Application number: 1-870-27617 for Desi Networks LLC

Desi Networks LLC

0013014529028

0013016567111

Mr. Ravin Ohri

CEO

0013014529028

rohri@desinetwork.in

Mr. Siddharth Ohri

COO

0012022364338

support@desinetwork.in

Limited Liability Corporation

State of Maryland, US

Not Available

Jeffery Brown
Chief Marketing Officer
Ravin Ohri
Chief Executive Officer
Siddharth Ohri
Chief Operations Officer

Jeffery Brown
Chief Marketing Officer
Ravin Ohri
Chief Executive Officer
Siddharth Ohri
Chief Operations Officer

Jeffery Brown
Chief Marketing Officer
Ravin Ohri
Chief Executive Officer
Siddharth Ohri
Chief Operations Officer

desi

Not Available

DESI Networks LLC, (the Company) has carefully examined (including S.W.O.R.D testing) the applied-for string “DESI” and found that deployment of it would not cause adverse operational, rendering or general user-confusion due to visual similarity with existing TLDs⁄ISO3166 lists⁄ICANN reserved list of names and list of ineligible strings. The string consists of ASCII letters and is a valid hostname having at least three and less than 63 ASCII characters. The label is therefore in compliance with the string requirements set forth in the Applicant Guidebook (Applicant Guidebook, page 64, section: 2.2.1.3.2 “String Requirements”) and with all technical standards such as but not limited to RFC 1035, RFC 2181, RFC 952, RFC 1123, and RFC 3696.
Although the applied for string is pure ASCII characters, the applicant is aware that it may need to mitigate inter alia such issues, as discussed on the “TLD Universal Acceptance” session at the Costa Rica ICANN Meeting on Wed, 14 March 2012. (http:⁄⁄costarica43.icann.org⁄meetings⁄sanjose2012⁄presentation-tld-universal-acceptance-14mar12-en.pdf) such as:
- Validity checks of TLDs based on either a hard coded list (may not be updated with all new gTLDs) or on a length check (i.e. maximum three characters
- Name conversion in various applications and browsers
- User acceptance. Some websites⁄applications may refuse user acceptance of users entering a new gTLD not accepted by the website⁄application
- Email clients validating on length on TLDs on by applying an outdated list of TLDs may also cause problems for this new gTLD, as valid email addresses may not be accepted
Websites and Search Engines   such as, but not limited to, Google, Yahoo! may refuse to offer services such as advertising, if they validate email addresses and valid domain names based on outdated definitions of TLDs, or simply refuse to add new gTLDs to their lists. Mobile browsers may also not be updating their lists of valid TLDs, as live DNS look ups, may be considered costly or in adequate by the providers.
A. Actions to mitigate or solve these issues
As the TLD is longer than 3 characters, it is understood that some issues concerning usage of DOT DESI in online forms may occur from time to time. The Company will work towards enabling general global acceptance for not just this TLD but all others as well. DESI Networks LLC will ensure that all known websites expecting to use DOT DESI will be communicated with concerning this issue and we will make all our own online forms available to accept all ICANN TLDs per the IANA list.
DESI Networks LLC has decided not to pursue 2nd Level IDN functionality at this time.

DESI Networks, LLC(the Company), the organization behind DOT DESI, is committed to providing a secure platform that will: unite the DESI Diaspora worldwide, promote the DESI culture to all who share an interest in it, energize the DESI population to foster education and internet growth and give back to the DESI people through education and philanthropy.

The term DESI refers to the people, culture and products from the Indian subcontinent. It includes peoples of similar origin across the globe and constitutes 24% of the world population. The term is used by the Diaspora to connote an origin or a connection with the DESI regions.

DOT DESI is intended to benefit a global network by providing a designated, secure namespace for cultures, people and businesses of the DESI countries in the Indian subcontinent and its widespread Diaspora. DESI countries include India, Nepal, Pakistan, Bangladesh and Sri Lanka. There are large active and growing populations in the United States, United Kingdom, Canada, South Africa, Australia, Singapore, Mauritius and other countries.

The Company’s mission is to provide a secure Internet space that will facilitate the distribution and exchange of information among DESI stakeholders by means of, but not limited to, websites, social networks, email and other technologies that will reside within the DOT DESI domain name space. In addition, and as technology needs advance and change, ancillary services may be provided in relation to registration of domains within the TLD, including but not limited to website hosting, Search Engine Optimization (SEO), marketing and consulting services.

Two of the founders are expatriates of India, educated abroad, with extensive ties back home. The Company has a strong desire to use the resources developed overseas to give back to India and the other DESI countries and assist with their development. To this end, the efforts of DESI Networks LLC will be focused on facilitating new domain adoption and expanding Internet acceptance amongst the DESI people and those interested in the DESI culture. In order to meet this objective it will be necessary to reach segments of the population that are not currently using the Internet or have stagnant web presence. The Company plans on accomplishing this objective in the following manner:

- Domain growth: In addition to the advantages gained through better domain name availability, DOT DESI registrants will know that their registrations are contributing to the growth of the culture. This will help drive early adoption of new registrations and provide a vehicle for those interested in helping
- Philanthropy: No less than five percent (5%) of the gross revenue from each new DOT DESI domain registration will be given back to DESI countries, through select charities and partner organizations, to create work, foster agriculture and education. Our belief is that by making the technology more accessible and more meaningful to those interested in the DESI culture, positive growth will naturally follow. This meets our vision of strengthening the DESI bonds and elevating the culture.

Desi Networks, LLC intends for DOT DESI names to be registered and used by persons and entities within the DESI region or who maintain an affinity towards the region and its Diaspora. However, DOT DESI domain registrations will not be restricted to such persons and entities. The Company’s goal is to promote the culture and as such anyone will be able to register a DOT DESI domain name.

The DOT DESI TLD is intended to benefit internet users by enabling DESI region residents and Diaspora to communicate more easily and effectively with each other and across the global internet. Users will benefit from a more distinctive and trustworthy internet experience in dealing with DOT DESI domain registrants because of the specific nature of the TLD. When a domain with the DOT DESI extension is identified, the expectation is that that entity is connected to the DESI culture. It will help filter search results that are unrelated.

The Company expects to provide an ample supply of relevant and available domain names for interested persons to claim an internet presence within the DOT DESI domain space. Today, DESI residents and Diaspora do not have any particular domain space catering to their needs, but instead use a variety of the existing gTLDs and ccTLDs without any consistency across the region and its Diaspora.


i) What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?

DESI Networks, LLC, is committed to being a respected leader in the TLD space with a reputation for offering a quality product and superior service levels. Our goals are as follows:

- To promote cultural awareness and collaboration for the DESI population and those interested in the DESI culture. We will enhance the DESI experience by engaging associations, organizations and individuals that have an active interest in the DESI lifestyle, culture, and values and providing a channel for them to make their services known. Our marketing and communications will highlight the people and the culture. We will assist members of the Diaspora by helping cultivate interactions online. Millions of people and entities identify with the DESI region and as a result will benefit from registering under the DOT DESI TLD. We seek to make DOT DESI ubiquitous across the DESI region and parts outside:
- To be a respected member of the international community known for integrity, innovation and philanthropy
- Provide a valuable service at a fair price to people who are interested in the DESI lifestyle, values and cultures 
- Provide a stable, reliable and secure technology platform that our customers can rely upon in providing their business and communications to the online DESI collective


ii) What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

DOT DESI will provide an alternative to the current TLDs. Our focus upon the DESI cultures, region and Diaspora sets us apart. We are committed to the values, beliefs, lifestyles and cultures of the DESI people worldwide. DOT DESI will serve as a differentiation force, as a distinctive name space that simplifies users’ choice to interact with people and entities that identify with the DESI region and cultures. For example, a restaurant with a similar naming convention can stand out by using a DOT DESI extension. ‘Restaurant.DESI’ demonstrates a definitive perspective and would not likely be confused with ‘Restaurant.com’, .biz or .info. Furthermore, the Company expects that many users will be able to directly navigate to intuitive DOT DESI domains and subdomains; saving time and resources from first accessing a search engine.

The Company’s expectation is that consumers will learn to distinguish the new TLDs from the existing TLDs and from other new generic, branded, geographical or cultural TLDs. The availability and potential of registration of new domains with DOT DESI ultimately should foster competition by diverting the number of domain registrations with existing registration providers. This effect, multiplied by the advent of many new TLDs, would result in increased competition among the existing registration providers. This will create a need to compete more fiercely for the remaining business interest in their existing TLDs, and with many new organizations offering use and⁄or registration of new TLD domain names. The logical effect should be lower pricing and better service for all internet users. 

Today it is often difficult to find a relevant and easily available domain name from existing registration providers. Even if one is found, often pricing is prohibitive because the domain name is only available on the secondary market. All new domains must be purchased from third parties and then managed as intellectual property assets. These expenses and complications can be dramatically reduced over time. The DOT DESI TLD will allow people and entities with an affinity to the DESI region and cultures to innovate and create many uses for domain names which with today’s restrictions on the availability of domain names are too complicated.

An ample supply of immediately available, relatively inexpensive domain names relevant to the DESI region and Diaspora will thus foster competition and lessen the financial burden on new registrants seeking domain names to perpetuate their brands, businesses, organizations, or other objectives.

Initially, DESI Networks LLC has decided not to pursue IDNs for DOT DESI. It is our intent to incorporate IDN support in the future when the technology is more developed.

iii) What goals does your proposed gTLD have in terms of user experience?

DOT DESI is intended to function with leading-edge technologies and business practices, ensuring a trustworthy and positive user experience. We know that consumers demand reliable, scalable service offerings and that our success demands that we are continually improving our performance and services. Internet based commerce is no longer an afterthought and we recognize that registrants that choose a DOT DESI domain expect it to be available and secure. The Company’s goal is to promote online infrastructure and services to encourage internet users from the DESI regions and Diaspora to interact online with each other. To that end, DESI Networks LLC has engaged KSregistry GmbH, owned by Key-Systems GmBH, to provide registry services and support for DOT DESI domains. Together with ICANN-accredited registrar Moniker, who owns part of the KeyDrive group, (the holding company of Key-Systems) the organization manages over 6 million names and ranks #6 (2012) amongst the world’s largest ICANN-accredited registrars.

Key-Systems GmbH has gathered experience in various roles in the domain business for more than ten years and has access to extensive knowledge in the domain business. This deep industry knowledge and experience has also been transferred to KSregistry GmbH, the technical provider of the KSregistry system (KSR). The commitment to excellence, extensive service offerings, scalable infrastructure and service level agreements offered by KSregistry played a major role in their selection by Desi Networks LLC.

DESI Networks LLC intends for users to perceive DOT DESI as a trustworthy source of online information and services relevant to the DESI cultures, region and Diaspora. DESI Networks intends to provide a safe and legitimate Internet space, enhancing user experience by addressing ICANN mandated policies related to abuse prevention and mitigation, rights protection mechanisms, and security, as further described in our response to Questions 26, 28, 29, and 30.


iv) Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.

The DOT DESI TLD will be open and unrestricted -- allowing anyone to select an appropriate DOT DESI domain name for their own legitimate purposes. Bad faith and other illegal uses of DOT DESI 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, DESI Networks will implement additional rights protection mechanisms as described in response to Questions 28 and 29.


v) Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users? If so, please describe any such measures.

DESI Networks, LLC intends for users to perceive DOT DESI as a trustworthy indicator of the source of online information 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 that enhances user experience by mitigating security-associated risks. With respect to WHOIS data, DESI Networks, LLC intends to comply with ICANN policies and otherwise to ensure that complete and accurate WHOIS information is readily accessible for every DOT DESI domain name.

DESI Networks, LLC 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. Furthermore, the Company complies with all applicable laws and regulations relating to internet security and the privacy of users’ confidential information.


vi) Describe whether and in what ways outreach and communications will help to achieve your projected benefits.

DESI Networks, LLC will promote the DOT DESI TLD more proactively than other TLDs have traditionally done in the past. Given the volume of potential new TLDs available to the public, it will be necessary to find new ways to communicate with potential registrants in order to stand out. In the early stages of the launch, it will be critical to promote DOT DESI continuously and through a variety of mediums. Examples of the channels we are developing are as follows:

- Traditional marketing sources: print media and direct marketing to businesses and brand holders
- Youtube: Viral videos featuring the DOT DESI brand will be spread throughout the DESI network
- Co-marketing with Registrars: Early adopter and multiyear discounts will be offered
- Brand messaging through social networks: The explosion of technologies linking large populations of users has made reaching a wide audience significantly easier. DOT DESI will host social media pages and launch an active awareness campaign that will allow rapid awareness of the TLD
- Philanthropy: Our contributions back to the region will help generate an awareness of the DOT DESI TLD

As a result of the new TLD program and additional domains available, the Company anticipates that user adoption will be widespread. Furthermore, use of domains within DOT DESI will help communicate to the intended audience the availability of the TLD, not only for the specific purpose at hand, but also for general or intuitive purposes. For example, a user who first sees an advertisement for productname.DESI may later directly navigate to company.DESI to search for other products of the producer. Search behaviors will change over time and consumers will become accustomed to searching for content based on extensions. 

In sum, outreach and communication are important in order to achieve the projected benefits of the TLD. These two components will be inherent via use of the TLD and further will be enhanced by the viral nature of communications about the TLD and those individuals and entities who use the DOT DESI domains. It appears there will be many other geographical and cultural TLDs presented to internet users. Consequently, it is expected that the outreach, communications and media relating to each individual TLD, will lead to collective benefits. Many internet users will quickly grasp the concept behind these TLDs and will expect companies to operate them in generally consistent ways.

DESI Networks, LLC will vigilantly pursue policies, procedures and technologies that facilitate and maintain a safe and positive user experience. Eliminating fraud, cyber-squatting and other activities that degrade the user’s trust are of paramount concern. Additionally, our procedures need to be simple for users to follow and the TLD needs to be easy to find and register.

Our technical answers will address the specifics in more detail. As previously noted the Company has partnered with KSregistry because of their established architecture, security measures and proven platform. 

By utilizing KSregistry, registrations will be handled through a proven network of registrars and will ensure proper care is taken to protect consumer data and facilitate timely and accurate registrations. Customer data will be protected as a result of the established processes at KSregistry.


i) How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first-serve basis?

DESI Networks, LLC will offer a phased launch, consistent with many prior gTLD domain name launches. The goal will be to protect brand holders as well as other concerned parties from malicious practices and to ensure accuracy.

- First, a Sunrise Period will be offered (per ICANN’s requirements), 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 name. 
- A Landrush Phase period will follow to allow this opportunity to entities that may not have a brand to protect, but desire a specific domain. These will follow an application process and will not be on a first come first served basis. Applications for identical domains will follow a similar auction process.
- After the Landrush, we will make names generally available for open registration by any interested person or entity. This General Availability Period will open after the Landrush Period has closed and will allow unrestricted registrations of all unreserved, remaining and available names.

An overview of our phased approach is provided below, with dates notational based on registry agreement with ICANN. The start-up plan provides for the orderly introduction of the DOT DESI TLD in a transparent and logical way, for the purpose of ensuring competition, fairness and reliability for ICANN-Accredited Registrars, registrants and the DOT DESI potential registrants. It is intended to create a stable and effective registration process for the benefit of the Internet community and affected stakeholders while minimizing the number of conflicts.

Launch Plan Release: January 2013
Publish Overall Launch Plan on registry website containing Rules, Policies and Schedule two months in advance of Sunrise Period.

Sunrise Period: 3-6 months.
The goal of the Sunrise period is to allow prospective registrants with trademarks or other prior rights to register them as domains in the DOT DESI TLD and to resolve potential disputes arising from overlapping or inconsistent claims. Thus, the Sunrise period will ensure stable registry operations and prepare for full operations, allowing for the adjustment of policies and processes if required. 
During the Sunrise period, KSregistry will closely monitor the day-to-day operations of the registry and adjust policies and processes as necessary to ensure stable registry operation and prepare for commencement of full operations.
- Four (4) stages of Sunrise:
 * Submission of application with full Trademark data.
 * Validation of applicant’s rights to domain by the ICANN mandated Trademark Clearinghouse process.
 * Auction competing application for same domain at our auction services provider
 * Award of domain name
- Allows documented Trademark holders an opportunity to apply for 2nd-level domains
- Competing applicants will be determined by closed auction at end of 3-6 Month period
- Non-competing applicants will be awarded domain at end of Sunrise period and will pay registration fees for the domain
- Minimum 2-year registration, maximum 10 years

Landrush: The Landrush Period will allow for multiple applications for the same domain to be accepted through a fair and equitable procedure. It is open to General Public and will last between 3-6 Months
- Applications open for the general public.
- Not first come first served, applications are collected for the duration of Landrush.
- At end of the landrush phase, domains with single applications are awarded immediately with a 2-year term.
- Domains with multiple applications for same name will go to closed auction administered by Pool.com 1-2 months following close of Landrush period.
- Minimum 2-year registration, maximum 10 years

General Availability: 
Full operations will provide continuous and stable registry operation. Our registry operator (KS Registry) will accept domain name registration requests from all ICANN-Accredited Registrars who have executed a contract with KSregistry. Registry Operator may from time to time update registration operations and procedures, as well as offer new products and services consistent with the Sponsored TLD Registry Agreement. Starts January 2014 - onward (commences after completion of Landrush)
- Applications on a first-come, first-served basis
- Standard pricing for all registrations
- Standard policies 
- The UDRP will be used to resolve trademark or name resolution disputes. All registrants agree to bound by the UDRP: http:⁄⁄www.wipo.int⁄amc⁄en⁄domains⁄gtld⁄udrp⁄
- Minimum 1-year registration, maximum 10 years

DESI Networks, LLC also intends to reserve certain second and third level premium and special purpose names. Such names will be permanently reserved, operated or offered on the most appropriate basis including auctions. The Company will offer a good portion of these reserved names during the landrush period in order to drive traffic to the DOT DESI TLD, thus enabling achievement of our goals and objectives at this stage. The Company may also withhold some reserved premium names for subsequent offering during the General Availability period.


ii) Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts)

DESI Networks, LLC intends to promote early adoption of the DOT DESI TLD by initially offering discounts for multi-year registrations and for purchase of multiple domain registrations. A registrant who chooses a multi-year registration will pay less for the second and successive years which are paid in advance. A registrant who chooses to register multiple domain names at one time will receive a discount on the second and successive registrations made at the same time. Registrants may combine both discounts, for even greater savings.

From time to time promotional campaigns and special offers will be provided equally to the registrars. Market conditions will drive many of the promotions and marketing messages.


iii) Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation?

DESI Networks LLC intends to make clear contractual commitments to registrants regarding the magnitude of price escalation upon renewal. The Company will not raise the base price (exclusive of any discounts, taxes, etc.) of DOT DESI domain name renewals by more than 10 percent in any calendar year.

No

Not Available

No

DESI Networks LLC, (the Company) has engaged KSregistry GmbH to deliver registry services for DOT DESI. This response describes protection of geographic names as implemented in the managed TLD registry service.


A. PROTECTION OF GEOGRAPHIC NAMES

In accordance with Specification 5 of the New gTLD Registry Agreement, the Registry Operator must initially reserve all geographic names at the second level and at all other levels within the TLD at which the Registry Operator provides for registrations.

DESI Networks LLC will comply with this requirement by using the following internationally recognized lists to develop a comprehensive 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 recognized 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]

Names on this reserved list in the TLD registry will be prevented from registration, unless and until any such names are released from reservation per DESI Network’s release procedures generally described below.

A corresponding list of geographic names will be made available to the public via the Registry Operator’s website in order to inform Registrars and potential Registrants of the reserved status of such names.

In addition to these requirements, KSregistry is able to support the wishes of the Company in regards to the reservation of additional terms on a case by case basis. The managed TLD registry allows such additions to the reserved list to be made by appropriately authorized staff, with no further system development changes required.

The following applies to all Domain Names contained within the managed TLD registry reserved list:

- Attempts to register will be rejected.
- Reserved names will not appear in the TLD zone file.
- WhoIs queries will receive responses indicating their reserved status;
- DNS queries will return a NXDOMAIN response.

B. PROCEDURES FOR RELEASE

We understand that if and when The Company wishes to release any reserved names at a later date, this will require further approval from ICANN. In order to release reserved names, The Company will make a proposal to ICANN via the RSEP or other future process created by ICANN for this purpose. The Company expects these reserved names to have significant value to the TLD and to the DESI people and diaspora. Moreover, The Company expects there would be minimal confusion or damage to anyone if geographic terms are released for use in the DOT DESI TLD. Therefore, The Company expects to receive ICANN’s approval to release geographic names for registration and use at the appropriate time, in accord with Specification 5 of the Registry Agreement.

Question 23: Registry Services



KSregistry has been chosen as technical backend for registry operations because of the companyʹs extensive knowledge of the domain industry and technical infrastructure. The parent company of KSregistry, Key-Systems GmbH, has extensive knowledge in the area of handling gTLDs (as of today all gTLDs are already supported) as well as more than 200 different ccTLDs (including com.br, de, jp, be, co.uk, us, etc.). This experience also covers IDN relevant topics as well as DNSSEC and industry best practice elements. Having participated in the early days of the IDN testbed of Verisign, which included the transition to the punycode standard in 2004, KSregistrysʹ parent company gained insight into transitioning processes and all aspects of IDNs. The KSregistry shared registry system (“SRS”) is based on the MetaRegistry platform, which is in use as the domain management platform of Key-Systems. The scalability of the system has been proven in 2007 by handling the transition of the former Namestore ccTLD system for country codes (other than CC and TV) from VeriSign to Key-Systems, as well as the growth of the customer base of Key-Systems. With more than 1,800 reseller-registrars and over 3 million domain names under management, the systemsʹ scalability is proven with the number of domains under management and the number of simultaneous connections from different reseller-registrars. With more than 5 years of experience in running and maintaining an EPP server KSregistry can guarantee the compliance and stability required to run a gTLD EPP service in accordance with the ICANN specifications. The KSregistry staff has repeatedly assisted gTLD and ccTLD operators in improving their systems.



These technical and operational specifications for the Registry DOT DESI consist of the following parts:



The EPP-based KSregistry (KSR) platform provides a stable, DNSSEC and IPv6-enabled SRS that is scalable, state-of-the-art, and secure. 



All registry services will be provided by the KSregistry in a responsible manner adhering to all ICANN requirements for TLD operations. KSregistry has already been chosen as the new technical registry service provider by the operators of the following ccTLDs : dotDM, dotTC, dotVG and dotGD. 



The goal is to operate an ICANN compliant technical registry platform meeting industry best practice standards to allow registrations under the applied for new top level domain.



All registry services described in our responses to questions 23-44 are managed in a contract based on a fixed yearly fee plus a per domain name fee per year.



Thus KSregistry has been mandated to manage all technical tasks related to operating our TLD, and will further support us with their legal resources, as described inter alia in our responses to question 27,31,35,39,43,44 as well as 28 and 29.



Hence, the responses to question 23-44 have been developed together with KSregistry.



All ICANN accredited registrars that meet the registry operators established eligibility criteria must use EPP (see section A below) to interact with the registry and manage their sponsored domain names. Due to the nature of the string as a ʺopenʺ TLD,” it is expected that multiple registrars will seek accreditation.



All fundamental registry services will be subject to the SLAs as defined in question 24. All services are continuously monitored for compliance with the SLAs and to discover increased system load and performance issues prior to affecting the experience of the registrars or end-usersʹ of the TLD.



The registry will implement several blacklists to ensure compliance with ICANN guidelines, including but not limited to Specification 5 of the New gTLD Agreement specifications.



All domain name availability checks and registrations will be checked against the implemented blacklists and eligible registration guidelines to ensure standard compliance and policy guidelines (such as hyphens in third and fourth place are only allowed for valid IDN registrations ʺxn--ʺ).



Two character labels, country and territory names as stated in ISO 3166-1 and all successors thereto, will be blocked and only released if a written confirmation of such a release is granted by the applicable governments. Detailed descriptions on the handling of reserved domain names can be found in answer to question 22.



None of the registry services are offered in a manner that is unique to DOT DESI. They are offered as standard registry services as is the case for established gTLDs today, and no new services are defined for DOT DESI.



KSregistry will support DOT DESI in accordance with the policies established by ICANN and the applicant leveraging a fully operational registry infrastructure supported by experienced professional staff and fully provisioned to immediately launch this and a number of other gTLDs to meet or exceed the Service Levels required in the ICANN contract.



Standard Policies and Dispute Resolution



Domain name registration in the zone are subject to the Uniform Dispute Resolution Policy (UDRP), PDDRP, URS and all successors thereto.



Inter-registrar transfers are subject to the ICANN transfer policy as described in



http:⁄⁄www.icann.org⁄en⁄transfers⁄policy-en.htm and the transfer dispute policy as described in http:⁄⁄www.icann.org⁄en⁄transfers⁄dispute-policy-12jul04.htm.



The registry operator is committed to using best practice standards as described by industry members and ICANN. 



Data Escrow Service



To ensure compliance with the Data Escrow requirements the registry will be using Group NCC to act as the third party data escrow agent (see answer 38 for details). All data uploaded to the escrow agent will follow the specifications published at http:⁄⁄tools.ietf.org⁄html⁄draft-arias-noguchi-registry-data-escrow-02 or any successor RFC.



The purpose of the third party data escrow service is to allow a registry data transition in the case that the registry provider fails to fulfill its SLA or is incapable of continuing the registry operations in a manner defined by ICANN.



Reports will be generated on a regular basis to be used for reportings to ICANN.





A. Receipt of Data from Registrars



A.1 Extensible Provisioning Protocol (EPP)



For the purpose of data exchange with the registrar, EPP is used in combination with an SSL encryption on a dedicated port. The registry will issue an SSL certificate for usage by the registrars.



Our EPP specifications follow the existing RFCs and will comply with all relevant successor standards. RFCs considered for the EPP protocol are: RFC 3735, 5730 – 5734, 5910 and 3915.



The following commands will be available for registry operation:



- CreateDomain, CreateContact, CreateHost

- ModifyDomain, ModifyContact, ModifyHost

- InfoDomain, InfoContact, InfoHost

- DeleteDomain, DeleteContact, DeleteHost

- CheckDomain, CheckContact, CheckHost

- TransferDomain

- RenewDomain



Check commands will be available for accredited registrars to check availability of contact handles, host objects, and domain names.



CreateContact will be used to create contact handles used for subsequent domain registrations and modifications. 



CreateHost will be used to create host objects serving as nameservers.



CreateDomain will enable all ICANN accredited registrars to create a domain name under the respective TLD of this application.



Several ʺInfoʺ commands will be available to provision status information on domains, contacts and host objects to the accredited registrars.



See attached fig. Q23_Figure1.pdf.



Detailed EPP descriptions can be found in the answers to the questions 25, which are incorporated here by reference.



A.2 Production and Operational Testing and Evaluation (OT&E) EPP Servers



There will be two EPP servers to interact with the registry. One will be for production purposes and the other for testing and evaluation (referred to as the OT&E server) of new software versions and EPP client implementations. The production server consists of at least two load balanced servers (n+1). Each new stable production release will be released on the OT&E EPP server at least 30 days in advance. To increase security, a registrar IP address limitation is in place for the EPP servers (both production and OT&E).



A limitation on the allowable commands per time interval will prevent the registrar from affecting other clients in the SRS environment in regard to performance issues and increased system load.



Each registrar in the SRS environment will be entitled to up to five sessions from two different IP addresses. The registrar will be forced to update the registry password for the EPP servers and registrar extranet (see below) at least once every six months.



A.3 Registrar Extranet and SFTP Area



In addition to the EPP system, the registrar can chose to interact with the registry through the registry specific registrar extranet and SFTP area. Access to the SFTP area will be secured by protocol specific encryption mechanisms. Aside from the EPP registrar-registry interaction, the registry extranet is mainly used to adjust registrar specific settings such as accounting, default values for RDDS (WHOIS), and reporting. Different tiers of access are granted to the registrars for this purpose. Access can be limited on a per user and group basis to either read only or write operations for the following objects: domains, hosts, contacts, user and group rights, accounting lists, and current account statement.



The registrar extranet will enable registrars to update their IP address range and passwords for the EPP production, OT&E and SFTP areas. When changes are made to the IP address range a support agent will contact the registrar to verify the changes prior to the implementation. The registry will provide marketing material and⁄or detailed reports to all registrars on a regular basis via the registrar specific SFTP area.



Documents will be generated on a regular basis for all registrars and can be found in the SFTP area. These include transaction reports, monthly billing details, and detailed lists on domain names with a status of PendingDelete, domain names under registrarsʹ management, and contacts used.



Access to the registry extranet and SFTP area is also limited to a set of IP addresses as defined by the registrar during the accreditation process.



A.4 Support Case Handling



Each support case received by the KSregistry system either by email (ticket system) or phone will be subject to a passphrase authentication scheme. The passphrases are given during the registrar accreditation process and will be used to identify authorized persons belonging to the registrar. This will thwart any social hacking attempts by unauthorized users.



Support will be handled through 3 different locations:



- USA, VA, Leesburg: 8 am – 5 pm EST ⁄ UTC⁄GMT -5 hours

- Germany, St. Ingbert: 7 am – 6 pm UTC⁄GMT

- Mexico, Monterey: UTC⁄GMT -6 hours



Supported languages are: English, German, Spanish, French, Polish and Mandarin Chinese. 



Registrar technical support will be available through a dedicated technical support team 24 x 7 x 365. The support team is committed to delivering support by utilizing best practices and industry standards.



A.5 Provisioning of Zone Status Information to Registrars 



Registrars can query the status of a domain name with the “InfoDomain” command or through RDDS. In order to query status information on an existing host-object the command “InfoHost” is used.



The registry operator will inform registrars by email in the cases of unplanned (emergency) or scheduled maintenance. 



Information on planned system maintenance will be sent to all accredited registrars at least 30 days prior to the deployment in the OT&E and production system. Registrars will also be informed in the event that system performance drops below normal operational standards and in the event of unforeseen system outages. 





B. Dissemination of TLD Zone Files



Nameserver operations for the Registry TLD will comply with RFCs 1034, 1035, and 2182 and all future successors and updates thereto. Additional details on the dissemination of TLD Zone Files can be found in answers to question 35 of this application, which are incorporated here by reference.

Distribution of zone files among all secondary nodes will be handled by a dedicated hidden master.



Updates to the primary master node will be performed every 15 minutes and distributed to a secondary master node (operated by PCH.NET, an external service provider specialized in providing anycast DNS services). For additional stability, the two hidden primary servers (master nodes) will be used in two different geographic locations. All other anycast and unicast nodes will query the secondary master node for zone file updates and update their records accordingly. Several checks will ensure the integrity of the distributed zone file before it is uploaded to the master node. Zone transfers will use the AXFR⁄IXFR zone file transfer method after successful verification of the newly generated zone. The distribution of new zone files will be continuously checked with each of the client nodes.





C. Dissemination of Contact or Other Information Concerning Domain Name Registration



A port 43 RDDS (WHOIS) server (RFC 3912) will be available for legitimate WHOIS lookups. The service will be load balanced on a cluster system updated in near real time. Query limitations on a per IP and subnet basis will apply to prevent system abuse. IP addresses stated in the ICANN RADAR section will be entitled to an increased query limit to facilitate inter-registrar transfers. A website WHOIS will be available on the registryʹs website to facilitate legitimate WHOIS queries using a normal browser. All services will be provided in full compliance with the ICANN requirements and applicable law. Additional details will be described as part of the answer to question 26 (RDDS).



In order to prevent system abuse of the website whois, a Completely Automated Public Turing test to tell Computers and Humans Apart (CAPTCHA) will be used. Each IP address will be entitled to up to six lookups per minute and up to 360 lookups per hour. Each subnet will be entitled to 12 lookups per minute and up to 720 lookups per hour.



IP Addresses listed in the ICANN RADAR section will be entitled to 20 lookups per minute and up to 1,200 lookups per hour. For clients using Ipv6, appropriate limitations will be in place to prevent data mining and abusive WHOIS queries.



Information used for WHOIS lookups will be distributed to the WHOIS server cluster using default SQL replication mechanisms. A dedicated read-only database (load balanced) will be used to store all relevant data at the location of the WHOIS server. To prevent any unauthorized access to the database all external communications to the database are blocked.

The WHOIS output will contain information such as domain names and contacts associated with the domain name registration, dates such as registration date and expiration date, status of a domain name, and host objects.



Example Request: Query for domain “example.string” (please refer to Q26 section 8 for additional information concerning the WHOIS output)

Example Response:

Domain Name: EXAMPLE.STRING

Domain ID: 213232132-TLD

WHOIS Server: WHOIS.example.string

Referral URL: http:⁄⁄www.example.string

Updated Date: 2011-07-22T01:44:02Z

Creation Date: 2011-06-01T23:45:33Z

Registry Expiry Date: 2012-06-01T23:59:59Z

Sponsoring Registrar: EXAMPLE REGISTRAR

Sponsoring Registrar IANA ID: 1234567890

Domain Status: clientTransferProhibited

Registrant ID: 123456-STR

Registrant Name: EXAMPLE REGISTRANT

Registrant Organization: EXAMPLE ORGANIZATION

Registrant Street: 123 EXAMPLE STREET

Registrant City: SOMEWHERE

Registrant State⁄Province: AP

Registrant Postal Code: 12345

Registrant Country: EX

Registrant Phone: +1.5555522222

Registrant Fax: +1.55555544444

Registrant Email: EMAIL@EXAMPLE.STRING

Admin ID: 392839283-STR

Admin Name: EXAMPLE REGISTRANT ADMINISTRATIVE

Admin Organization: EXAMPLE REGISTRANT ORGANIZATION

Admin Street: 123 EXAMPLE STREET

Admin City: SOMEWHERE

Admin State⁄Province: AP

Admin Postal Code: 12345

Admin Country: EX

Admin Phone: +1.5555551212

Admin Phone Ext: 1234

Admin Fax: +1.5555551213

Admin Fax Ext:

Admin Email: EMAIL@EXAMPLE.STRING

Tech ID: 392811183-STR

Tech Name: EXAMPLE REGISTRAR TECHNICAL

Tech Organization: EXAMPLE REGISTRAR LLC

Tech Street: 123 EXAMPLE STREET

Tech City: SOMEWHERE

Tech State⁄Province: AP

Tech Postal Code: 12345

Tech Country: EX

Tech Phone: +1.1235551234

Tech Phone Ext: 1234

Tech Fax: +1.5555551213

Tech Fax Ext: 93

Tech Email: EMAIL@EXAMPLE.STRING

Billing ID: 112811183-STR

Billing Name: EXAMPLE REGISTRAR BILLING

Billing Organization: EXAMPLE REGISTRAR LLC

Billing Street: 123 EXAMPLE STREET

Billing City: SOMEWHERE

Billing State⁄Province: AP

Billing Postal Code: 12345

Billing Country: EX

Billing Phone: +1.1235551234

Billing Phone Ext: 1234

Billing Fax: +1.5555551213

Billing Fax Ext: 93

Billing Email: EMAIL@EXAMPLE.STRING

Name Server: NS01.EXAMPLEREGISTRAR.STRING

Name Server: NS02.EXAMPLEREGISTRAR.STRING

DNSSEC: signedDelegation

DNSSEC: unsigned0





D. Internationalized Domain Names (IDNs)



The applicant will not offer IDNs.





E. DNS Security Extensions (DNSSEC)



DNS Servers will provide DNSSEC capability according to RFCs 5910, 4641, 4034 and all successors and updates thereto. EPP DNSSEC specifications will be implemented according to RFC 4310. Zones will be signed on the signing server and distributed to the hidden master nameservers which will then distribute them to the secondary servers. A full detailed description of DNS and DNSSEC related topics can be found in answers to question 43, which are incorporated here by reference.





F. Additional Proposed Registry Services



F.1 Bulk Zonefile Access



Clients with a legitimate interest in accessing the registry zone file will be entitled to access this file once a day. For this purpose a dedicated SFTP access will be granted and the zone file will be uploaded once a day. This service will be subject to an additional agreement fully executed between the interested party and the registry.



F.2 Tiered Registration



As this is an open TLD, a Sunrise Period, Landrush and General Availability Period are all planned. The Sunrise will occur as follows:



Sunrise Period: (3-6 Month Period)

• 4 stages of Sunrise:

 1. Submission of application with full Trademark data.

 2. Validation of applicant’s rights to domain by neutral party (WIPO)

 3. Auction competing application for same domain at Pool.com

 4. Award of domain name

• Allows for documented Trademark holders an opportunity to apply for 2nd-level domains. 

• $200 Non-refundable Application Fee. 

• Not first come first served...Competing applicants will be determined by closed auction administered by Pool.com at end of 3-6 Month period

• Non-competing applicants will be awarded domain at end of Sunrise period and will pay registration fees for the domain.

• Minimum 2-year registration, maximum 10 years

• IDN registrations not allowed.





Landrush, Open to General Public: (3-6 Month Period)

• Applications open for the general public

• $27 Non-refundable Application Fee.

• Not first come first served, applications are collected for the duration of Landrush

• At end of the 3 month phase, domains with single applications are awarded immediately with 1 year term

• Domains with multiple applications for same name will go to closed auction administered by Pool.com 1-2 months following close of Landrush period.

• Minimum 2-year registration, maximum 10 years





General Availability: (commences after completion of Landrush)

• Applications on a first-come, first-served basis

• Standard pricing for all registrations

• Standard policies 

• Minimum 1-year registration, maximum 10 years









G. List of Attachments



- Q23_Figure1.pdf - List of supported EPP commands ⁄ EPP object relationship

- Q23_Figure2.pdf - List of Codes throughout the Application







〉〉 SPECIAL NOTE: IN OUR RESPONSE TO QUESTIONS 25, 29, 32, 36, 38, 42, AND 43 WE ARE DEMONSTRATING EXAMPLES OF CODE TO ILLUSTRATE HOW OUR REGISTRY SERVICES WORK. OUR CODE CONTAINS THE BRACKETS ʺ〈ʺ AND ʺ〉ʺ. WHEN GENERATING HTML PREVIEW VERSIONS OF AN APPLICATION VIA THE TAS, WE HAVE DETECTED THAT BROWSERS, OR PROGRAMS SUCH AS MICROSOFT WORD AND ADOBE READER, DO NOT SHOW THESE CODES (THEY ARE, HOWEVER, SHOWN IF YOU OPEN THE FILE WITH NOTEPAD OR SIMILAR TEXT EDITORS). HENCE, WE HAVE DECIDED TO ATTACH CODE FOR QUESTIONS 25, 29, 32, 36, 38, 42, AND 43 IN ORDER FOR EVALUATORS TO HAVE AN EASY ACCESS TO ALL THE CODE EXAMPLES.

The KSregistry (KSR) system is a domain registry system capable of registering domain names managed by multiple registrars. In addition to the SRS system, KSR provides RFC conforming interfaces for EPP, RDDS (WHOIS), DNS, and DNSSEC. KSR is capable of running any IDN string as well as IPv6. KSR uses recognized and proven technologies such as MySQL database software and BIND DNS servers, as well as industry standard backup and monitoring solutions.

KSR uses a thick registry model wherein all contact details are stored in a central location by the registry. All services are set up as a fully redundant solution (n+1). Additionally, there are two geographically separate data centers (Tier 3, all components are available at least n+1), one active and one which is designed to function as a warm-standby solution to ensure a maximum of data security and business continuity. All SRS and DNS related information is replicated in real-time between the data centers. 

KSRʹs modular design allows for quick and easy installation or removal of system components at any time. This ensures KSRʹs ability to react to any business needs or system loads in an appropriate manner at all times. 

KSR is managed by trained personnel only. Its operations follow well-defined business and security processes which are based on the ITILv3 standard and in accordance with ISO 27001. 

KSR has a NOC and support team available at two different locations (St. Ingbert, Germany and Munich, Germany) which allows 24 x 7 x 365 monitoring of all systems and provides customers with an easy way to reach KSR personnel regarding any issue they may have. 

The SRS is protected against unauthorized access. Data integrity is ensured by both physical and software security and protection mechanisms.
All these measures together are the basis for running a robust and reliable SRS and are in compliance with Specification 6 and 10.


A. Detailed KSR Description

The following section refers to attachment Q24_Figure1.pdf.

Figure 1 contains a high level functional overview of all KSR components which are described below. All described services and functions are in compliance with Specification 6 and 10 based on their design and setup.

For all of the services listed below the following applies:

The application servers (e.g. EPP, DNS, and RDDS) are set up as a cluster to guarantee a high-availability solution. The sizing of the servers and the databases are calculated to meet the needs of each business case. Additionally, the system is set up to be scalable so that an increase of domains or registrars can be easily handled by installing additional hardware as needed. 


A.1 Services Integrated into KSR

Domain Name System (DNS)

The Domain Name System (DNS) is a hierarchical distributed naming system for computers, services, and any other resource connected to the Internet or a private network. The registry will be set up with a mix of anycast and unicast name servers. This service is provided by an external provider called PCH.NET which has over 10 years of experience in this area. This partnership with PCH.NET ensures a 100% guaranteed uptime of the service and worldwide DNS coverage. DNS and zone file creation is performed periodically (every 15 minutes), uploaded to the primary hidden master name server, and spread to the anycast clouds (PCH.NET) within 180 seconds. The communication between the primary hidden master name server and the DNS cloud is facilitated by zone transfer {AXFR (Asynchronous Full Transfer Zone)⁄IXFR (Incremental Zone Transfer)} to the worldwide anycast net.

DNS Security Extensions (DNSSEC)

DNSSEC adds security to the Domain Name System. DNSSEC helps in preventing cache poisoning or man in the middle attacks. This helps to protect usersʹ personal and⁄or financial information from being compromised on the Internet. This additional security helps in protecting end users and the reputation of brands.

Extensible Provisioning Protocol (EPP) 

The EPP gives registrars the ability to fully automate the management of their domain names. KSR uses EPP as a protocol for registering and managing domain names in a very standardized way. KSR is in compliance with RFCs 3735 and 5730-5734 as well as with Specifications 6 and 10 of the registry agreement. EPP compliance is ensured by technical validation (XML validator) and through the change management process which includes a quality assurance program.

Web Interface

The web interface provides the registrars the ability to manage their domain names through a comfortable user interface and grants access to reports and accounting information.

RDDS (WHOIS)

The Whois is a data directory service which grants public free access regarding domain information. The RDDS (WHOIS) service is provided as a web-based directory service via port 43 in accordance with RFC 3912. This service provides different information depending on the request. The data this will offer includes, but is not limited to:

- Domain name
- Address information on the registrant, administration-, technical-, and billing contacts.
- IP addresses of the name servers
- The identity of the registrar
- Domain creation and expiration dates

There will be a searchable Whois accessible via the web interface. This service will only be available to registrars in respect to confidential data. In order to prevent any abuse of the provided data, additional limitations on the service include IP-based limitations and masking of critical customer data.

SFTP ⁄ SCP Access to the File Store 

The SFTP area grants access to all reports which are available in the KSR. Communication is only possible over an encrypted connection, such as with SFTP or SSH, protecting registrars from unauthorized access to their data. In addition to command line access, KSR offers access through the https-based web interface.

Escrow

KSR generates two types of deposits: full and differential. The escrow data provides all SRS-related information to an escrow agent as required for running a registry in compliance with the approved registry services.

The escrow file is generated in compliance with the format specifications as described in Specification 2. The file will be transferred (SFTP) to the escrow agent as a compressed (ZIP RFC 4880) and encrypted file.

KSR is working with the escrow agent NCC Group.

The required data for generating the deposits are always stored in both data centers at all times. This enables the KSR to generate these files even in disaster scenarios.

Reports

The KSR system generates all ICANN reports on a monthly, weekly, or daily basis. In addition to the ICANN related reports, reports for the registrars are created which contain invoicing and domain portfolio information:

- Per-registrar transactions report (Specification 3)
- Registry functions activity report (Specification 3)
- Up-to-date registration data (escrow format as described in Specification 2)
- Thick registration data in case of a registrar failure, de-accreditation, court order, etc. (escrow format as described in Specification 2)
- Technical and operational reports describing performance specifications (Specification 10)
- Registrar based domain and contact reports
- Monthly invoicing reports
- Name server reports
- Data escrow (full and differential as required in Specification 2)


B. Network Diagram

See attached fig. 2 in Q32_Figure1.pdf for the detailed network overview.

B.1 Hardware (Number of Servers)

Network Components:

- Two (2) or more firewalls (Vyatta) (load balanced) Vyatta 6.3
- Two (2) or more network switches frontend (Juniper), EX2200, EX4200
- Two (2) or more network switches transfer (Juniper), EX2200, EX4200
- Two (2) or more network switches backnet (Juniper), EX2200, EX4200
- Two (2) or more load balancer (Keepalived) and SUSE Linux Enterprise High Availability Extension

B.2 Server Components

Typical components for all servers:

Server: IBM compatible Linux server
Processor: INTEL 64bit multicore CPU
Memory: Up to 64 GB ECC DDR2 RAM modules
Disk: Internal RAID 5 for operating system and software, additional intern RAID 5 for data, iSCSI support 
Network Adapter: Average 4 100⁄1000 mbit network interface

- Two (2) or more webservers for the web interface (load balanced)
- Two (2) or more EPP server (load balanced)
- Two (2) or more RDDS (WHOIS) servers (load balanced)
- Two (2) or more SFTP servers (load balanced)
- Two (2) or more tools servers (cron, batch) (n+1 redundant with failover)
- Two (2) or more database servers (load balanced)
- Two (2) or more storage servers (load balanced)
- One (1) BIND hidden master
- One (1) Generator
- One (1) Signer ⁄ HSM

Full detailed hardware description can be found in attached fig. Q32_Figure3.pdf.

The listed hardware satisfies the SLA requirements as described in Specification 10.


C. Description of Inter-Connectivity with Other Registry Systems

The modular design of the KSR solution has the advantage of being very flexible and highly scalable. The SRS, EPP, and RDDS (WHOIS) services communicate through an internal API which protects the system from direct database access while providing real-time information to all SRS related services. 

The DNS and DNSSEC information is provided every 15 minutes to the primary hidden master name server and then spread to the anycast⁄unicast cloud within 180 seconds. The communication between the primary hidden master name server and the DNS cloud is facilitated by AXFR⁄IXFR.

The escrow data (full and differential deposit) is generated, zipped, and encrypted once a day and sent to the escrow agent in compliance with Specification 2.

The complete SRS database information is shared between both data centers (primary site, warm-standby). This is achieved by real-time data synchronization. In addition, the SRS program code and binaries are also shared between both data centers at any given time. Only one of the two data centers is actually running in production mode at a time, while the other one is always on standby but not active until needed.

The two data centers are connected through a VPN connection which is used for synchronization of the services described above. In the unlikely event of the complete loss of one data center, the KSR can be switched from one site to another within minutes and with no data loss. The DNS⁄DNSSEC is secure and highly available due to its worldwide setup.

The systemʹs complete inter-connectivity is integrated into the system monitoring and ensures the readiness of the failover locations at any time. In addition to monitoring, a controlled failover testing from the production data center to the warm-standby data center is performed once a year.

These measures ensure compliance with registry continuity in Specification 6.


D. Frequency of Synchronization Between Servers

The frequency of the server synchronization depends on the service being synchronized. Some services are synchronized in real-time while others are synchronized at fixed periods.

The database is set up as a cluster solution (with n+1 redundancy) in each data center. Since only one data center is running in production mode at a time, the other data center is connected to the production database by real-time replication. This guarantees a complete set of SRS⁄DNS information at all sites.

As the DNS⁄DNSSEC is generated from the database information, KSR always has the complete zone file information available at all data center sites. The zone file itself is generated every four minutes and uploaded to the primary hidden master name server. From there, the zone file is distributed to 95% of all DNS servers worldwide within 180 seconds.

The RDDS (WHOIS) is retrieved from the database in real-time and is available at both data center locations at all times. 

Like RDDS, the EPP interface retrieves and submits its information in real-time and is also connected to the database.

In addition to storing the complete registry-related data in the database, KSR also distributes the complete SRS source and binary codes to both data center locations at all times. This is achieved by a central repository which is synchronized at every location.

The combination of synchronization of source and binaries of each SRS-related service and the centralized database allows the KSR solution to switch from one data center to the other within 30 minutes. During a failover, the DNS service remains unaffected by the switch.

The data escrow files are generated in accordance with the registry Specification 2.

- Full Deposit: Each Sunday by 23:59 UTC
- Differential Deposit: Monday through Saturday by 23:59 UTC

These measures ensure the compliance with registry continuity in Specification 6.


E. Synchronization Scheme (warm-standby)

The setup of the system includes two geographically separate data centers configured as a warm-standby system (one active, the other in warm-standby, see fig. 1 in attachment Q24_Figure1.pdf). If the production data center is hit by a disaster which results in the complete loss of the data center, the warm-standby system can be brought online within minutes to completely take over.

The complete SRS data (domains, contacts, DNS, etc.) is always available at both data centers at any given time, safeguarding the SRS data from being lost. This is achieved by the setup of the SRS databases as clusters and distributed over both data centers. The cluster is synchronized in real-time.

Using PCH.NET as a partner for DNS⁄DNSSEC, KSR always has ten different locations available worldwide.

These measurements ensure the compliance with Specification 6.


F. Project Resources and Roles

Key-Systems GmbH has gathered experience in various roles in the domain business for more than ten years and has access to extensive knowledge in the domain industry. This deep industry knowledge and experience has been transferred to KSregistry GmbH, the technical provider of the KSregistry system (KSR), and is evident in many trusted persons serving in different roles throughout the company.

All employees, contractors, and consultants that have access to or control of the KSregistry system are trusted persons.

Each role is staffed with multiple human resources for backup and capacity purposes.

Prior to commencement of employment in a trusted role, KSregistry GmbH performs the following background checks on a prospective candidate:

- Criminal records bureau check
- Verification of previous employment
- Check of professional references

F.1 Role Descriptions

All of the following roles have a backup available in each separate location in Germany (St. Ingbert and Munich).

Security Role

The Chief Security Officer (CSO) is dedicated to the security role. The CSO is the person responsible for the security of a companyʹs communications and other business systems. The CSO is involved in both the business (including people) and technical aspects of security. CSO responsibilities include training of personnel regarding security awareness, developing secure business and communication practices, purchasing security products, and ensuring that security practices are followed. The CSO has a stand-in backup available.

Designated Engineering Role

The designated engineering role includes the software developers of the entire SRS and all related interfaces such as EPP, RDDS (WHOIS), escrow, etc. All engineers are also integrated into 3rd level support of the SRS and related interfaces. 

System Administration Role

The system administrators take care of the infrastructure of the SRS system. This includes the entire network, hardware and system installations as well as the cluster setup of the databases and all data backups which are made. 

The NOC team is composed of system administrators. This team is responsible for clean, well-documented, and reliable data center operations. All access to the data center is restricted to members of the NOC team and persons accompanied by members of the NOC team only. There is an emergency team of at least two people at all times. This team is reachable 24 hours a day, 365 days a year.

Security Administrator

Members of this role define HSM domains⁄tokens and administer HSM users and the overall HSM policy. Security administrators guarantee a working HSM domain for DNSSEC signing.

Support Role

The support role covers the first and second levels of support (Service Desk). All registrars and SRS customers may contact the support role as the first line of contact. Requests can be submitted via email or phone and can be placed 24 x 7. The support role is located in two geographically separate locations, one in Germany and the other in Mexico. If problems are traced back to an erroneous system behavior as the cause, all available data are gathered and a problem report is generated and handed over to the change management team. 

DNS⁄DNSSEC Role

The DNSSEC administrator role is staffed with at least two persons. Members of this role are responsible for the overall Open DNSSEC setup and maintenance. This includes the connection to the HSM cluster as well as compliance to the HSM policy for the DNSSEC domain. 

Quality Management Role

The Quality Management (QM) role takes care of each software component which is integrated into the SRS system and related interfaces. After a development cycle is finished, the QM performs full integration testing of the entire system. The testing is performed entirely on a separate testing system (OT&E) which mirrors the production system. The QM ensures the production readiness of each and every software upgrade, including emergency software patches. No software or system change will be promoted to production without the explicit approval of the QM. 

Change Management ⁄ Project Management Role (CM⁄PM)

The CM and PM role ensures that all steps in the development and system change processes are assessed, approved, implemented, and reviewed in a controlled manner. They also chair the Change Advisory Board (CAB) and the Emergency Change Advisory Board (ECAB). These boards are comprised of selected people from other functions within the company. The CM⁄PM reviews and closes requests for change and reports to management. 

F.2 Project Resources

The table in (fig. 2 in attachment Q24_Figure2.pdf) shows how the roles described above are planned for the SRS system. The calculations differ between the project phase and the years after the operational start. The project phase requires more resources as there is much planning, management, and development required. All human resources are only engaged in the domain industry and are experts in their area.

However, as the resources are shared and are not dedicated exclusively to one SRS project, the columns contain the number of resources available for this role and the percentage of all people working for this specific TLD. This percentage is the guaranteed time the resources for this SRS project assure.


G. List of Attachments

- Q24_Figure1.pdf
- Q24_Figure2.pdf
- Q32_Figure1.pdf
- Q32_Figure3.pdf

Key Systems GmbH first gained experience working on the client side of the Extensible Provisioning Protocol(EPP) with the .Info registry (launched in 2001). This deep industry knowledge and experience has been transferred to KSregistry GmbH. Launched against early Internet Drafts, a great deal was learned in the first years leading to important protocol revisions. Some of these included changes to prevent the formation of orphaned glue records in an EPP registry and the ability to affect mass internal host updates with a single request. Most importantly, EPP brought the required functionality of populating registration contact data in the registry, allowing the subsequent implementation of a centralized or “thick” Whois service.

EPP was largely motivated by the growth in the number of accredited registrars that occurred beginning in 1999. Technologists working on EPP believed that the emergence of many new TLD registries was imminent and sought to ease the client-to-server implementation work that would flood the registry⁄registrar community if a standardized protocol was not developed through which to interact with domain registries. The effort was largely successful, although there has been extensive distinct diversion among overlapping EPP extensions between different registries over the years.

These many EPP extension difference first led KSregistry (KSR) to write a EPP proxy server in May 2009. The KSR RFC compliant EPP server implementation has been serving over 300 large and small registrars, passing up to 7000 EPP transactions per minute to over 280 registries. Some of these well known registries include: com, net, org, biz, info. 

KSR EPP Server Interface

The EPP server is set up as a cluster to guarantee a high availability solution. The sizing of the servers and databases are calculated to meet the needs of each business case. The system is set up in a scalable way so that an increase of domains or registrars can be handled by adding hardware as needed. The KSR EPP API is offered over TCP on port 700 with mandatory SSL session enforcement for registrars for automated interaction with username and password. To increase security, a registrar IP address limitation is in place for the EPP servers (both production and OT&E). This API also supports a secure web-based (over https) EPP client for registrarsʹ manual use only. The web-based graphical interface interacts with the EPP server through standard EPP XML queries. The EPP XML responses are in turn displayed in the web interface. This allows the registrars to perform registry transactions through the web-based interface.

The KSR EPP Interface is capable of supporting up to 5000 read transactions per minute and 2000 write transactions (concurrently). It is provisioned in a highly redundant,duplicative environment using stateless, multiple application instances. Please see Q. 31 for details on expected transaction volumes for DOT DESI registry.


A. RFC Relevance to KSregistry (KSR)

A.1 RFC 5730

This RFC is a base protocol document for EPP. EPP is an XML-text object based client-server protocol, atomic in its transactions, and developed to support multiple transports and lower level security protocols. There are no partial failures; all commands either succeed or fail definitively. Object-to-object associations are standard with limited application of parent-child relationships where delegate relationships are necessary for affected functionality, such as internal host data and its relationship to domain objects. The KSR registry fully implements the service discovery, commands, responses, and the extension framework described. 

A.2 RFC 5731

This RFC explains the mapping of the primary EPP registry object, the domain object. It reviews associated attributes and states of the domain object as well as child object relationships (hosts). It also details associations with other contact objects. KSR complies with the full XML examples and descriptions and applies flexibility where permitted. For example, 5731 allows operators to implement the info command with different responses for a “sponsoring registrar” and a “non-sponsoring registrar” in regards to most domain object attributes. KSR implements this as a base protocol document for EPP.

A.3 RFC 5732

KSR implements this as a base protocol document for EPP. KSR notes this RFC describes the mapping of relationships to host objects, which are by definition subordinate to the superordinate domain name object. Host objects that are defined as internal or in the namespace of the registry must be related to a superordinate domain object to be created. Internal hosts, as full child objects, face restrictions associated with the management of their superordinate domain object. External hosts are hosts belonging to another domain namespace and as such are not subordinate in the present namespace. Internal hosts can have a glue or an A record associated with them, external hosts refer to another namespace or zone for the associated A record. 

A.4 RFC 5733

Another base RFC implemented in the KSR server, this RFC describes the contact object mappings in EPP. Contact objects are used to contain related data surrounding the standardized contacts types in TLD registries including attributes such as contact type, country, telephone numbers, email addresses, etc. As a standalone object, a contact object can be created and associated with no domain objects or with any number of domain objects available in the registry. This is used commonly by registrars to update common contact information associated across large numbers of domains in a single transaction. Like the domain object, it can be secured with a passphrase or “authinfo” code. Contact object data represents the definitive data source for authoritative RDDS (WHOIS) in new TLDs. 

A.5 RFC 5734

KSR will implement this RFC as the preferred industry transport and in compliance with ICANNʹs requirements. Early implementations of EPP were considered over BEEP. This RFC describes a standard implementation of TCP incorporating TLS. As mentioned earlier, EPP can be implemented over multiple transports. The transport of choice for the EPP registry community has been TCP. Implementers are encouraged to take precautions against denial of service attacks through the use of standard technologies such as firewall and border router filters. IANA awarded port 700 as the dedicated port for the server side. There is no dedicated port assignment for the client side. 

A.6 RFC 5735

KSR will implement this RFC as applicable to any extensions it utilizes as this RFC provides specific and detailed guidance on EPP extensions. An important principle in creating extensions to, as opposed to modifying, the EPP protocol was to fully preserve the integrity of the existing protocol schema. Additionally, a valid extension itself should be extensible. Another important requirement in the RFC is to include announcements of all available extensions in the EPP server greeting element before establishing an interactive client session. 

A.7 RFC 3915

KSR will support this extension since DOT DESI implements the grace period implementation known as the Redemption Grace Period or “RGP”. When RGP is in use, domains are deleted into the RGP where Registrars may request a restoration of the domain. This is a billable event and requires a three-step process: placement of the domain into a pending restore state, submission of a restore report explaining why the domain is being restored, and finally the restoration of the domain. The RFC extends the domain update command, adds related domain statuses, such as ʺredemptionPeriodʺ and ʺpendingRestore,ʺ and extends the responses of domain info and other details. The RFC provides a lifecycle description of the RGP and defines the format and content for client to server submission of the associated restore reports. 

A.8 RFC 5910

KSR will support DNSSEC from the initiation of DOT DESI and therefore will also support this extension from initiation of the registration process. DNSSEC is a mechanism for cryptographically verifying that each delegate zone in the DNS hierarchy has been referred to or is referring to its genuine parent or child zone respectively. Since TLD zone files are generated from authoritative registry data, this extension specifically provides the ability to add elements to the domain-create and domain-update functions and to the domain-info responses, allowing registrars to submit associated delegated signer information of the child zone indicating it is digitally signed and that the parent zone recognizes the indicated key as a valid zone key for the child zone.

 
B. Extensions used by KSR and Related Internet Drafts

B.1 Draft-tan-epp-launchphase-01 (Launch Phase Mapping for the EPP)

KSR intends to use this EPP internet draft to facilitate Sunrise phases during the initiation of DOT DESI registry. This internet draft proposes an extension mechanism that supports the organization of Sunrise related domain applications. The extension considers the following elements:

〈lp:phase〉
This element allows a Sunrise application submission to be marked by the EPP client as a particular Sunrise application type, in respect to running different types of Sunrise applications during a concurrent submission period. KSR will use this to identify Sunrise A and Sunrise B application types. 

〈lp:status〉
This element allows the EPP server to assign one of a number of statuses indicating what stage the Sunrise application is in. These statuses can be expressed through the domaininfo command response and, optionally, through the RDDS service if applicable. The statuses listed below can be assigned uniquely or in combinations where appropriate:

〈pvrc〉
The Pre-Validation Result Code, an opaque string issued by a third-party validation agent

〈claimIssuer〉
contains the ID of a contact object (as described in RFC 5733 [RFC5733]) identifying the contact information of the authority which issued the right (for example, a trade mark office or company registration bureau)

〈claimName〉
identifying the text string in which the applicant is claiming a prior right

〈claimNumber〉
the registration number of the right (ie trademark number or company registration number)

〈claimType〉
indicates the type of claim being made (eg trademark, symbol, combined mark, company name)

〈claimEntitlement〉
indicates the applicantʹs entitlement to the claim (ie, owner or licensee)

〈claimRegDate〉
the date of registration of the claim 

〈claimExDate〉
the date of expiration of the claim

〈claimCountry〉
indicates the country in which the claim is valid

〈claimRegion〉
indicates the name of a city, state, province or other geographic region in which the claim is valid. This may be a two-character code from [WIPO.ST3] 

The complete draft is described in attachment Q25_Figure3.pdf.


C. KSR EPP Server 

C.1 KSR EPP Command and Elements and Overview

Attachment Q25_Figure1.pdf contains the table with the supported EPP commands and the EPP object relationship.
Note: There are at least 2 name servers required for an active domain. Otherwise, the domain will be in the inactive status.

C.2 EPP Compliance Assurance:

KSR is committed to ensuring and maintaining compliance with the aforementioned EPP RFCs and, to this end, employs numerous mechanisms as listed below:

Quality Assurance Program

KSR runs a robust Quality Assurance (QA) program with multiple dedicated QA engineers. KSR has developed complete unit, regression, and stress based automated test suites for positive and negative use case testing. The test suites are self-developed and optimized for the relevant use cases. KSR reviews its use cases regularly with the entire development and registry operations teams for consideration as additional test cases. Additionally, KSR hosts periodic events where we bring together registrar engineers to discuss these use cases and seek new cornerstone cases that registrars may be able to offer from their experiences and points of view. 
KSR provides its QA team with a robust production grade testing environment with client load emulation capabilities that far exceed the load (through rate limiting) permitted on the KSR production environment. 

OT&E

All new candidate EPP application versions will be released to a pre-candidate Registrar Operational and Testing Environment (OT&E) before promotion. Minor revisions, defined as new optional functionality, will have a minimum 30 day period in OT&E. Major changes, defined as requiring changes on the registrar client side, will have a minimum 90 day period in OT&E.

Inline XML Validator

The KSR EPP application uses the following XML validator in its server implementation. (Perl library XML::LibXML) XML errors or malformed XML will fail EPP transactions with the client atomically and the server will detail the failure state in the returned error message as well as the incorrect XML.

Third Party Validation

KSR is partnered with another Registry Service Provider (RSP), Internetwire, and has a bilateral agreement for each party to independently test and verify each otherʹs EPP RFC compliance. KSR may also opt to engage other third parties for compliance testing.


D. Resources and Roles

D.1 Resources

Key-Systems GmbH has gathered experience in various roles in the domain business for more than ten years and has access to extensive knowledge in the domain industry. This deep industry knowledge and experience has been transferred to KSregistry GmbH, the technical provider of the KSregistry system (KSR), and is evident in many trusted persons serving in different roles throughout the company.

All employees, contractors, and consultants that have access to or control of the KSregistry system are trusted persons.

Each role is staffed with multiple human resources for backup and capacity purposes.

Prior to commencement of employment in a trusted role, KSregistry GmbH performs the following background checks on a prospective candidate:

- Criminal records bureau check
- Verification of previous employment
- Check of professional references

D.2 Roles

Designated Engineering Role

The designated engineering role includes the software developers of the entire SRS and all related interfaces (EPP, RDDS (Whois), escrow, etc.). All engineers are also integrated into 3rd level support of the SRS and related interfaces. The members of the engineering role are located in two geographically separate locations in Germany (St. Ingbert and Munich).

System Administration Role

The system administrators take care of the infrastructure of the SRS system. This includes the entire network, hardware, and system installations, as well as the cluster setup of the databases and all data backups which are made. Further, the installation of the hardware security module is performed by this role. This includes network setup, operating system installation, and HSM activation.

Support Role

The support role covers the first and second levels of support (service desk). All registrars and SRS customers may contact the support role as the first line of contact. Requests can be submitted via email or phone and can be placed 24 x 7. The support role is located in two geographically separate locations: one in Germany and the other in Mexico.
The first level of support receives all incoming requests from registrars and SRS customers and establishes the first contact. All problems that arise due to improper usage of the system or a misunderstanding of procedures will be resolved by the first level support. In addition, the first level points the customers to the online wiki and knowledge bases to prevent such requests in the future.

The second level support takes care of all problems which could not be solved by the first level. If problems are traced back to an erroneous system behavior as the cause, all available data are gathered and a problem report is generated and handed over to the change management team.

Quality Management Role

The Quality Management (QM) role takes care of each software component which is integrated into the SRS system and related interfaces. After a development cycle is finished, the QM performs full integration testing of the entire system. The testing is performed on a separate testing system (OT&E) which mirrors the production system. The QM ensures production readiness of each and every software upgrade, including emergency software patches. No software or system change will be promoted to production without the explicit approval of the QM.

Change Management (CM) ⁄ Project Management (PM)

The CM and PM role ensures that all steps in the development and system change processes are assessed, approved, implemented and reviewed in a controlled manner. This role filters requests so that only useful, valid and approved changes are implemented. They are also responsible for managing development efforts and changes to ensure that the changes are applied in accordance with predefined processes. They also chair the Change Advisory Board (CAB) and the Emergency Change Advisory Board (ECAB). These boards are comprised of selected people from other functions within the company. The project and change management role reviews and closes requests for change and reports to management. 


The table in (fig. 2 in attachment Q25_Figure2.pdf) shows how the roles described above are planned for the SRS system. The calculations differ between the project phase and the years after the operational start. The project phase requires more resources as there is much planning, management, and development required. All human resources are only engaged in the domain industry and are experts in their area.

However, as the resources are shared and are not dedicated exclusively to one SRS project, the columns contain the number of resources available for this role and the percentage of all people working for this specific TLD. This percentage is the guaranteed time the resources for this SRS project assure.


E. List of Attachments

- Q25_Figure1.pdf
- Q25_Figure2.pdf
- Q25_Figure3.pdf

The KSregistry (KSR) provides both web and command line (port 43) publicly accessible RDDS (WHOIS) which offers a central location for all authoritative TLD related information when registering or modifying a domain name. The RDDS (WHOIS) information is reflected in real-time to the public. 

The RDDS (WHOIS) service is a public service for interested stakeholders such as registries, registrars, individuals, law enforcement, and trademark owners that require detailed information on one of the following categories of information:

- Domain name including status, creation, and expiration date
- Information on domain registrant, administration, technical and billing contact
- Name server and IP address
- Registrar information

This information will provide the public with the ability to get in touch with the domain holder for any reason that requires action to be taken (e.g. trademark issues, violations with registry policies, offensive content, etc.). In addition to the search capabilities, the service has methods of limiting abuse.

The RDDS (WHOIS) service is in compliance with RFC 3912 and Specifications 4 and 6 of the registry agreement and global best practices.

KSR is already running a RDDS (WHOIS) server in full compliance with RFC 3912. The service has been in place for over 11 years without any major incidents. Experienced personnel are on board for operating and maintaining the RDDS (WHOIS) service.


A. Searchable RDDS (WHOIS)


The KSR RDDS (WHOIS) includes a web-based searchable service for registrars only which reveals more detailed information, satisfying the requirements for a score of 2.

Fig. 2 in attachment Q26_Figure2.pdf shows the complete list of all possible queries which can be made.

For security reasons and legal restrictions some search capabilities are only available in the registrar web-based RDDS (WHOIS). This includes partial match capabilities regarding the registrantʹs postal address.


B. Abuse Protections

There are technical restrictions in place for all RDDS (WHOIS) types to prevent the abuse of the data from such methods as data mining or DDOS (Distributed Denial of Service). Following best practices, KSR protects the web-based whois service with CAPTCHA (Completely Automated Public Turing test to tell Computers and Humans Apart) and port 43 whois service with IP limitations. 

In addition to these technical restrictions, the registry policy disallows data mining or comparable approaches of collecting data.


C. Technical Overview

The RDDS (WHOIS) service is set up as a two server cluster with a redundant load balancer in front of it to ensure a highly available solution (n+1 redundancy). 

The server software is running on a SuSE Linux Enterprise Server and is configured to be scalable, allowing KSR to be extended by simply adding additional servers to the setup during regular operations.

The sizing of the servers and the databases are calculated to meet the needs of the individual business case and are able to handle a sustained and significant load. The available RDDS (WHOIS) servers are always active at one regional site and may be switched to another regional site within minutes as necessary. There are two different sites available for running the RDDS (WHOIS) service.

- Primary Site: St. Ingbert, Germany
- Secondary Site: Munich, Germany

All sites have a permanent highly secure VPN connection to the (current) primary site in order to synchronize the complete SRS, EPP, DNS⁄DNSSEC, escrow and RDDS (WHOIS) related database information. All network traffic between the VPN gateways will be encrypted using 1024 bit RSA keys. The complete availability of KSR information at all times allows for a safe failover from the primary site to the secondary or disaster site within minutes.

The RDDS (WHOIS) information data is stored in a MySQL database which is setup as an active⁄active database cluster. This cluster is permanently replicated to all other sites. The RDDS (WHOIS) data is also stored daily by the KSR backup system. The backups are also sent to the secondary site.

In addition to the performance aspect of the RDDS (WHOIS) service, the KSR detects abusive usage levels such as those that occur from excessive numbers of queries from one source. This is accomplished by checking the source IP of the request on the port 43 RDDS (WHOIS). The web-based RDDS (WHOIS) comes with an additional CAPTCHA mechanism in order to prevent abuse.

Further protections to the WHOIS service from incidents like DDOS (Distributed Denial Of Service) attacks are assured by an IDS (Intrusion Detection System) which provides KSR overall protection.

Daily generated escrow data files containing all RDDS (WHOIS) related data are stored at the NCC Group as the KSR escrow provider. 

The full RDDS (WHOIS) architecture is described in fig. 1 in attachment Figure Q26_Figure1.


D. Quality Measurements and Validation of Compliance with Specifications 4 and 10

KSR takes several measurements in order to ensure ongoing Service Level Agreement (SLA) checking, RFC compliance, and compliance with Specifications 4 and 10 of the registry agreement. For the following, KSR refers to the RDDS (WHOIS) as RDDS (Registration Data Directory Services) in order to describe the collective of RDDS (WHOIS) and web-based RDDS (WHOIS) services. 

In order to facilitate the registry performance specification (Specification 10), the following checks are performed on the RDDS (WHOIS) periodically:

- RDDS availability
- RDDS query RTT 
- Web-based RDDS query RTT 
- RDDS update time
- RDDS test 

All available RDDS (WHOIS) search patterns are randomly checked with a data parser compliant with RFC 3912 and Specification 4 in order to check if the data output satisfies the given requirements.

A non-registry partner also validates RFC 3912 compliance. KSR also performs backwards RFC compliance checks on the non-registry partner through its registry partnership with Internetwire. All software enhancements or corrections go through the change management process. This includes full regression testing with the complete SRS system. Provided that all quality tests and the change is approved by the Change Management Board (CMB), a change will be made in the OT&E system. Once the testing phase in the OT&E is done and no problems are found while testing with the registrars, the software change of the new version will be made in production.


E. System Capacity

KSR sizing calculations have been performed to assess the hardware resources necessary to support the expected volume of transactions from the business case for this TLD and are based on available statistics from the monthly ICANN registry reports of existing gTLDs like .Com, .Org, .Info and the ccTLD .Be. 

Taking into account that the KSR is setup and designed to host multiple strings, the maximum number of this specific string does not fully load the maximum capacity of the system.

KSR is capable of handling up to the following volumes as a maximum with the current capability of the hardware:
Max. RDDS (WHOIS) capacity of KSR: 200,000,000 queries⁄month

For DOT DESI the expected number of domain name registrations will be approximately 150,000 (this is a total of new domains added each year for a cumulative three years).
Yr 1 additions: 29,225
Yr 2 additions: 42,658
Yr 3 additions: 59,721
Total additions (Not Domains in Management due to churn) is approximately 131,000.

If the system reporting and alerts indicate that the current volumes of data or transactions is reaching 75% of the maximum capacity of the system, the system will be upgraded by adding additional servers to the setup. This can be done during regular operations without requiring any downtime.

KSR used the gathered statistics to derive blended base and peak transaction volume expectations per domain. Calculations of traffic presented below are derived strictly from peak transaction volumes in support of conservative estimates and the intent that a margin of error should result in over-provisioning registry services, versus under-provisioning. 

First Year:
RDDS up to 78 queries per domain per month

For a 30,000K domain name registry:
RDDS up to 2,340,000 queries per month

Note: benchmark calculations from values from public registry data are raised by 50% for RDDS in the first year in respect to related registry launch activities.

Second Year:

RDDS up to 52 queries per domain per month

For a 73,000K domain name registry:
RDDS up to 3,796,000 queries per month

Third Year:

RDDS up to 52 queries per domain per month

For a 131,000K domain name registry:
RDDS up to 6,812,000 queries per month

F. Hardware Specifications

The hardware specifications are based on the analysis from the system capacity numbers.

KSRʹs primary and secondary data center were chosen to fit a common architecture, providing the following benefits:

- at least TIER III certification
- n+1 redundancy on power supply, cooling network 
- at least one 1 Gbit uplink provider
- latest fire prevention system
- 10 Gbit internal network transfer for KSR systems 

The detailed hardware list is described in the table in fig. 3 in attachment Q26_Figure3.pdf.

RDDS plans are consistent with the technical, operational, and financial approach as described in the application


G. Roles and Resources

G.1 Resources

Key-Systems GmbH has gathered experience in various roles in the domain business for more than ten years and has access to extensive knowledge in the domain business. This deep industry knowledge and experience has also been transferred to KSregistry GmbH, the technical provider of the KSregistry system (KSR) and is evident in many trusted persons serving in different roles throughout the company.

The table in (fig. 4 in attachment Q26_Figure4.pdf) shows how the roles described above are planned for the SRS system. All resources at KSregistry are dedicated to the registry business. The calculations differ between the project phase and the years after the operational start. The project phase requires more resources as there is much planning, managing, and development required. All resources are engaged in the domain industry only and are experts in their field.

However, as the resources are shared and are not dedicated exclusively to one SRS project, the columns contain the number of resources available for this role and the percentage of all people working for this specific TLD. This percentage is the guaranteed time the resources for this SRS project assure.

G.2 Engineering Role

The designated engineering role includes the software developers of the entire SRS and all related interfaces (EPP, RDDS (WHOIS), escrow, etc.). All engineers are also integrated into 3rd level support of the SRS and related interfaces. The members of the engineering role are located in two geographically separate locations in Germany (St. Ingbert and Munich).

System Administration Role

The system administrators take care of the infrastructure of the SRS system. This includes the entire network, hardware, and system installations, as well as the cluster setup of the databases and all data backups which are made. Further, the installation of the hardware security module is performed by this role. This includes network setup, operating system installation, and HSM activation.

The members of the administration role are spread across two geographically separate locations inside of Germany (St. Ingbert and Munich).

Quality Management Role

The Quality Management (QM) role takes care of each software component which is integrated into the SRS system and related interfaces. After a development cycle is finished, the QM performs full integration testing of the entire system. The testing is performed on a separate testing system (OT&E) which mirrors the production system. The QM ensures production readiness of each and every software upgrade including emergency software patches. No software or system change will be promoted to production without the explicit approval of the QM.

Change Management (CM) ⁄ Project Management (PM)

The CM and PM role ensures that all steps in the development and system change processes are assessed, approved, implemented and reviewed in a controlled manner. This role filters requests so that only useful, valid and approved changes are implemented. They are also responsible for managing development efforts and changes to ensure that the changes are applied in accordance with predefined processes. They also chair the Change Advisory Board (CAB) and the Emergency Change Advisory Board (ECAB). These boards are comprised of selected people from other functions within the company. The project and change management role reviews and closes requests for change and reports to management. 


H. Whois Output Fields

Query on domain name data displays the following information:

Domain Name
Domain ID
WHOIS Server 
Referral URL
Domain Last Updated Date 
Domain Registration Date
Domain Expiration Date
Sponsoring registrar
Sponsoring registrar IANA ID
Domain Status
Registrant, Administrative, Technical and Billing Contact
Information including
Contact ID
Contact Name
Contact Organization
Contact Address, City, State⁄Province, Country
Contact Postal Code
Contact Phone, Fax, E-mail
Name Servers associated with this domain
DNSSEC information

Example Request: Query for domain “example.string”
Example Response:
Domain Name: EXAMPLE.STRING
Domain ID: 213232132-TLD
WHOIS Server: WHOIS.example.string
Referral URL: http:⁄⁄www.example.string
Updated Date: 2011-07-22T01:44:02Z
Creation Date: 2011-06-01T23:45:33Z
Registry Expiry Date: 2012-06-01T23:59:59Z
Sponsoring Registrar: EXAMPLE REGISTRAR
Sponsoring Registrar IANA ID: 1234567890
Domain Status: clientTransferProhibited
Registrant ID: 123456-STR
Registrant Name: EXAMPLE REGISTRANT
Registrant Organization: EXAMPLE ORGANIZATION
Registrant Street: 123 EXAMPLE STREET
Registrant City: SOMEWHERE
Registrant State⁄Province: AP
Registrant Postal Code: 12345
Registrant Country: EX
Registrant Phone: +1.5555522222
Registrant Fax: +1.55555544444
Registrant Email: EMAIL@EXAMPLE.STRING
Admin ID: 392839283-STR
Admin Name: EXAMPLE REGISTRANT ADMINISTRATIVE
Admin Organization: EXAMPLE REGISTRANT ORGANIZATION
Admin Street: 123 EXAMPLE STREET
Admin City: SOMEWHERE
Admin State⁄Province: AP
Admin Postal Code: 12345
Admin Country: EX
Admin Phone: +1.5555551212
Admin Phone Ext: 1234
Admin Fax: +1.5555551213
Admin Fax Ext:
Admin Email: EMAIL@EXAMPLE.STRING
Tech ID: 392811183-STR
Tech Name: EXAMPLE REGISTRAR TECHNICAL
Tech Organization: EXAMPLE REGISTRAR LLC
Tech Street: 123 EXAMPLE STREET
Tech City: SOMEWHERE
Tech State⁄Province: AP
Tech Postal Code: 12345
Tech Country: EX
Tech Phone: +1.1235551234
Tech Phone Ext: 1234
Tech Fax: +1.5555551213
Tech Fax Ext: 93
Tech Email: EMAIL@EXAMPLE.STRING
Billing ID: 112811183-STR
Billing Name: EXAMPLE REGISTRAR BILLING
Billing Organization: EXAMPLE REGISTRAR LLC
Billing Street: 123 EXAMPLE STREET
Billing City: SOMEWHERE
Billing State⁄Province: AP
Billing Postal Code: 12345
Billing Country: EX
Billing Phone: +1.1235551234
Billing Phone Ext: 1234
Billing Fax: +1.5555551213
Billing Fax Ext: 93
Billing Email: EMAIL@EXAMPLE.STRING
Name Server: NS01.EXAMPLEREGISTRAR.STRING
Name Server: NS02.EXAMPLEREGISTRAR.STRING
DNSSEC: signedDelegation
DNSSEC: unsigned0

Query on name server name data displays the following information:

Name Server Host Name
Name Server IP Addresses if applicable 
Sponsoring registrar
Name Server Creation Date
Name Server Last Updated Date 

Example Request: Query for name server ns1.example.string
Example Response:
Server Name: NS1.EXAMPLE.STRING
IP Address: 192.0.3.123
IP Address: 2001:0DB8::1
Registrar: Example Registrar, Inc.
Creation Date: 2011-06-01T23:45:33Z
Updated Date: 2011-07-22T01:44:02Z

Query on registrar displays the following information:

Registrar ID
Registrar Name
Registrar Status
Registrar Address, City, State⁄Province, Country
Registrar Postal Code
Registrar Phone, Fax, E-mail
Registrar Creation Date
Registrar Last Updated Date
Administrative, Technical Contact
Information including
Contact Phone, Fax, E-mail

Example request: Query for registrar Example Registrar, Inc.
Example response:
Registrar Name: Example Registrar, Inc.
Street: 4231 King Street
City: London
State⁄Province: XY
Postal Code: 123445
Country: XR
Phone Number: +1.3105559999
Fax Number: +1.3105559911
Email: registrar@example.string
Admin Contact: Pete Registrar
Phone Number: +1.3105551213
Fax Number: +1.3105551213
Email: pete@example-registrar.string
Technical Contact: Karlo Schlapp
Phone Number: +1.5610555222
Fax Number: +1.33105551111
Email: karlo@example-registrar.string


I. List of Attachments

- Q26_Figure1.pdf
- Q26_Figure2.pdf
- Q26_Figure3.pdf
- Q26_Figure4.pdf

DOT DESI operates with an open registrant policy and only offers one to ten year registration and renewal periods. The KSR platform also supports the handling of multiple year periods, as is it capable of managing multiple registrars, as described in the following.

A. Registration Life Cycle Periods

The registration life cycle of a domain name includes the following periods: available, add-grace period, registered, expired, auto-renew grace period, redemption grace period, pending delete, and released. This life cycle offers the possibility for different business cases, such as domain auctioning, drop catching, and domain tasting. As DOT DESI operates with an open registrant policy, auctioning, drop catching, and domain tasting may occur. It also includes the domain deletion excess fee in order to avoid massive abuse of the add-grace period. The complete registration life cycle is shown in attached fig. Q27_Figure1.1.pdf.

A.1 Available

The domain name is available for registration. Each registrar can register the domain name using a create domain command. The first registrar which submits the domain registration order and has sufficient funding will receive the domain name. After the successful registration of the domain name, the add-grace period will begin. An available domain name cannot be transferred, deleted, updated, or restored and will not be included in the zone file.

A.2 Add-Grace Period (AGP)

The AGP starts after the successful registration of the domain name and lasts for five days. During this period the registrar can submit a delete domain command to delete the domain name and will receive a complete refund of the registration fee. This refund does not include non-refundable fees of the registration process. However, the AGP follows the Internet Corporation for Assigned Names and Numbers (ICANN) AGP consensus policy to charge the registrar for excessive deletion activity during this period. During the AGP, the domain name is considered registered and therefore offers the same possibilities available during the registered period described below. A domain name in the AGP is included in the zone file and may not be transferred. The registrar license and agreement prohibits a domain name holder from changing registrars within the first 60 days of the initial registration, enforced by the SRS. If a domain name is renewed during this period and then subsequently deleted, the owning registrar will only receive a refund for the initial registration fee.

A.3 Registered

A domain name can be registered for a period of one to ten years. During this period the domain name can be transferred to another registrar using the transfer domain command if the requesting registrar has sufficient funding to pay the transfer domain fee. The transfer of a domain name will extend the registration period for one year, but cannot exceed ten years total registration period. The domain name can be renewed any time by the owning registrar using the renew domain command if the owning registrar has enough funding for the domain renewal fee. However, the maximum registration period of ten years can never be exceeded. A registered domain name is included in the zone file if associated with any host objects.

A.4 Expired

If the domain name passes its expiration date without being renewed by the owning registrar, the domain name will enter the auto-renew grace period. An expired domain name is included in the zone file if associated with any host objects.

A.5 Auto-Renew Grace Period (ARGP)

During this period the owning registrar has the possibility to delete the domain name using the delete domain command and receive a refund of the domain renewal fee. The ARGP lasts for 45 days. A transfer to another registrar is possible if the requesting registrar has enough funding for the domain transfer fee. A transfer process will extend the domain registration period for one year, but cannot exceed ten years total registration period. If the registration period is already ten years, the transfer will not extend the registration period. After 45 days without a renewal, the domain name will enter the redemption-grace period. During the ARGP the domain name will still be in the zone file if associated with any host objects.

A.6 Redemption Grace Period (RGP)

If a domain name enters the RGP it will be excluded from the zone file and the domain name will no longer resolve. During this period no renewal, transfer, or new registration of the domain name is possible. The RGP lasts for 30 days. During this time the owning registrar can restore the domain name. The registrar can submit an extended update domain command (restore) to reactivate the domain name if the registrar has enough funding for the restore domain fee. If a domain is restored it will enter the registered status with a registration period of one year. It will be included into the zone file with the associated host objects that were used before entering the redemption grace period. If a domain name passes the 30 days of redemption grace period (75 days total after expiration) the domain name will enter the pending delete period and can no longer be restored.

A.7 Pending Delete

In the pending delete period the domain name is set for deletion. The period lasts for five days and prohibits any process from occurring regarding the domain name. It will not be included in the zone file. After five days the domain name will be released and available for new registration through a valid domain registration order.

A.8 Released

The domain name is deleted from the SRS and enters the available period. The domain name will be immediately available for registration to all registrars.


B. Domain Name Operations

B.1 Create Domain

A registrar uses the create command to register a domain name. Before a domain name can be created the registrar should use the check command to determine if the domain name is available. The domain name will be registered for the period specified by the registrar. This period may be from one to ten years (the default is one year). Upon registration of a domain name the registrarʹs credit is immediately debited by the registration fee multiplied by the number of years requested. The registry operator may also add an initial setup fee for a new registration. To be included into the zone file, the domain name must have at least two but no more than thirteen name servers. The registrant may add an authentication code for the domain during the creation or a randomly generated authentication code will be set for the domain name.

B.2 Delete Domain

The delete domain command allows the owning registrar of the domain name to delete it. A request to delete a domain name will cause all child name servers of the domain name to also be deleted. A domain must not be deleted if it has child name servers hosting other domains. When a domain name is deleted outside of the AGP it goes into the redemption-grace period status for 30 days. When a domain name is deleted within the AGP it is deleted immediately from the SRS and the zone file and will be available for a new registration.

B.3 Transfer Domain

The transfer process begins when a registrar initiates a transfer with a transfer domain command, the correct authentication code, and sufficient funding in his account for the transfer domain fee. The domain will be flagged in the SRS as being requested for transfer (“pendingTransfer” status). The current registrar has five calendar days to approve or reject the transfer request. If the losing registrar explicitly approves the request the domain is transferred and one year is added to the expiration date. However, the registration period cannot exceed ten years total and will be capped at a maximum of ten years. If the losing registrar explicitly denies the request, then the transfer is immediately canceled and the requesting registrar will receive a refund of the transfer fee. If the gaining registrar mistakenly sends a transfer request, they may cancel the request as long as the transfer is pending. In this case the requesting registrar receives a refund of the transfer fee. Once one of these three actions is complete the SRS creates a poll message to all participating registrars for the domain name. If no action is taken within five days, the request is automatically approved by the SRS batch system. Once a transfer is requested the losing registrar has the response options to reject, approve, or do nothing (auto approve). After the successful transfer of a domain name the old authentication code will be replaced with a new randomly generated authentication code.

B.4 Update Domain

The update command enables the owning registrar of the domain name to perform four different update operations on the domain name: Update the name servers, the authentication code, the associated contacts, and the statuses of a domain name. Possible statuses that can be updated include “clientHold”, “clientDeleteProhibited”, “clientUpdateProhibited”, “clientTransferProhibited”, and “clientRenewProhibited”. If an update command removes all name servers of a domain name, it will no longer be included in the zone file and will receive the status “inactive”.

B.5 Renew Domain

The renew domain command allows the registrar of the domain name to extend the registration period if they have enough funds for the renew domain fee multiplied by the number of years the registration period will be extended. The request for a renewal should contain the period to identify the number of years to be added to the registration period. If not provided, the SRS uses a default value of one year. The renewal request should contain the current expiration date to ensure that the domain name will not be renewed multiple times if the request was submitted multiple times due to connection problems between the SRS and the registrar. If no expiration date is given, the SRS will automatically use the current expiration date as the default value. The SRS will renew the domain name for the period specified by the registrar and returns the new registration expiration date.

B.5 Restore Domain

The restore domain command enables a registrar to restore a deleted domain name after the AGP. In order to successfully restore a domain, the registrar must submit a restore domain command and have sufficient funding for the restore domain fee. The restore operation adds the “pendingRestore” status to the domain name until completion of the request. A successful restore will extend the registration period of the domain name by one year but is capped at a total registration period of ten years. After the restore operation, the domain name will be added back into the zone file as long as there is at least one name server and no “clientHold” or “serverHold” status associated. If the restore operation fails, the domain will stay in the RGP until it enters the pending delete period and the registrar will receive a refund of the restore domain fee.


C. Domain Name Statuses

To ensure the registration domain life cycle there are several domain statuses that can be seen by everyone using the RDDP (WHOIS) or by any registrar using the extensible provisioning protocol (EPP). These statuses are very important in identifying the current period a domain name is in, or identifying the problems a registrar can encounter while managing a domain name (e.g. a failing transfer request caused by a “serverTransferProhibited” status). A foreign registrar may also be interested in the statuses of a domain name to identify when a specific domain name will be available for registration again (drop catching). Domain name statuses include EPP and RGP domain name statuses as referenced in RFC 3915. Depending on the life cycle period of a domain name, it can have an EPP and a RGP status at the same time. In some cases these two statuses can be different.

These domain statuses are compliant with the RFCs 3915, 5730-5734, and 5910. The domain statues are:

- addPeriod
- autoRenewPeriod
- inactive
- ok
- pendingRestore
- pendingDelete
- pendingTransfer
- redemptionPeriod
- serverDeleteProhibited
- serverHold
- serverRenewProhibited
- serverTransferProhibited
- serverUpdateProhibited

All server statuses are always set by the SRS. However, the owning registrar also has the ability to assign statuses to a domain name, offering the same functionality as the server statuses. These statuses are:

- clientDeleteProhibited
- clientHold
- clientRenewProhibited
- clientTransferProhibited

A domain name may have more than one status at a time, but must have at least one status. Some statuses prohibit other statuses on the same domain name.

C.1 ok

This is the default status of a domain name that has no operations or prohibitions. This value is set and removed by the SRS system as other status values are added or removed and cannot be combined with any other status. The SRS sets this status upon initial creation. A domain name with this status may be updated with any “client” statuses and will be included in the zone file if there is at least one name server associated with it.

C.2 inactive

If the delegation information has not been associated with the domain name, this status is applied. This is the default status when a domain name has no associated host objects for the DNS delegation. This status will be set by the SRS when all host-object associations are removed.

C.3 clientHold

The owning registrar may set the domain name to this status to prevent the domain name from being included in the zone file. 

C.4 clientUpdateProhibited

If a domain name status is “clientUpdateProhibited” it cannot be updated using an update domain command. The name servers, authentication code, contacts, and other statuses of the domain name cannot be updated until this status is removed. 

C.5 clientTransferProhibited

The owning registrar can set this status to a domain name to prevent any other registrar from successfully requesting a transfer for this domain name.

C.6 clientDeleteProhibited

If a domain name status is “clientDeleteProhibited”, it cannot be deleted from the SRS using the delete domain command. The domain can still expire after the registration period has passed. 

C.7 clientRenewProhibited

If a domain name status is “clientRenewProhibited”, it cannot be renewed explicitly by the registrar using the renew domain command. It can still be automatically renewed by the SRS batch system if the owning registrar has set the renewal mode of the domain name to auto renew.

C.8 serverHold

The SRS administrator may set the domain name to this status to exclude it from the zone file. 

C.9 serverUpdateProhibited

The SRS may set the domain name to this status to prevent any updates using the update domain command. The name servers, authentication code, contacts, and the domain name statuses cannot be updated until this status is removed. 

C.10 serverTransferProhibited

The SRS may set the domain name to this status to prevent any registrar from successfully requesting a transfer for this domain name.

C.11 serverDeleteProhibited

The SRS may set the domain name to this status. If a domain name status is “serverDeleteProhibited” it cannot be deleted from the SRS using the delete domain command. This status is slightly different from the “clientDeleteProhibited” as the domain will not even be deleted after the redemption-grace period.

C.12 serverRenewProhibited

The SRS may set the domain name to this status. If a domain name status is “serverRenewProhibited”, it cannot be explicitly renewed by the owning registrar using the renew domain command. It can still be automatically renewed by the SRS batch system. 

In addition, the SRS batch system may set the RGP pending period statuses as listed below. In EPP, the RGP pending period statuses are represented as substatuses of the EPP statuses.

C.13 redemptionPeriod

The SRS sets the domain name to this status when a domain is deleted after the AGP. Only the restore domain operation is allowed on a domain with the “redemptionPeriod” status.

C.14 pendingRestore

The SRS sets the domain name to this status when a restore is requested. If a domain name status is “pendingRestore”, then no additional restore request can be successfully submitted.

C.15 pendingDelete

The SRS sets the domain name to this status once it has been in “redemptionPeriod” for 30 days. A domain name remains on “pendingDelete” status for five days before it is finally deleted from the SRS.

C.16 pendingTransfer

The “pendingTransfer” status is automatically set when a domain transfer is requested by a registrar. A domain name remains in “pendingTransfer” status until the transfer is approved, automatically approved through the SRS batch system, rejected, or canceled by the requesting registrar.

C.17 addPeriod

This period is entered after the initial registration of a domain name. If the domain name is deleted by the owning registrar during this period he will receive a refund of the domain registration fee in compliance with ICANNʹs AGP consensus policy.

C.18 autoRenewPeriod

This period is set after a domain name registration period expires and is renewed automatically by the SRS. If the domain name is deleted by the owning registrar during this period he will receive a refund of the domain renewal fee.


D. Reserved Premium Domain Names

The registry operator reserves the option to define specific domain names as reserved or premium domain names. These domain names will be in compliance with the described registration life cycle with the addition of a manual registration process through the registry operator support and legal team. Special fees may be accounted for those domain names to reflect manual processing.


E. Roles

The table in attached fig. 27_Figure_5.1.pdf shows how the roles described above are planned for the SRS system.

Support Role

The support role of the registry operator will review these reports. If there is a logical problem, an engineer will be assigned to solve the problem. The support may manually correct or influence the life cycle of a domain name if necessary. The registry operatorʹs support role will also take care of any submitted registrar problems regarding the registration life cycle, either through the telephonic support or the ticket system.

Legal Role

All legal issues and dispute cases will be manually reviewed and processed by the legal role of the registry operator in compliance with the registry operatorʹs policy. The legal role may manually correct or influence the life cycle of a domain name if necessary.

Administration Role

The ticket system and the telephone system where the registrars submit their problem requests will be set up and maintained by the administrators. 

Designated Engineering Role

Each technical issue that is assigned by a supporter will be reviewed and solved by an engineer. Another task of the engineering role is the development of the tools that enable the support and legal roles to influence and maintain the domain life cycle.


F. List of Attachments

- Q27_Figure1.1.pdf
- Q27_Figure5.1.pdf

Desi Networks LLC’s (the Company) proposed use for the DOT DESI TLD will include robust protection mechanisms designed to quickly and effectively address any abusive registrations within the space. Accordingly, the Company will adopt a comprehensive system including all rights protection mechanisms required by ICANN, plus ongoing monitoring for abusive use of domain names within the space.

Additionally, Desi Networks LLC will do the following:

- Utilize a trusted method of communication for all correspondence between Desi Networks LLC and the TLDʹs registrars
- Ensure that all registrant contact information, including WHOIS records, is complete and remains current
- Implement effective mechanisms for identifying and addressing abusive practices
- Establish a point of contact for third-party reporting of abusive practices
- Determine and implement a streamlined practice for addressing and removing orphan glue records
- Publish on its website and include as binding registry policy an Anti-Abuse Policy, described in detail below, which provides applicable definitions of abuse and outlines steps the Company will take to address any such situations


A. Point of Contact for Abuse Complaints

The Company will establish a point of contact to handle complaints directly. In order to effectively capture any complaints the abuse email inbox will be routinely and continuously monitored. Complaintants will be provided with a responsive communication containing an auditable tracking or case number. The abuse point of contact will be responsive and effective at resolving issues. They will be tasked with answering email quickly, empowered to take effective action, and guided by well-defined written criteria. This role-based function will be performed by Desi Networks LLC’s legal team which includes Mr. Mike Rodenbaugh and Mrs. Shaila Lakhani Ohri, which will ensure that the abuse point of contact has a broad familiarity with current industry knowledge and a high-level awareness of evolving online security risks.

The abuse point of contact will be supported by the law firm Rodenbaugh Law, of San Francisco, California, USA, with whom the abuse point of contact will consult and coordinate the correct management of disputes and reported abuse. The abuse point of contact will further consult with Thomsen Trampedach GmbH, as well as with KSregistry in order to coordinate technical reactions necessary to respond to or mitigate abusive behavior in a timely manner.

Mr. Mike Rodenbaugh is a UDRP Panelist with the Czech Arbitration Court and has extensive, firsthand knowledge of ICANN and its structure. Thomsen Trampedach GmbH is a Swiss-based domain name consulting company with long-term involvement in ICANN, experience advising large brands in all domain name related issues, and is qualified to assist and advise the Company’s on-hand staff. With regard to the estimated number of registrations, these allocated resources will be sufficient to handle the expected initial volume of abuse complaints. Abuse complaint metrics will be tracked and reviewed carefully each year, and adequate resources will be expended to ensure appropriate trending of those metrics, thus providing the abuse point of contact with sufficient resources.

Mrs. Shaila Lakhani Ohri has over 15 years of experience as an attorney, and has practiced law in the areas of corporate, securities, finance, employment and contracts. Shaila’s legal experiences include working at a law firm and as in house counsel for a finance company and a fortune 500 company. Shaila graduated with a B.A. from The American University in Political Science and International Studies, and completed her Juris Doctor degree at The George Washington University School of Law. Shaila will provide general legal advice and counsel to the company.

Desi Networks LLC, believes that infrastructure protection, rights protection, and user security are of paramount importance for a TLD owner. To that end, the Company expects to ensure sufficient resources for this critical role, and to do whatever is reasonably necessary to ensure a secure and trusted zone.


B. Anti-Abuse Policy

Desi Networks LLC, will develop and implement upon launch of the TLD an Anti-Abuse Policy (AAP). The AAP will be made binding for all registrants by contractually obligating registrars through the Registry-Registrar Agreement to pass on the AAP as part of their registration agreements. The AAP will also be published prominently on the Registry website alongside the abuse point of contact and with instructions on how to best report any suspected violations of the AAP to the registry.

The AAP will be based on and expand upon existing registry policies to ensure best industry practice is followed. The goal of the AAP is to limit significant harm to internet users, to enable Desi Networks LLC or accredited registrars to investigate and to take action in case of malicious use of domain names and to deter registrants from engaging in illegal or fraudulent use of domain names.

The Company defines abuse as an action that causes actual and substantial harm, or is a material predicate of such harm, and is illegal, illegitimate, or otherwise contrary to Desi Networks LLC’s policy.

“Abuse” includes, but is not limited to, the following:

- Use of a domain to defraud or attempt to defraud members of the public in any way
- Use of a domain to distribute or publish hateful, defamatory, or derogatory content based on racial, ethnic, or political grounds, intended or generally able to cause or incite injury, damage or harm of any kind to any person or entity
- Use of a domain name to publish content threatening or invading the privacy or property rights of a third party
- Use of a domain name to publish content that infringes the trademarks, copyrights, patent rights, trade secrets or other intellectual property rights, or any other legal rights of the Company or any third party, or any action infringing on the named rights
- Violation of any applicable local, state, national or international law or regulation
- Use of a domain name for the promotion, involvement in or assisting in, illegal activity of any kind, as well as the promotion of business opportunities or investments that are not permitted under applicable law
- Advertisement or offer for sale any unlawful goods or services in breach of any national or international law or regulation
- Use of domain names to contribute to the sale or distribution of prescription medication without a valid prescription as well as the sale and distribution of unlicensed or unapproved medication
- Distribution of Child Pornography or other content depicting minors engaged in any activity of a sexual nature or which may otherwise harm minors
- Use of domain names to cause minors to view sexually explicit material
- Any use of domain names with regard to spam in any form, including through e-mail, instant messaging, mobile messaging, or the spamming of Web sites or Internet forums, as well as advertising for a domain name through spam
- Initiation or intentional participation in denial-of-service attacks (“DDoS attacks”)
- The use of domain names in phishing activities, tricking Internet users into divulging personal data such as usernames, passwords, or financial data
- The use of domain names in pharming, such as DNS hijacking and poisoning
- The use of domain names for the intentional distribution of spyware, botware, keylogger bots, viruses, worms, trojans or other forms of malware
- The use of a domain name in unauthorized fast flux hosting, disguising the location of internet addresses or Internet services. Fast flux hosting may be used only with prior permission of Desi Networks LLC
- The use of domain names to command and control botnets, i.e. a network of compromised computers or “zombies”
- The use of domain names in activities intended to gain illegal access to other computers or networks (“hacking”), as well as any activity to prepare for such system penetration

In accordance with best practices in current generic Top Level Domains, the Company reserves the right to either directly or through the issuing of a request to an accredited registrar 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:

- To protect the integrity and stability of the .DOT DESI TLD and⁄or prevent the abuse of any DOT DESI domain name
- To comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process
- To avoid any liability, civil or criminal, on the part of Desi Networks LLC, as well as its affiliates, subsidiaries, officers, directors, and employees.per the terms of the Registry Agreement or to correct mistakes made by DESI, Registry Service Provider or any Registrar(s) in connection with a domain name registration

The Company also reserves the right to place a domain upon registry lock, hold or similar status name during resolution of an investigation or dispute.


C. Handling of Abuse Reports

All abuse reports received by the abuse point of contact will be tracked internally in a ticketing system to ensure accountability and ease of reference, and a tracking number will be provided to the reporter. Each report will be carefully reviewed and evaluated regarding its credibility, to determine whether the reported issue is an abuse concern and to assess the required action(s), if any. Desi Networks LLC will work in tandem with the sponsoring registrar(s) as well as the Registry Service Provider to rapidly address potential threats or abuse complaints, investigate all reasonable complaints, and take any appropriate action(s) thereto.

As standard practice, the Company will forward all credible and actionable reports, including the accompanying evidence, if any, to the sponsoring registrar, with a request to investigate the issue further and to take appropriate action. In case the registrar determines in the course of the investigation that the use of the domain name violates the applicable terms of use, ICANN policies or the AAP, the registrar is expected to take action within a reasonable time. Desi Networks LLC further reserves the right to act directly and immediately in cases of obvious and significant malicious conduct.

The Company will implement valid court orders or seizure warrants from courts, arbitration tribunals, or law enforcement agencies of applicable jurisdiction as a top priority. The Company will further work closely with law enforcement agencies if necessary.

In case of an unexpected volume of credible abuse complaints, Desi Networks LLC will take advantage of additional resources such as spam databases and blocklists, anti-phishing feeds, analysis of registration data, and DNS queries.


D. Orphan Glue Records:

According to the ICANN SSAC paper SAC048 at: http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf orphan glue records are defined as follows:

“By definition, orphan records used to be glue records. A glue record becomes an ‘orphan’ when the delegation point NS record referencing it is removed without also removing the corresponding glue record. The delegation point NS record is sometimes referred to as the parent NS record.”

An orphan glue record can occur whenever a domain is placed in ServerHold or ClientHold status. In these cases, the domain is removed from the zone file but existing name servers of this domain will be kept in the zone file so that other sites which are still using these name servers are still kept functional.

Example:
“example.string” is deleted from the zone file by setting to ServerHold status, but “ns1.example.string” will be kept in the zone file.


D.1 Prevention of Orphan Glue Records During Domain Deletion

Deleting a domain name is only possible if there are no glue records used by other domains associated with the domain being deleted.

If there are glue records available but not used by other domains in the registry, the glue records will be deleted prior to the domain deletion. Whenever there are glue records available which are still in use, this has to be resolved first. If there are no glue records at all the domain can be deleted instantly.

Solving the problem of glue records for domains which are supposed to be deleted can be done by checking the zone file. The zone file reveals the domains which are using the name servers. Once the required information is available, the named registrars must be contacted and new name servers should be set for the remaining domains in order to release the glue records.

In cases where glue records are being used in a malicious way, the abuse point of contact has to be contacted. The abuse point of contact will check this issue and take any appropriate actions, which may result in removing relevant records from the zone file in case the abuse complaint is valid.


E. Preventive Countermeasures

Pharming is an abusive practice used to gain illegal access to personal and confidential internet user information by diverting internet traffic through the manipulation of the information between the recursive resolver name server and the client software (e.g. web browser) (DNS-cache poisoning). Since pharming is commonly accomplished by redirecting traffic at the recursive DNS level, mitigation is most effective at the ISP level.

However, as an added countermeasure, the KSregistry will sign the domain zone using DNSSEC, as detailed in our answer to question 35, allowing the relying party to establish a chain of trust from the DNS root down to the domain name, thus validating DNS queries in the zone.

Registrars will be encouraged to use a DNSSEC enabled DNS hoster and to provision the related delegation signers (originating from the DNS hoster) to KSregistry’s SRS via EPP. This way it will be possible for the relying party to validate DNS queries and to protect from DNS tampering to a certain degree.

DNSSEC is a set of records and protocol modifications that provide authentication of the signer of the DNS data, verification of integrity of the DNS data against modification, non-repudiation of DNS data that have been signed, and authenticated denial of existence of DNS records. DNS data secured with DNSSEC are cryptographically signed and incorporate asymmetric cryptography in the DNS hierarchy, whereby trust follows the same chain as the DNS tree, meaning that trust originates from the root and is delegated in the same way as the control of a domain. When a domain name in the TLD is requested by a browser, the signature is validated with the public key stored in the parent zone.


F. Promoting Accurate WHOIS Data

Desi Networks LLC is committed to maintaining the DOT DESI TLD space as a safe, secure online environment. A key component of such a plan is the creation and upkeep of accurate WHOIS records for the registry. As indicated in detail in the above answer to Question 26, the Company will develop strong safeguards to help best ensure the accuracy and privacy of the data stored in the WHOIS database, and will ensure that such records will be publicly-available to the extent required by ICANN regulations.

The WHOIS records for this TLD will constitute a “thick” WHOIS, combining all applicable data and information for domain name registrants in a central location. The individual registrars offering DOT DESI TLD domain names will be responsible, under the terms of the Registry-Registrar Agreement, for providing and promptly updating the WHOIS database with current, accurate and complete information. The Registry Service Provider will be responsible for monitoring such information and records to ensure that registrars comply with the contractual agreements to provide accurate data, including the use of field-valid telephone and fax numbers and the use of country names as defined under ISO 3166. DESI shall expressly reserve the right to cancel or suspend any domain name registrations within the space should a registrant fail to provide accurate or complete WHOIS information.

At all times, ICANN’s WHOIS Data Problem Reporting System (WDPRS) will be available to anyone wishing to file a complaint regarding the accuracy or sufficiency of WHOIS records within this TLD.


G. Ensuring Proper Access to Domain Functions

The Registry will be operated using a comprehensive and detailed authentication system designed to implement a wide range of registry functions for both internal operations and as external registrar access. Registrar access will be limited by IP address control lists and TLS⁄SSL certificates, as well as verification processes for proper authentication and appropriate limitations to restrict access to the sponsored objects.

Each domain name will be assigned a unique AUTH-INFO code. The AUTH-INFO code is a 6- to 16-character code assigned by the registrar at the time a domain is created and which can be modified by the registrar at any time. Its purpose is to aid in the identification of the domain owner so that proper authority can be established. For example, a registrar-to-registrar transfer can be initiated only by using the correct AUTH-INFO code, to ensure that domain updates (update contact information, transfer, or deletion) are undertaken by the authorized registrant. Access to the domain’s AUTH-INFO code, stored in the registry, is limited to the sponsoring registrar and is accessible only via encrypted, password-protected channels.

Further security measures are anticipated and will be implemented in the new space, but are currently treated as confidential for security reasons. Accordingly, a full explanation of these mechanisms may be found in the response to Question 30(b).

Rights holder protection is a core element of Desi Networks LLCʹs (the Company) approach to the management of this new TLD. We have built our comprehensive rights-protection plan by carefully reviewing the many mechanisms developed during the launch of other recently introduced and already established TLDs in order to learn from previous experience and find innovative solutions to certain common issues. Our outsourced registry service provider, KSregistry GmbH, will comply with all required management and gateway mechanisms needed for the TLD. Thus, the outsourced registry service provider and Desi Networks LLC will jointly undertake the following actions:

- Implement appropriate rights protection mechanisms during the various critical phases of the registry launch
- Execute a well-defined Sunrise period in compliance with ICANN requirements, which will include implementation of the Trademark Clearinghouse notification system
- Implement a professional Trademark Claims program, utilizing the Trademark Clearinghouse and drawing upon models of similar programs used successfully in previous TLD launches
- Enlist a third party Trademark validation service, if necessary, during the Sunrise period in conjunction with using the Trademark Clearinghouse
- Commit to operating the URS (Universal Rapid Suspension) Policy as described in the draft Registry Agreement
- Commit to operating and implementing the UDRP (Uniform Domain Name Dispute Resolution Policy) when and as needed in our capacity as the Registry Service Provider for the space
- Comply with the new Trademark Post-Delegation Dispute Resolution Procedure (PDDRP)
- Embed all rights protection elements that require compliance support or involvement with Registrars and⁄or their resellers into the Registry-Registrar Accreditation Agreement for all domains of this TLD
- Ensure the inclusion of all ICANN-mandated and TLD-specific rights-protection mechanisms in the Registry-Registrar Agreement entered into by ICANN-accredited registrars authorized to register names in the TLD, including oversight of all provisions to be included in the end-user Registration Agreements in effect as between the registrar and registrants of this TLD

The following provides a brief outline of the steps the Registry Service Provider intends to implement in conjunction with the Registry Operator for the proper function of this new TLD space.


A. Trademark Clearinghouse

The Trademark Clearinghouse is a new service offering provided for under the ICANN New gTLD program. It will provide a mechanism to notify trademark holders of qualified Sunrise applications for textual strings that present an identical match to their trademarks. The Clearinghouse system will be comprised of the following elements:

- Registration of marks in the Clearinghouse by trademark holders will be validated by the Clearinghouse operator, utilizing trademark filings and other rights as applicable under the established policies for the Trademark Clearinghouse
- An asynchronous comparison of marks submitted during Sunrise with those registered in the Trademark Clearinghouse
- Should an exact match be identified between an applied-for textual string and a mark registered in the Clearinghouse database, notification will be provided to the relevant mark holder and the Sunrise applicant in the manner and means specified in the Applicant Guidebook

Desi Networks LLC will comply with all required elements of the Trademark Clearinghouse system, and will utilize a trademark validation agent if necessary to assist with the Sunrise procedure.


B. Sunrise Procedure

B.1 Sunrise Mechanism

The DOT DESI TLD Sunrise period will be conducted in compliance with ICANN specifications. It is anticipated that independent, third-party trademark owners will register their marks as second-level domain names within the space. Therefore, the company will develop a fully compliant Sunrise policy, which will define what domains may be applied for during Sunrise applications and detail all dispute policies, including its SDRP (Sunrise Dispute Resolution Policy), for challenging the validity of any Sunrise registration. The elected SDRP dispute provider will be a member of ICANNʹs list of approved UDRP providers. Desi Networks LLC will consult with both the dispute provider and expert legal counsel in drafting and finalizing the Sunrise Policy.

The Sunrise period will run for a minimum of 30 days prior to the general availability of domain names and will include a minimum two week quiet period. The registration functions will not be available during the quiet period while we work to complete related Trademark Clearinghouse matches and related notifications.


C. Eligible Rights

The proposed Sunrise Eligibility Requirements (SERs) will conform to the following qualifications derived from numerous past TLD Sunrise programs:

C.1 Ownership of a qualifying mark

See Section 7.2, number (i): The registry will recognize and honor all

- Word marks that are nationally or regionally registered and for which proof of use (which can be a declaration and a single specimen of current use) was submitted to, and validated by, the Trademark Clearinghouse
- Trademarks not in the Clearinghouse but that are verified by a third party Trademark validation contractor and conform to the following standards:

 * the Domain Name is identical to the textual or word elements of the trademark or service mark registration on which the registration of the Domain Name is based
 AND
 * The trademark or service mark registration on which the registration of the Domain Name is based is of national effect
 AND
 * The trademark or service mark registration on which the registration of the Domain Name was based was issued (registered) prior to [a cutoff date to be determined]
- Representation that all provided information is true and correct
- Provision of data sufficient to document rights in the trademark


D. Application Process

All submissions during Sunrise will be accepted as applications only and not a full registration until the Trademark has been validated to conform per the SERs listed above, and the Sunrise applicant has been determined to meet the eligibility requirements for registration in this TLD. Multiple applications for the same string, were they to occur, would be allowed from multiple Trademark holders. Contention would be resolved through auction were there to be more than one qualifying applicant. Following winning an auction, or if there is a single qualifying applicant, the application would be promoted to a full domain registration.

D.1 Field Submission and Validation Safeguards

To support the Sunrise process the registry system will apply requirements to data submissions, in the registry application. KSregistry will use the data fields⁄extensions from the Dot Asia and Dot XXX launches. The field types listed below are mandatory during Sunrise submissions and are not able to be updated once an application has been submitted in order to avoid manipulation of the validation process. Please see the related EPP extension 〈Draft-tan-epp-launchphase-01〉 attached to the Question 25 response.

〈claimName〉

The word mark of the trademark, as noted in the trademark or service mark registration record.

〈claimNumber〉

The registration number (not the application number) of the trademark.

〈claimRegDate〉

The date the trademark was registered. This is the date that the trademark was granted.

〈claimCountry〉, [〈claimRegion〉]

The two-letter code for the nation or national jurisdiction the trademark was registered in. Allowable values will be limited to identify national trademark registries and regional trademark registries (such as the Benelux and EU trademark registry registrations).

〈claimEntitlement〉

Whether the applicant (corresponding to the Registrant Contact) holds the trademark as the original ʺowner,ʺ ʺco-owner,ʺ or ʺassigneeʺ.

D.2 Trademark Validation and Safeguards

As mentioned previously we may employ a third party Trademark validator to examine Sunrise applications. The Trademark Validator will have the ability to request additional data or clarifying materials about any Sunrise Application, including additional direct verification of the Sunrise applicantʹs identity in respect to the cited trademark.

The contracted party will be globally experienced in intellectual property law and will employ the following stepped process and functions:

Examination of Trademark

Trademarks will be validated against either the Trademark Clearinghouse, or against a National Trademark Database from a qualifying country. This is required for a Sunrise application to be considered ʺqualified or validatedʺ.

Deterrents

In policy documents, training materials, and FAQs, we will communicate clear language indicating that administration fees associated with filing Sunrise applications are NOT refundable. The administration fee will be designed to recover validation costs and should financially dissuade frivolous applications.

D.3 Contending Applications, Sunrise Auctions

The Registry will complete all Sunrise application validations following the close of the Sunrise period. There are only three possibilities for outcome and subsequent actions:

- One valid application for a given string: The domain will be awarded to that applicant
- Two or more valid applications for the same string: The domain will be offered to all qualified applicants at auction. The highest bidder will be awarded the domain
- No valid applicants for a given string: The domain will be offered in subsequent phases of the Registry but without Trademark requirements

D.4 Additional Considerations

Sunrise auctions may take some time to conduct and likely will run over other later phases. In the event no applicant bids at auction, the first valid application received will be awarded the domain.

Domains awarded under Sunrise will be locked (Sunrise lock status) for at least 60 days following the procedure to support parties wishing to file a Sunrise Challenge.

Once a Sunrise domain is awarded, it will be promoted to a full registration and the relevant RDDS (WHOIS) data will be published as per standard Registry RDDS (WHOIS) policy.

Conflict of Interest restrictions will be applied to employees, contractors, consultants and significant investors of the Registry disallowing participation in Sunrise auctions. See also the answer to Question 28.


E. Sunrise Challenges

The Sunrise Dispute Resolution Process (SDRP) will allow challenges based on the following four grounds:

- At the time the challenged domain name was registered, the registrant did not hold a trademark registration of national effect
- The domain name is not identical to the mark on which the registrant based its Sunrise registration
- The trademark registration on which the registrant based its Sunrise registration is not of national effect (or regional effect)
- The trademark registration on which the domain name registrant based its Sunrise registration did not issue on or before the effective date of the Registry Agreement and was not applied for on or before ICANN announced the applications received

We see that ICANNʹs Module 4, ʺTrademark Clearinghouseʺ document, paragraph 6.2.5 says ʺThe Clearinghouse will maintain the SERs, validate and authenticate marks, as applicable, and hear challenges.ʺ We are not sure exactly what ʺhearing challengesʺ means. If it means that the Clearinghouse Provider is the only party that can adjudicate Sunrise Challenges, then of course the DOT DESI TLDʹs Sunrise Challenges will go there to be heard. Otherwise, we will retain the services of a dispute resolution provider such as WIPO or the Czech Arbitration Court to receive and adjudicate the Sunrise Challenges. All applicants and registrars will be contractually obligated to follow the decisions handed down by the dispute resolution provider.

After any Sunrise name is awarded to an applicant, it will remain under a ʺSunrise Lockʺ status for at least 60 days so that parties will have an opportunity to file Sunrise Challenges. During this Sunrise Lock period the domain name will not resolve and cannot be modified, transferred, or deleted by the sponsoring registrar. The domain name will be unlocked at the end of that lock period only if it is not the subject of a Sunrise Challenge. Challenged domains will remain locked until the dispute resolution provider has issued a decision, which the registry operator will promptly execute.


F. Continuing Rights Protection Mechanisms in the Specific TLD Space

Following the conclusion of the Sunrise period for this TLD space, certain rights protection mechanisms will continue to be active. These mechanisms are the dispute resolution policies, which shall include the URS, UDRP, Trademark PDDRP, a Trademark Claims Service, and any other policies ICANN may enact from time to time via the adoption of Consensus Policies.

F.1 Uniform Rapid Suspension (URS)

The registry operator will implement decisions rendered under the URS on an ongoing basis. As per the URS policy, the registry operator will receive notice of URS actions from ICANN-approved URS providers. These e-mails will be directed immediately to our outsourced KSregistry support staff, which is on duty 24 x 7 x 365. The support staff will be responsible for executing the directives from the URS Provider, and all support staff will receive training in the proper procedures.

As per ICANNʹs URS guidelines, within 24 hours of receipt of the Notice of Complaint from the URS Provider, our staff will lock the domain, meaning the registry shall restrict all changes to the registration data, including transfer and deletion of the domain names, but the name will continue to resolve. The support staff will accomplish this by associating the following EPP statuses with the domains and relevant contact objects:

- ServerDeleteProhibited, with an EPP reason code of ʺURSʺ
- ServerTransferProhibited, with an EPP reason code of ʺURSʺ
- ServerUpdateProhibited, with an EPP reason code of ʺURSʺ

Our support staff will then notify the URS Provider via e-mail immediately upon locking the domain name.

Our support staff will retain all copies of the e-mails from the URS providers. We will assign each case or order a tracking or ticket number. We will use this to track the status of each opened URS case through to resolution via a database.

Our support staff will then execute further operations upon notice from the URS providers. Each URS provider is required to specify the remedy and required actions of the registry operator, with notification to the registrant, the Complainant, and the Registrar. We will set up the necessary DNS re-pointing required by the URS guidelines.

The guidelines state that if the Complainant prevails, the registry operator shall suspend the domain name, which shall remain suspended for the balance of the registration period and would not resolve to the original web site. The nameservers shall be redirected to an informational web page provided by the URS Provider about the URS. The WHOIS for the domain name shall continue to display all of the information of the original Registrant except for the redirection of the nameservers. In addition, the WHOIS shall reflect that the domain name will not be able to be transferred, deleted or modified for the life of the registration.

F.2 Uniform Dispute Resolution Policy (UDRP)

Although UDRP actions are typically implemented at the Registrar level, itʹs conceivable that a court order may be directed to the Registry through the Abuse Point of Contact (APOC). Such an order would be escalated to the support and⁄or legal department contacts as required. Support staff would quickly affect a mandated transfer, if so ordered, or an order requiring the lock-down of a domain name. The Registryʹs legal counsel also may attempt to verify the court order. Registry functionality outlined in the answer to Question 27 describes the necessary functionality required by Registrars to support their UDRP commitments, and Desi Networks LLC is committed to meeting these standards.

F.3 Trademark Post-Delegation Dispute Resolution Procedure (Trademark PDDRP)

Desi Networks LLC commits to complying with the PDDRP as set forth in the Applicant Guidebook.

F.4 Trademark Claims Service:

For at least the first 60 days of general registration, the Applicant will enable a Trademark Claims service for trademarks recorded in the Trademark Clearinghouse, which will provide a real-time notice to a party attempting to register a domain name if it matches a trademark in the Clearinghouse and notify trademark holders when domain names are registered that match marks in the Clearinghouse.


G. Contractual Operation of Provision via the Registry-Registrar Agreement

The Registry-Registrar Agreement will be signed by all registrars interested in offering registrations under this TLD. This agreement will contractually bind such registrars to follow certain registry-mandated procedures, and will include inter alia the following provisions:

- The registrar will ensure that the relevant Domain Name Registration Agreements between itself and any prospective registrant in the TLD space will incorporate all registry-mandated policies, restrictions, and guidelines
- The registry shall have the authority to refuse or reject any registration request received for a domain name within the .DESI TLD space, or to cancel, transfer, delete, suspend, revoke, or otherwise modify a registration within the space, for the following reasons:
 * The domain name was registered through a registrar error or oversight, the provision of inaccurate data, fraud, or mistake, and the registrant is determined to be ineligible to register domain names within the TLD
 * The request for registration was not made in the proper format, did not contain sufficient information under ICANN and⁄or registry requirements, or such information was not properly updated as required by ICANN and⁄or registry requirements
 * In order to rectify or correct any mistake or error made by the registry or registrar in the registration of the domain name.
 * In order to comply with any request received from law enforcement, a court order, arbitral panel decision, appropriate dispute resolution provider, or to comply with any applicable laws or regulations
 * For the purpose of protecting the stability, safety and integrity of the registry, the TLD infrastructure, or the stability of the DNS
 * In order to avoid any civil or criminal liability on the party of the registry, its affiliates, subsidiaries, officers, directors, representatives, employees, contractors, and stockholders
 * In order to establish, assert or defend the rights of the registry or any third party
 * For any other reason provided for in either the Registry-Registrar Agreement or the Domain Name Registration Agreement


H. Preventive Safeguards

Desi Networks LLC will implement several additional mechanisms to prevent misuse of the TLD space, including the introduction of best practices, standards, and a comprehensive monitoring system.

H.1 Best Practices - Reducing Opportunities for Behaviors such as Phishing or Pharming

In our answer to Question 28 (ʹAbuse Prevention and Mitigationʹ) above, we described our strong anti-abuse program, which will shut down phishing sites and has provisions for rapid takedown of other domain name abuses. The system prompts notification of relevant registrars for rapid take-down action should phishing activity is identified. This program will deter bad actors from operating within the space by reducing the effectiveness of their attempts to initiate phishing domains, without infringing upon the rights of legitimate registrants. Since pharming is commonly accomplished by redirecting traffic at the recursive DNS level, mitigation is effective at the ISP level.

H.2 Monitoring of the TLD Zone for Malware

In case of an unexpectedly high volume of abuse reports regarding the proliferation of malware-infected websites in the TLD zone, the Company intends to investigate options for conducting regular analysis of websites hosted within the TLD zone, scanning for malware, then determining if there is malicious content that may infect visitors, and reporting to the affected registrar and registrant with remediation instruction.

H.3 Monitoring of the Success of Abuse Prevention Programs

Every six months, the Anti-Phishing Working Group (APWG) publishes its latest Global Phishing Survey, which is made publicly available on the Groups website. This study contains an analysis of phishing per TLD. The company will review the performance of our anti-abuse program by using the APWG reports and other metrics developed within the security community. The company notes that, according the APWGʹs available data for 2011, only around 12% of malicious phishing sites contained a brand name (or misspelled variant) in the relevant domain name, and that in the 2010-2011 data only 5,700 brand-targeted phishing sites were known worldwide. Accordingly, phishing represents a very small percentage of brand-targeted domain name registrations, and Desi Networks LLC believes its adopted anti-abuse best practices and monitoring policies will mitigate the risk of bad actors entering the TLD space.

H.4 Ongoing Rights Protection Resources

The maintenance of the new TLD space and the ongoing monitoring and RPM mechanisms will require dedicated resources and staff from both the registry service provider and the Registry Operator. KSregistry maintains a team of experts dedicated to these procedures, which draws from a wide pool of experience and includes engineers, developers, security, and enforcement personnel. The company additionally has in place state-of-the-art technical equipment and software systems, and is capable of implementing the proposed mechanisms.

The Registry Operator is fully staffed and ready to undertake the procedures outlined in this application and maintains a dedicated team for the oversight and management of the new TLD. Initially, at least one designated employee from The Company will be tasked with overseeing anti-abuse policies in the TLD as part of his⁄her duties. The Rights Protection Team will be supported by the law firm Rodenbaugh Law, of San Francisco, California, USA, and will further consult with Thomsen Trampedach GmbH. Mr. Mike Rodenbaugh is a UDRP Panelist with the Czech Arbitration Court and has extensive, first-hand knowledge of internet abuse mitigation. Thomsen Trampedach GmbH is a Swiss-based domain name consulting company with long-term involvement in ICANN, experience advising large brands in all domain name related issues, and is qualified to assist and advise DESIʹs on-hand staff. The team is further supported by Shaila Lakhani Ohri who has over 15 years of experience as an attorney, and has practiced law in the areas of corporate, securities, finance, employment and contracts. Shailas legal experiences include working at a law firm and as in house counsel for a finance company and a fortune 500 company.

KSregistry GmbH, as the registry backend provider of the KSregistry system (KSR), attaches great importance to the security of the entire registry infrastructure as well as business and customer data. Having more than ten years of experience in the domain business, Key-Systems has imparted extensive expertise about threats, possible vulnerabilities, and suitable countermeasures to its new subsidiary KSregistry GmbH. In case of an attack, the entire staff working on the KSR is trained to react quickly to any security issue that may arise. Distinct escalation plans with clear roles for each employee at KSregistry GmbH are defined for any possible incident. All team members have access to these plans at any time, according to their security clearance and role.

These plans and security rules are subject to a regular audit schedule and are documented in KSregistry GmbHʹs security policy, which includes the Registry Information Security Policy that covers the basic registry services. These services include, but are not limited to, the safety of the technical backend (covering items such as EPP and RDDS, DNS and DNSSEC policies, an ESCROW policy, SFTP, etc.).


A. Security Policy

KSregistry GmbH has established a security policy that contains the complete Registry Service Policy, covering the basic registry services. The Registry Service Policy is complimented by policies regarding technical, organizational, and personnel issues for:

- Network structure
- Network and system access
- Wireless networks
- Malware
- Setup of servers and client systems
- System and software updates
- Firewall and IDS
- Removable media
- DNSSEC
- Backups and ESCROW
- Physical Security
- Emergencies and Monitoring
- Continuity

Additional policies cover the behavior of employees concerning passwords, remote access, general communication and allowed tools and describe the handling of general procedures, audits, maintenance and monitoring. These policies are described in detail and attached to AGB question 30b. 

The security policy drafted by KSregistry GmbH is based on an extensive threat analysis and is thus tailored closely to the registry services. The introductory investigation of both common and rare security issues to the registry service and to the business in general is accompanied by examples with representative solutions and references to the corresponding policies. 

Based on the analysis, certain notable aspects of the policy, as determined by the threat analysis, are (a more complete description of the policy is detailed in answer 30b):

- To prevent unauthorized access to internal and external services as well as data of all possible security levels, all employees are only provided with the access rights needed for their assigned role and obliged to follow a strict policy regarding the strength, the periodical change and the storage of their password. Updates or new software installations can not be deployed by engineers themselves but must be managed by the change manager, who reviews the quality management reports and determines deployment procedures
- The administration is also split into different roles to prevent too much access being given to one single point. Access to servers is only possible with individual user rights, there are no superuser logins. All actions on the servers are logged and monitored. All servers are secured against external manipulation by physical separation and limitation to internal IP addresses as far as possible. The network is also separated into different layers depending on each layerʹs function and security level with each layer having its own security measures installed, including firewalls that check every request traveling from one layer to another
- The object data stored by KSregistry GmbH is secured in several, geographically distributed data centers with high security standards and which are constantly being backed up to prevent the danger of data loss and to guarantee continuity
- Denial of Service attacks are countered by measures appropriate to the target within the infrastructure. The DNS infrastructure of KSregistry GmbH is widespread and reliable to withstand attacks and is additionally secured against manipulation by DNSSEC. Attacks against other services are immediately identified by the Intrusion Detection System and repelled by the firewall and its corresponding rules
- Authorized registrars connect to services offered by KSregistry GmbH via encrypted communication. The EPP gateway can be only used with SSL or TSL and an additional check is made for correct authorization credentials for each connection. Each writing operation is logged which allows the reconstruction of every past transaction
- The registrarsʹ frequency of usage of the non-public services is generally monitored to prevent flooding and to guarantee reliable and stable services for all other registrars
- All software used by KSregistry GmbH, both developed in-house and acquired from third-party providers, is not deployed until it has been intensely tested by the quality management team. All registry systems, both hardware and software, are under constant monitoring from at least two different locations, and quick reaction times from the Administration Team, the ERT and the engineers are guaranteed 24 X 7 with defined emergency plans and procedures for all kinds of security issues or misbehavior of any component of the infrastructure. The monitoring is fully redundant on system and network level with different software solutions being used to additionally eliminate possible malfunction. Two leading enterprise monitoring solutions are used with the services running on separate hardware. All checks within the monitoring are continuously optimized by engineers and administrators, especially after software updates which are followed by determined check reviews

Regular audits of policies and procedures ensure a steady state of preparation for the entire team and allow for fast and appropriate escalation procedures. In case of an emergency incident, the administration will be very quickly mobilized by the monitoring and then follow the defined emergency procedures by either solving the problem immediately or activating the responsible roles within the company. Procedures and guidelines for any possible incident have been defined from the preceding threat analysis and describe:

- all required steps such as data restoration from backups or fail over to a secondary data center;
- the affected, involved, and responsible roles; and
- the necessary details for the concluding report

After the incident, the involved team members file an accurate report which they forward to the role responsible for the corresponding policies, who then checks the policies for complete coverage. The policies then undergo a review by the responsible team members and the Chief Security Officer (CSO) of KSregistry GmbH to determine necessary changes based on the report. In case of changes, the CSO is responsible for a final review and the supervision of the policy revisions. Policy reviews are also triggered prior to software updates, the introduction or change of processes, or changes to the infrastructure in general. This procedure guarantees that the policies are continuously up to date and that their coverage is complete. 

The beginning and end of employment of a team member also follow defined routines especially the assignation and termination of access rights, respectively. Each policy contains strict rules for enforcement and the measures taken in case of policy violation. The CSO of KSregistry GmbH holds the general responsibility for policy compliance. The security policy describes additional responsibilities of certain roles and the corresponding policies and lists all affected roles within the company. 

The KSregistry GmbH develops these policies alongside the ISO⁄IEC 27001 requirements, accompanied by the code of practice given in the ISO⁄IEC 27002 (source: http:⁄⁄www.iso.org⁄iso⁄catalogue_detail?csnumber=42103). More details can be found in section B. The backup strategy is a TIER 4 strategy following the best practice guide by IBM redBooks (source: http:⁄⁄www.redbooks.ibm.com⁄abstracts⁄tips0340.html?Open).


B. Independent Assessment

As a merchant using credit card payment systems, KSregistry GmbH is obligated to meet the requirements defined by the Payment Card Industry Data Security Standard (PCIDSS). Validation of compliance is done annually by an externally Qualified Security Assessor. For KSregistry GmbH this validation is provided by the IT security experts from Acertigo AG located in Stuttgart, Germany. Security requirements of the standard are reviewed using a Self Assessment Questionnaire covering the following control objectives: build and maintain a secure network, protect cardholder data, maintain a vulnerability management program, implement strong access control measures, regularly monitor and test networks, and maintain an information security policy. The review of the questionnaire is accompanied by vulnerability scans for all systems which are also carried out by Acertigo quarterly. The resulting reports document a constant security level and certify compliance to the PCIDSS standard, thereby also meeting the security requirements for the registry services. 

The PCI security scans facilitate the identification of vulnerabilities and misconfigurations of web sites and all infrastructures with public services including, for example, mailservers and internet access for employees. Acertigo determines active IP addresses and services by probing a complete list of external IP addresses relevant to the PCIDSS (provided by KSregistry GmbH) and also ensures that only services intended for external use are accessible. The list includes web, application, and mail servers, as well as domain name servers and virtual hosts. Acertigo also scans for open IP addresses outside the scope given by KSregistry GmbH to ensure the integrity of the scans. The IDS of the KSR is configured to allow access to all systems for the IP addresses from which the scans originate.

Since the introduction of the PCIDSS, KSregistry GmbH has constantly been compliant to the standard. The quarterly scan reports are reviewed by KSregistry GmbH administrators and the chief security officer and necessary measures are taken immediately. In addition to the benefits for the security of KSregistry GmbHʹs proprietary software, the scans also help to keep third-party software up to date and add another level of malware detection to the already established detection system.

While its policies already cover a part of the ISO⁄IEC 27001 standard and are are compliant to it, the KSregistry GmbH is also working towards an official certification. This implies the implementation of an Information Security Management System (ISMS) compliant to ISO⁄IEC 27001 and includes changes to and extensions of the security policies and procedures. Part of the requirements of the ISMS are periodic internal audits which will be executed by the ʹsafe and secure systems – evaluation and verificationʹ department of the DFKI GmbH (the German Research Center for Artificial Intelligence), the leading German AI research institute and an officially approved ISO⁄IEC 27001 auditor. The DFKI GmbH will also certificate the complete compliance to ISO⁄IEC 27001 until the end of 2012 and subsequently provide periodical assessment reports.


C. Commitments

KSregistry GmbH, the registry backend technology provider for the domain registrar Key-Systems, benefits from Key-Systemsʹ more than ten years of experience in the domain business and its associated processes (with some team members working even longer in this field). As an ICANN accredited registrar and member in several work groups and technical boards representing a range of registries, Key-Systems is developing all systems in keeping with the requirements of registrars, registrants, and brandowners worldwide. 

These requirements are covered by our security policy in general and are implemented in certain policies as our registry service policy or other specifically mentioned policies. The customers of KSregistry GmbH can rely on:

- Secure storage and handling of confidential customer data, with clearly defined access rules for virtual access in our “Network and System Access Policy” and physical access in our “Physical Security Policy”
- All objects are stored in one secured, central registry database as KSregistry GmbH supports a thick registry system
- A reliable and widespread DNS system, additionally secured by DNSSEC with its rules being defined in our “DNSSEC Policy”
- Secure communication from the registrants, over the registrars to the registry
- A guarantee that no changes to the registry technology will be made if these changes bear a risk of malfunction, as described in our specific “System and Software Update Policy”

KSregistry GmbH will also enforce the policies distributed on all levels of usage of the registry system. The complete staff is trained and audited in every policy the team member is affected by and constantly aware of the great importance of a secure system.

The registry operator is obligated to inform the registrars about all important agreements, general terms and conditions, events and notifications, and must also include these in its own registration agreement that is passed to the registrants. KSregistry GmbHʹs extensive documentation of the registry system interfaces such as EPP is provided as white-label and can be forwarded from the registry to registrars or even registrants if desired.

Accredited registrars should nominate persons who are authorized to contact the KSregistry GmbH 24⁄7 support in urgent emergency cases. These individuals have to prove their identity with a previously agreed passphrase. It is the registrars responsibility to provide support for their registrants and to decide if support requests have to be escalated to the registry at any time benefiting from KSregistry GmbHs Support described above.


D. gTLD Specific

KSregistry GmbH guarantees a high level of security that is also reviewed and refined on a regular basis. The security policies and procedures comply with the general requirements of a technical registry operator with no need for deviation for DOT DESI. If any changes to the description of DOT DESI should occur in the future, KSregistry GmbH is able to rapidly adapt new policies and procedures as required.


E. Resources and Roles

E.1 Trusted Roles

Key-Systems GmbH has gathered experience in various roles in the domain business for more than ten years and has access to extensive knowledge in the domain business. This deep industry knowledge and experience has also been transferred to KSregistry GmbH, the technical provider of the KSregistry system (KSR) and is evident in many trusted persons serving in different roles throughout the company.

All employees, contractors, and consultants that have access to or control of the KSregistry system are regarded as trusted persons.

The following Trusted Roles are used for managing the KSR solution:

- Security Role: Chief Security Officer (CSO)
- Designated Engineering Role
- System Administration Role
- Security Administrator Role 
- DNS⁄DNSSEC Role
- Operational Role
- Support Role
- Quality Management Role
- Change Management ⁄ Project Management Role 
- Financial ⁄ Controlling Role
- Legal Role

Each role is staffed with multiple human resources for backup and capacity purposes.

Prior to employment in a Trusted Role, KSregistry GmbH performs the following background checks on a prospective candidate:

- Criminal Records Bureau check
- Verification of previous employment
- Check of professional references

Complete role descriptions are given in the security policy in answer 30b.

E.2 Project Resources

The table in fig. Q30a_Figure1.pdf shows how the roles described above are planned for the SRS system. All resources at KSR are dedicated to the registry business. The calculations differ between the project phase and the years after the operational start. The project phase requires more resources as there is much planning, managing, and development required. All resources are engaged in the domain industry only and are experts in their field.

However, as the resources are shared among the TLDs operated through KSR and are not dedicated exclusively to one SRS project, the columns in the attached figure contain the number of human resources available for this role and the percentage of time those people are working for this specific string. This percentage is the guaranteed time the resources are allocated to each SRS project.


F. List of attachments

- Q30a_Figure1.pdf