actively monitoring the developments of the Implementation Assistance Group (“IAG”) designed to assist ICANN staff in firming up the rules and procedures associated with the policies and technical requirements for the trademark clearinghouse. In addition, Neustar, .CLUB’s back-end registry services provider is actively participating in the IAG to ensure that the protections afforded by the clearinghouse and associated RPMs are feasible and implementable.

Utilizing the trademark clearinghouse, all operators of new gTLDs must offer: (i) a sunrise registration service for at least 30 days during the pre-launch phase, giving eligible trademark owners an early opportunity to register second-level domains in new gTLDs; and (ii) a trademark claims service for at least the first 60 days that second-level registrations are open for general registration. The trademark claim service is intended to provide “clear noticeʺ to a potential registrant of the rights of a trademark owner whose trademark is registered in the clearinghouse.
.CLUB’s registry service provider, Neustar, has already implemented Sunrise and⁄or Trademark Claims programs for numerous TLDs including .biz, .us, .travel, .tel and .co -- and will implement both of these services on behalf of .CLUB. 

B. Neustar’s Experience in Implementing Sunrise and Trademark Claims Processes

In early 2002, Neustar became the first registry operator to launch a successful, authenticated Sunrise process. This process permitted qualified trademark owners to pre-register their trademarks as domain names in the .us TLD space prior to the opening of the space to the general public. Unlike any other “Sunrise” plans implemented (or proposed before that time), Neustar validated the authenticity of Trademark applications and registrations with the United States Patent and Trademark Office (USPTO). 

Subsequently, as the back-end registry operator for the .tel gTLD and the .co ccTLD, Neustar launched validated Sunrise programs employing processes very similar to those that are to be employed with respect to the Trademark Clearinghouse for new gTLDs. 

Below is a high level overview of the implementation of the .co Sunrise period that demonstrates Neustar’s experience and ability to provide a Sunrise service and an overview of Neustar’s experience in implementing a Trademark Claims program to trademark owners for the launch of .BIZ. Neustar’s experience in each of these rights protection mechanisms will enable it to seamlessly provide these services on behalf of .CLUB as ultimately required by ICANN. 

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

Like the new gTLD process set forth in the Applicant Guidebook, trademark owners had to have their rights validated by a Clearinghouse provider prior to the registration being accepted by the Registry. The Clearinghouse used a defined process for checking the eligibility of the legal rights claimed as the basis of each Sunrise application, using official national trademark databases and submitted documentary evidence. 

Applicants and⁄or their designated agents had the option of interacting directly with the Clearinghouse to ensure their applications were accurate and complete prior to submitting them to the Registry pursuant to an optional “Pre-validation Process”. Whether or not an applicant was “pre-validated”, the applicant had to submit its corresponding domain name application through an accredited registrar. When the Applicant was pre-validated through the Clearinghouse, each was given an associated approval number that it had to supply the registry. If they were not pre-validated, applicants were required to submit the required trademark information through their registrar to the Registry.

At the registry level, Neustar, subsequently either delivered the: 
- Approval number and domain name registration information to the Clearinghouse; or,
- When there was no approval number, trademark information and the domain name registration information was provided to the Clearinghouse through EPP (as is currently required in the draft Registry Agreement). 

Information was then used by the Clearinghouse as either further validation of those pre-validated applications, or initial validation of those that did not go through pre-validation. If the applicant was validated and their trademark matched the domain name applied-for, the Clearinghouse communicated that fact to the Registry via EPP. 

When there was only one validated sunrise application, the application proceeded to registration when the .co TLD re-launched. If there were multiple validated applications (recognizing that there could be multiple trademark owners sharing the same trademark), those were included in the .co Sunrise auction process. Neustar tracked all of the information it received and the status of each application and posted that status on a secure Website to enable trademark owners to view the status of its Sunrise application. 

Although the exact process for the Sunrise program and its interaction between the trademark owner, Registry, Registrar, and Trademark Clearinghouse is not completely defined in the draft Registry Agreement and is dependent on the current RFI issued by ICANN in its selection of a Trademark Clearinghouse provider, Neustar’s expertise in launching multiple Sunrise processes and its established software will implement a smooth and compliant Sunrise process for .CLUB.

ii. Trademark Claims Service Experience

With Neustar’s biz TLD launched in 2001, Neustar became the first TLD with a Trademark Claims service. Neustar developed the Trademark Claim Service by enabling companies to stake claims to domain names prior to the commencement of live .biz domain registrations. 

During the Trademark Claim process, Neustar received over 80,000 Trademark Claims from entities around the world. Recognizing that multiple intellectual property owners could have trademark rights in a particular mark, multiple Trademark Claims for the same string were accepted. All applications were logged into a Trademark Claims database managed by Neustar. 
 
The Trademark Claimant was required to provide various information about their trademark rights, including the:
- Particular trademark or service mark relied on for the trademark Claim
- Date a trademark application on the mark was filed, if any, on the string of the domain name
- Country where the mark was filed, if applicable
- Registration date, if applicable
- Class or classes of goods and services for which the trademark or service mark was registered
- Name of a contact person with whom to discuss the claimed trademark rights. 

Once all Trademark Claims and domain name applications were collected, Neustar then compared the claims contained within the Trademark Claims database with its database of collected domain name applications (DNAs). In the event of a match between a Trademark Claim and a domain name application, an e-mail message was sent to the domain name applicant notifying the applicant of the existing Trademark Claim. The e-mail also stressed that if the applicant chose to continue the application process and was ultimately selected as the registrant, the applicant would be subject to Neustar’s dispute proceedings if challenged by the Trademark Claimant for that particular domain name. 

The domain name applicant had the option to proceed with the application or cancel the application. Proceeding on an application meant that the applicant wanted to go forward and have the application proceed to registration despite having been notified of an existing Trademark Claim. By choosing to “cancel,” the applicant made a decision in light of an existing Trademark Claim notification to not proceed. 

If the applicant did not respond to the e-mail notification from Neustar, or elected to cancel the application, the application was not processed. This resulted in making the applicant ineligible to register the actual domain name. If the applicant affirmatively elected to continue the application process after being notified of the claimant’s (or claimants’) alleged trademark rights to the desired domain name, Neustar processed the application. 

This process is very similar to the one ultimately adopted by ICANN and incorporated in thedraft Registry Agreement. Although the collection of Trademark Claims for new gTLDs will be by the Trademark Clearinghouse, many of the aspects of Neustar’s Trademark Claims process in 2001 are similar to those in the Applicant Guidebook. This makes Neustar uniquely qualified to implement the new gTLD Trademark Claims process.
 
B. Uniform Dispute Resolution Policy (UDRP) and Uniform Rapid Suspension (URS)

1. UDRP
The UDRP has been required to be implemented by all domain name registries and registrars since 1999. The UDRP is intended as an alternative dispute resolution process to transfer domain names from those that have registered and used domain names which are 1) confusingly similar to another’s trademark; 2) with no legitimate interest demonstrated by the registrant; and 3) with bad faith intent to profit. Although there is not much of an active role that the domain name registry plays in the implementation of the UDRP, Neustar has closely monitored UDRP decisions that have involved the TLDs for which it supports and ensures that the decisions are implemented by the registrars supporting its TLDs. When alerted by trademark owners of failures to implement UDRP decisions by its registrars, Neustar either proactively implements the decisions itself or reminds the offending registrar of its obligations to implement the decision. 

2. URS
In response to complaints by trademark owners that the UDRP was too cost prohibitive and slow, and the fact that more than 70 percent of UDRP cases were “clear cut” cases of cybersquatting, ICANN adopted a requirement that all new gTLD registries be required, pursuant to their contracts with ICANN, to take part in a Uniform Rapid Suspension System (“URS”). The purpose of the URS is to provide a more cost effective and timely mechanism for brand owners than the UDRP, to protect their trademarks and to promote consumer protection on the Internet. 

The URS is not meant to address questionable cases of alleged infringement (e.g., use of terms in a generic sense), but rather is intended only for those cases in which there is no genuine contestable issue as to the infringement and abuse that is taking place. 

Unlike the UDRP which requires little involvement of gTLD registries, the URS envisages much more of an active role at the registry-level. For example, rather than requiring the registrar to lock down a domain name subject to a UDRP dispute, it is the registry under the URS that must lock the domain within 24 hours of receipt of the complaint from the URS Provider. This will restrict all changes to the registration data, including transfer and deletion of the domain names. 

In addition, in the event of a determination in favor of the complainant, the registry is required to suspend the domain name. This suspension remains for the balance of the registration period, during which time the domain name will not resolve the original website. Rather, the nameservers would be redirected to an informational web page provided by the URS Provider about the URS. 

Additionally, the WHOIS record for a suspended domain will reflect that the domain name will not be able to be transferred, deleted, or modified for the life of the registration. Finally, there is an option for a successful complainant to extend the registration period for one additional year at commercial rates. 

.CLUB is fully aware of each of these requirements and will have the capability to implement these requirements for new gTLDs. In fact, during the IRT’s development of f the URS, Neustar began examining the implications of the URS on its registry operations and provided the IRT with feedback on whether the recommendations from the IRT would be feasible for registries to implement. 

Although there have been a few changes to the URS since the IRT recommendations, Neustar continued to participate in the development of the URS by providing comments to ICANN, many of which were adopted. As a result, Neustar is committed to supporting the URS for all of the registries that it provides back-end registry services.

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

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

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

Monitoring for Malicious Activity 
.CLUB is committed to ensuring that those domain names associated with abuse or malicious conduct in violation of the Acceptable Use Policy are dealt with in a timely and decisive manner. These include taking action against those domain names that are being used to threaten the stability and security of the TLD, or are part of an investigation by law enforcement. 
Once a complaint is received from a trusted source, law enforcement entity or other third-party, or malicious activity is detected by the Registry, the Registry will use commercially reasonable efforts to verify the information in the complaint. If that information can be verified to the commercially reasonable satisfaction of the Registry, then the sponsoring registrar will be notified and be given 12 hours to investigate the activity and either 1) take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety, or 2) provide a compelling argument to the Registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), then the Registry may place the domain on “ServerHold”. Although this action removes the domain name from the TLD zone, the domain name record still would appear in the TLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved.

Malware Scan.
In addition to ICANN-required RPMs primarily intended to address intellectual property concerns, .CLUB sees great value in continually monitoring all .CLUB domains for websites or servers that are hosting malware which might infect visitors to such domains. Therefore, .CLUB intends to perform a periodic malware scan of the TLD zone, to analyse all websites hosted within the TLD zone, scan for malware, then determine if there is malicious content that may infect visitors, and report same to the affected registrar and registrant with remediation instructions. We believe this will help mitigate damage from ‘drive by downloads’ that cause a great deal of identity theft and computer system damage today.

29.2 Safeguards against Unqualified Registrations
.CLUB acknowledges that ICANN has developed a number of mechanisms over the past decade that are intended to address the issue of inaccurate WHOIS information. .CLUB intends to do more than ICANN’s current minimum requirements, in order to better reflect current and accurate WHOIS information for every .CLUB domain. .CLUB will offer a mechanism whereby third parties can submit complaints directly to the Registry Operator (as opposed to ICANN or the sponsoring Registrar) about inaccurate or incomplete WHOIS data. Such information shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Twenty days after forwarding the complaint to the registrar, .CLUB will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, the Registry Operator may suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.

In addition, .CLUB intends on its own initiative, no less than twice per year, perform a manual review of a random sampling of [.TLD] domain names to test the accuracy of the WHOIS information. Although this will not include verifying the actual information in the WHOIS record, .CLUB will be examining the WHOIS data for prima facie evidence of inaccuracies. In the event that such evidence exists, it shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Twenty days after forwarding the complaint to the registrar, the Applicant will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, .CLUB may suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.

This audit will occur more often and with more effectiveness than ICANN’s annual WHOIS data verification policy applicable in the existing gTLDs. Specifically, the existing policy does not require affirmative response from the WHOIS email addresses, merely to ensure that they are still valid and monitored. .CLUB’s audit policy will generally require this periodic verification.

Authentication of Registrant Information 
.CLUB intends to authenticate registrant information as complete and accurate upon registration. In particular, through our direct sales channel and through participating registrars, .CLUB will screen incoming registration requests for common and current indicia of fraud, through algorithmic technology commonly referred to as a “fraud engine.” Again this is a step not taken today by many registrars and registries, yet is employed by some of them, and by many other online businesses as a means to reduce fraudulent registrations and other abuse.

Furthermore, the provision of Searchable WHOIS, as described in Response to Question 26, will allow security researchers, IP professionals and law enforcement to more quickly determine if a known bad actor has also registered names in .CLUB, and thus notify us of false WHOIS information that has been supplied by .CLUB registrants.

Policies and Procedures Ensuring Compliance
When .CLUB or any .CLUB registrar receives a notice of false WHOIS information or other activity which violates our Acceptable Use Policy, the relevant registrar will be required to promptly acknowledge the notice, conduct a reasonable investigation, and report to the complainant and to .CLUB the results of such investigation – whether appropriate action was taken, whether further information is required in order to evaluate the complaint, or whether the complaint was found invalid.

29.3 Resourcing Plans
The rights protection mechanisms described in the response above involve a wide range of tasks, procedures, and systems. The responsibility for each mechanism varies based on the specific requirements. In general the development of applications such as sunrise and IP claims is the responsibility of Neustar’s Engineering team, with guidance from its Product Management team. Neustar’s and .CLUB’s Customer Support, and Legal teams play a critical role in enforcing certain policies such as the rapid suspension processes. These teams have years of experience implementing these or similar processes. 

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

Development⁄Engineering – 19 employees
Product Management- 4 employees
Customer Support – 12 employees

These resources, coupled with .CLUB’s own resources, are more than adequate to support the rights protection mechanisms of the .CLUB registry. The necessary .CLUB resources will be pulled from the pool of available employee and contract FTE (Full Time Equivalent) resources who will be available to support this activity;

Development⁄Technology - 5 FTEs in Y1, expanding to 7 FTEs by Y3.
Customer Support and Compliance - 6FTEs in Y1, expanding to 11 FTEs Yr3.
Product and Marketing - 2 FTEs in Yr1, expanding to 3 FTEs by Y3.

30.(a).1 Security Policies

.CLUB DOMAINS, LLC and our back-end operator, Neustar recognize the vital need to secure the systems and the integrity of the data in commercial solutions. The .CLUB registry solution will leverage industry-best security practices including the consideration of physical, network, server, and application elements. 

Neustar’s approach to information security starts with comprehensive information security policies. These are based on the industry best practices for security including SANS (SysAdmin, Audit, Network, Security) Institute, NIST (National Institute of Standards and Technology), and CIS (Center for Internet Security). Policies are reviewed annually by Neustar’s information security team.

The following is a summary of the security policies that will be used in the .CLUB registry, including:

1. Summary of the security policies used in the registry operations
2. Description of independent security assessments
3. Description of security features that are appropriate for .CLUB
4. List of commitments made to registrants regarding security levels

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

30.(a).2 Summary of Security Policies 

Neustar has developed a comprehensive Information Security Program in order to create effective administrative, technical, and physical safeguards for the protection of its information assets, and to comply with Neustarʹs obligations under applicable law, regulations, and contracts. This Program establishes Neustarʹs policies for accessing, collecting, storing, using, transmitting, and protecting electronic, paper, and other records containing sensitive information.

-The policies for internal users and our clients to ensure the safe, organized and fair use of information resources.
-The rights that can be expected with that use. 
-The standards that must be met to effectively comply with policy.
-The responsibilities of the owners, maintainers, and users of Neustar’s information resources.
-Rules and principles used at Neustar to approach information security issues

The following policies are included in the Program:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

30.(a).3 Independent Assessment Reports

Neustar IT Operations is subject to yearly Sarbanes-Oxley (SOX), Statement on Auditing Standards #70 (SAS70) and ISO audits. Testing of controls implemented by Neustar management in the areas of access to programs and data, change management and IT Operations are subject to testing by both internal and external SOX and SAS70 audit groups. Audit Findings are communicated to process owners, Quality Management Group and Executive Management. Actions are taken to make process adjustments where required and remediation of issues is monitored by internal audit and QM groups.

External Penetration Test is conducted by a third party on a yearly basis. As authorized by Neustar, the third party performs an external Penetration Test to review potential security weaknesses of network devices and hosts and demonstrate the impact to the environment. The assessment is conducted remotely from the Internet with testing divided into four phases:

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

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

30.(a).4 Augmented Security Levels and Capabilities

There are no increased security levels specific for .CLUB. However, Neustar will provide the same high level of security provided across all of the registries it manages. 
A key to Neustar’s Operational success is Neustar’s highly structured operations practices. The standards and governance of these processes:
 
-Include annual independent review of information security practices 
-Include annual external penetration tests by a third party 
-Conform to the ISO 9001 standard (Part of Neustar’s ISO-based Quality Management System)
-Are aligned to Information Technology Infrastructure Library (ITIL) and CoBIT best practices 
-Are aligned with all aspects of ISO IEC 17799
-Are in compliance with Sarbanes-Oxley (SOX) requirements (audited annually)
-Are focused on continuous process improvement (metrics driven with product scorecards reviewed monthly).

A summary view to Neustar’s security policy in alignment with ISO 17799 can be found in section 30.(a).5 below.

30.(a).5 Commitments and Security Levels 

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

Compliance with High Security Standards

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

Highly Developed and Document Security Policies

-Compliance with all provisions described in section 30.(b) and in the attached security policy document.
-Resources necessary for providing information security
-Fully documented security policies
-Annual security training for all operations personnel

High Levels of Registry Security

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