Application number: 1-875-24017 for Merchant Law Group LLP

Merchant Law Group LLP

100 - 2401 Saskatchewan Drive
Regina SK S4P 4H8
CA

+1 306 359 7777

+1 306 522 3299

Mr. Brendon James Ralfe

IT Manager

+1 306 359 7777

bralfe@merchantlaw.com

Mr. Evatt Francis Anthony Merchant

Director

+1 306 227 2222

emerchant@merchantlaw.com

Limited Liability Partnetship

The Partnership Act Saskatchewan
http:⁄⁄www.justice.gov.sk.ca⁄Partnership-Act

Not Available

Evatt Francis Anthony Merchant Jr.
Director
John Eric Joshua Merchant
Director

Evatt Francis Anthony Merchant Jr.
Director
John Eric Joshua Merchant
Director

Merchant Law Professional Corporation
Not Applicable

club

Not Available

The string ʺclubʺ consists of 4 ASCII characters, each of which currently occurs as part of existing and operational gTLD strings. We are not aware of any possible rendering problems concerning the string ʺclubʺ.
We are aware of the issue of universal acceptability and accept that some incorrectly configured third-party software may consider ʺclubʺ to be an invalid string, in the same way that other TLDs such as ʺ.INFOʺ and “.MUSEUMʺ are also at times considered ʺinvalid.ʺ MLG and CentralNic will work to raise awareness of the issue of universal acceptance of .CLUB and other new gTLDs. CentralNic has previously contributed to similar efforts, such as by publication of TLD Verification code for the PHP programming language.
We are aware that a significant fraction of queries sent to the DNS root servers are for invalid TLDs such as ʺ.LOCALʺ or ʺ.LANʺ, and that the delegation of these TLDs could cause previously undiscovered configuration errors to result in operational problems for other operators. We have reviewed the research in this area, including the SAC 045 report from ICANNʹs Security and Stability Advisory Committee, data from the Day In The Life of the Internet project, and other sources, and are not aware of any significant volume of invalid root server queries related to .CLUB. Therefore we are confident that the delegation of this string will not result in any operation problems for Internet users.

Question No. 18(a)

.CLUB Top Level Domain


Mission of the .CLUB TLD

The mission of the .CLUB TLD is to be the designated namespace for all individuals, groups, businesses, organizations, and other entities that engage in commercial or non-commercial activities related to the creation, promotion, and ongoing existence of clubs of all varieties.


18(a).2 Value Proposition of the .CLUB TLD

The .CLUB TLD is the online standard for clubs of all varieties, as well as club related products and services.


18(a).3 The Purpose of .CLUB

The .CLUB TLD will be an Internet space that facilitates the creation and ongoing function of the wide variety of operations and organizations that can be called ‘clubs’. This will be accomplished by means of, but not limited to, websites, social networks, email, and other technologies. MLG will be adapting and broadening the scale and scope of these activities to ensure the successful launch of the .CLUB TLD.

MLG has a plan to develop, build, and sustain a unique value proposition for the .CLUB TLD, and a marketing strategy to ensure that the maximum number of people and organizations are aware of how a .CLUB domain can enhance their value proposition or other goals and purposes. A .CLUB domain will provide a competitive advantage to registrants through a multitude of scenarios. MLG’s delivery of the .CLUB value proposition will provide an additional incentive for registrants acquiring .CLUB domains to leverage their resources and capabilities and develop their unique place on the World Wide Web.

MLG believes in being nimble, flexible, and well funded, with a long term vision for the .CLUB TLD. We have the ingenuity and partnerships to market and develop .CLUB in a manner that:
(1) quickly establishes a base of .CLUB registrants that will immediately utilize their .CLUB domain name to provide Internet users with club related information, products, and services;
(2) preserves the integrity and promotes the development of various country and region specific .CLUB domains through accredited organizations;
(3) establishes customers who will immediately derive value from a .CLUB TLD;
(4) protects registered trademark holders without undue cost to them;
(5) builds and protects the value proposition of the .CLUB TLD;
(6) ensures the continued development of the .CLUB TLD through competition and innovation; and
(7) leverages assets, resources, and competencies to effectively and efficiently establish a registration base from target registrant markets and all other members of the global community and public who can benefit from an ever expanding .CLUB TLD.

MLG affirms that the Internet is a transformative technology that continues to empower people around the globe, spur innovation, facilitate trade and commerce, and enable the free and unfettered flow of information. MLG envisions .CLUB domains to be registered and used by anyone who is interested in communicating about clubs or providing club related products and services. .CLUB domain registrations will not be restricted and everyone will have an opportunity to register a .CLUB domain name.

The introduction of a .CLUB TLD offers numerous benefits and opportunities to anyone that engages in activities related to the creation or ongoing existence of a club of any sort, as well as benefits and opportunities to the online community in general. MLG will work closely with CentralNic and Internet registrars to implement a focused marketing strategy with an emphasis on ensuring that the existing club community adopts and builds on the .CLUB foundation in addition to attracting new and innovative registrants to the TLD. MLG is committed to fostering competition, consumer trust, and consumer choice within the .CLUB TLD Internet space and the broader global marketplace. MLG and its partners understand the intrinsic value, rarity, and non-imitability of the .CLUB TLD and have the expertise, strategy, and capacity to ensure the successful establishment and growth of the .CLUB TLD. Through our goals, policies, and operating rules, MLG is committed to managing the .CLUB TLD in a manner that maximizes benefits and mitigates costs for all stakeholders.

Question No. 18(b)

18(b).1 Goal

The goal of the .CLUB TLD is to provide a distinct online presence for all individuals, groups, businesses, organizations, and other related entities that engage in activities related to the creation, promotion, and ongoing existence of clubs in all their varieties. 


18(b).2 Innovation, Competition, and Differentiation

An ample supply of relevant .CLUB domains will be made available for interested persons to claim within the .CLUB domain space. Currently, there is no generic TLD specifically devoted to clubs. Instead, content related to clubs online is dispersed among a variety of existing generic and country-code TLDs without the benefit of a unifying string.

Consumers have changed. The Internet is now the vehicle through which consumers find information, products, and services of all varieties. A .CLUB TLD will help clubs and club related organizations to capitalize on the opportunities provided by the Internet. A .CLUB TLD presents an opportunity for all individuals, groups, businesses, organizations, and other related entities that engage in activities related to clubs to garner a more effective and differentiated online presence.

The .CLUB TLD will be a specialized domain space which will be developed into the online standard for clubs and club related products and services.

The .CLUB TLD is a distinctive, succinct, and memorable TLD that epitomizes club related industries and communities across numerous different languages. MLG’s vision is to make .CLUB domain names prevalent among people, entities, and organizations that are clubs or that provide club related products, services, and information.

Many clubs and related organizations already have some online presence. However, a .CLUB TLD allows for greater differentiation on the Internet, simplifies users’ choice when searching for and interacting with club related content online, and offers new benefits and opportunities to anyone that engages in club related activities. 

A .CLUB TLD will create a level playing field for club related organizations online by providing a new, distinct channel for the consumption of club related content by consumers. A .CLUB domain name will provide an enhanced platform for individuals and groups to broadcast and communicate club information to an online population which now numbers over two billion.

The opportunity to carry out our mission and deliver our value proposition will always be contingent upon providing benefits that matter to our registrants, Internet users, and the online population. To that end, MLG will strive to ensure that the .CLUB TLD provides the best value for creating and developing a club related online presence. MLG’s long term strategy is to ensure that .CLUB domains become a “must-have” for all individuals, groups, businesses, organizations, and related entities that engage in activities related to the creation, promotion, or ongoing existence and operation of clubs of all varieties.

A .CLUB domain will be the “best bang for the buck” registration by providing the best value for creating and developing a distinct, clear, and credible club related online presence. MLG will ensure that .CLUB domains provide the best quality-to-price ratios by offering competitive registration pricing and leveraging the core competencies of MLG and CentralNic.

MLG believes that .CLUB registrants will offer a variety services and content related to clubs. .CLUB’s target markets are broad enough to maintain a financially viable TLD and distinct enough that the .CLUB TLD will not become ‘just another .info’. A .CLUB TLD will provide a unique space on the Internet for club information and services. It will allow anyone to register a domain name and use that online space to provide information, products and services. MLG’s vision for the .CLUB TLD mirrors the Internet’s growth as a transformative technology that enables the free and unfettered flow of information.

The introduction of the .CLUB TLD to the Internet will increase competition, provide opportunities for differentiation, and promote innovation.

The .CLUB TLD will provide an alternative to the current TLDs by focusing on clubs and catering specifically to all individuals, groups, businesses, organizations, and related entities that engage in activities related to the clubs. .CLUB will serve as a force for differentiation as a distinctive namespace that simplifies users’ choice to interact and communicate about clubs. MLG expects that users will be able to navigate to .CLUB domains and subdomains intuitively, saving them time and resources.

The .CLUB TLD will introduce more relevant domain names into the Internet domain space. This will increase competition which should compel other TLDs to increase the quality-to-price ratios of their online presence offerings.

MLG hopes that the use of .CLUB domains will increase differentiation on the Internet. It is expected that the .CLUB TLD will substantially meet the online needs of its registrants. One of MLG’s goals with the introduction of the .CLUB TLD is to ensure that our target market registrants do not have to engage in unnecessary defensive registrations with other generic TLDs and country code TLDs. MLG will be marketing and branding the .CLUB TLD using strategies that continuously support and enhance the .CLUB TLD value proposition. MLG will continually invest in the .CLUB TLD brand to ensure that .CLUB registrants have a strong incentive to maintain their websites with substantive, regularly updated content that will lead to unique and sustained web traffic.

Currently it is difficult to find relevant and easily recognizable domain names from existing TLDs. Even if one is found, pricing can be prohibitive because the desired domain name is often only available on the secondary market. The .CLUB TLD will allow people, businesses, organizations and entities with an interest in communicating about clubs to register a relevant domain name immediately and the freedom to develop as many uses for their .CLUB online presence as they can imagine. An ample supply of relevant, generic .CLUB domain names will be available immediately and the innovative uses for these domain names will pay dividends for the online community in ways that are not currently quantifiable.


18(b).3 User Experience

The .CLUB TLD will enhance users’ Internet experience.

The .CLUB TLD will function with leading-edge technologies and adopt business practices that ensure a trustworthy and positive user experience. MLG will work with registrants and relevant stakeholders through a .CLUB Advisory Board that will continuously garner feedback, advice, and suggestions and when appropriate, suggest practices, technology and policies that help meet and exceed the expectations of .CLUB TLD users. One of MLG’s goals for the .CLUB TLD is to ensure that the .CLUB online infrastructure and aggregation of websites and services encourages Internet users to interact online more frequently and rely on .CLUB domains for all their club related needs and interests.

MLG intends for users to perceive the .CLUB TLD as a trustworthy platform of online club related content. MLG intends to adopt industry leading standards and policies to provide a safe and legitimate Internet space, enhance user experience by mitigating security-associated risks as further described in our responses to Questions 26, 27, 28 and 29.

MLG intends to adopt policies that develop the .CLUB TLD in a manner that provides an easily navigable and predictable domain name space--for example, ‘geographicalname.club for localized websites, and ‘product.club’ for relevant club related content. All of this will enhance users’ experience online by lessening confusion when browsing and interacting online.


18(b).4 Registration Policies

The .CLUB TLD will adopt contemporary registration policies.

The .CLUB TLD will be open and unrestricted, allowing anyone to select an appropriate .CLUB domain name for their own legitimate purposes. Illegal uses of .CLUB domain names will not be tolerated. MLG will implement an Acceptable Use Policy as further described in response to Question 28, and will implement the UDRP, URS and all other ICANN-required rights protection mechanisms. Further, MLG intends to implement additional rights protection mechanisms as described in response to Questions 28 and 29. Registrants offering services not related to clubs will have lessened interest in the .CLUB domain because .CLUB has limited intuitive appeal outside the realm of a club. The price point of .CLUB will help ensure that .CLUB domains are not abused but are competitive against other TLDs. 


18(b).5 Privacy Policies

The .CLUB TLD will adopt contemporary privacy policies.

We recognize and affirm the need for security of private and personal information on the Internet. We also recognize that the operation of a TLD necessarily involves the collection of personal information. MLG desires users to perceive the .CLUB TLD 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. We intend to minimize any risks to our registrants by maintaining industry standard protocols for the protection of the personal and confidential information of registrants. With respect to Whois data, MLG intends to comply with ICANN policies and otherwise to ensure that complete and accurate Whois information is readily accessible for every .CLUB domain name. Moreover, MLG intends to offer additional Whois verification of each registrant’s email address as discussed in response to Questions 26, 28 and 29. Still further, MLG and its partners intends to scan the websites in the .CLUB TLD periodically for malware infusion, and take appropriate action for the benefit of Internet users.

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

Our approach to privacy on the Whois service is two-fold:
1. Our Whois service is rate limited to prevent ʺdictionaryʺ attacks where attackers try to obtain large volumes of Whois records by making repeated queries.
2. Contact objects associated with natural (as opposed to legal) persons can ʺopt outʺ of display in the Whois service, though their information is still made available via the secure Searchable Whois Service (SWS). Additional details can be found in our response to Question 26.


18(b).6 Outreach and Communications

MLG will engage in extensive outreach initiatives and communications campaigns for the .CLUB TLD.

The use of .CLUB domains will effectively communicate the availability of the TLD to the intended audience, not only for the specific purpose at hand but also for more general or intuitive purposes. For example, a user who first sees an advertisement for ‘productname.club’ may later directly navigate to ‘company.club’ to search for other products of the producer. In addition to MLG’s own specific efforts to communicate the new TLD to its intended audience, MLG expects that audience and relevant media to further communicate the TLD as they discover the many domain names, websites and services located at .CLUB domains. As the first generic TLD targeted to clubs of all varieties, MLG expects a substantial degree of publicity and word-of-mouth marketing within its target markets.

Question No. 18(c)

18(c).1 Social Cost Minimization

 The .CLUB TLD will minimize social costs.

The .CLUB TLD will function with leading-edge technologies and adopt business practices that ensure a trustworthy and positive user experience. MLG will work with registrants and relevant stakeholders through a .CLUB Advisory Board that will continuously garner feedback, advice, and suggestions and when appropriate, suggest practices, technology and policies that help meet and exceed the expectations of .CLUB TLD users. One of MLG’s goals for the .CLUB TLD is to ensure that the .CLUB online infrastructure and aggregation of websites and services encourages Internet users to interact online more frequently and rely on .CLUB domains for all their club related needs.

MLG intends for users to perceive the .CLUB TLD as a trustworthy platform of online information related to clubs. MLG will adopt industry leading standards and policies to provide a safe and legitimate Internet space, and enhance user experience by mitigating security-associated risks as further described in our responses to Questions 26, 27, 28 and 29.

MLG will adopt policies that develop the .CLUB TLD in a manner that provides an easily navigable and predictable domain name space. All of this will enhance users’ experience online by lessening confusion when browsing and interacting online.


18(c).2 .CLUB Advisory Council

A volunteer .CLUB Advisory Council will be established.

We recognize that there are significant interests at stake in the .CLUB TLD. We believe that members of club related industries and other relevant stakeholders, including Internet users in general, will have suggestions and concerns regarding the continued operation and growth of the .CLUB TLD. We believe that these groups should be heard. MLG will establish a non-commercial volunteer .CLUB Advisory Council and additional web-based feedback mechanisms for interested parties. This combination will provide a foundation for all interested parties to express their thoughts and ideas, and will help us develop policies so that the intended benefits of the .CLUB TLD are realized and maximized.

The Advisory Council will be made up of representatives from a broad spectrum of associations, organizations and institutions who have and will indicate an interest in the .CLUB TLD. The Council will be invited to provide MLG with feedback on specific issues as well as valuable advice to the .CLUB management team. These issues may range from policy to the introduction of new services, and the Council will serve as a resource for management as it seeks to incorporate the broadest possible input for important decisions.


18(c).3 Feedback Website

A .CLUB TLD dedicated feedback website will be established.

Members of the broad Internet community should have a means of learning about and commenting on initiatives underway with the .CLUB TLD. Similarly, .CLUB management should be able to tap into the community for input on important issues. To facilitate this communication, MLG will establish a .CLUB feedback website to both inform and solicit input from interested parties. Key elements of the site will include (1) a news feed for up to date information on the development of .CLUB, (2) Discussion forums for posting comments and other items of interest to .CLUB, (3) A polling capability in order to assess interests or needs of the community from time to time.


18(c).4 Domain Name Contention

The .CLUB TLD will adopt current domain name contention policies.

.CLUB will comply with all of ICANN’s requirements for implementation of rights protection mechanisms, including the Trademark Clearinghouse, the Uniform Domain-Name Dispute Resolution Policy, and the Uniform Rapid Suspension Policy. MLG will offer additional rights protection mechanisms as described in response to Questions 26, 28 and 29.

MLG will offer a phased launch, consistent with many prior generic TLD domain name launches. First, a Sunrise Period will be offered as required by ICANN, for trademark holders to register domain names that correspond to their marks. If there is more than one qualified Sunrise applicant, then they will be invited to participate in an auction to select the registrant of the contested name. After the close of the Sunrise Period, MLG will conduct a Premium Name Availability Period, accepting applications for registrations of any available .CLUB domain names. In the event of more than one applicant contending for any domain during this Period, all such applicants will be invited to participate in an auction to select the registrant of the contested name. After the Premium Name Availability Period, MLG will make unreserved names generally available for open registration by any interested person or entity, on a first-come⁄first-served basis.

Any changes to pricing plans or other .CLUB policies will be announced well in advance via e-mail to the registered owner of any domains, and via public announcement to all registrars that offer .CLUB registrations – all as required by the Registry Agreement. MLG also will make contractual commitments to registrants regarding the magnitude of price escalation upon renewal. 

No

Not Available

No

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.

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

1. 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];

2. 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];

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

4. 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 MLG’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. The lists previously noted, will be regularly monitored for revisions and the reserved list, both within the registry and publicly facing, will continually be updated to reflect any changes.

In addition to these requirements, CentralNic is able to support the wishes of MLG in regards to the reservation of additional terms on a case by case basis. The .CLUB 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 .CLUB TLD registry reserved list:

1. Attempts to register reserved Domain Names will be rejected;

2. Whois queries for listed Domain Names will receive responses indicating their reserved status;

3. Reserved names will not appear in the TLD zone file; and

4. DNS queries for reserved domain names will result in an NXDOMAIN response.

22.1 Procedures for Release of Geographic Names

We understand that if and when MLG wishes to release any reserved names at a later date, this will require further approval from ICANN.

In order to release reserved names, MLG will have in place a special release mechanism, described below.

Consistent with the .info release of geographic names, as referenced in the New GTLD Application, MLG will present the GAC Representatives with an option, at no charge, of objecting to release and use of any initially reserved names at the second level. The at-no-charge objection will remain an option for the GAC Representatives, in compliance with current ICANN requirements regarding geographic reserved names.

Generally, it is extremely unlikely that MLGʹs authorized use of any countryname.club or cc.club domain name could be confusing to users, or otherwise offensive to any country. To the extent that use of any .CLUB domain was ever deemed confusing or offensive, MLG will have a strong desire to resolve the situation quickly and respectfully to any affected country’s sovereign interests. At minimum, MLG will ensure that its designated abuse contact is aware of the additional sensitivities that may potentially arise with respect to use of cc.club or countryname.club domains, such that any complaints of this nature are prioritized accordingly.

Question No. 23
MLG has chosen CentralNic as the registry infrastructure provider for the .CLUB TLD (see Appendix 23.1 for the acceptance letter from CentralNic.) Any information regarding technical and operational capability of the proposed TLD registry (answers to questions 23 – 44) therefore refers to CentralNic’s registry infrastructure systems. 
MLG and CentralNic confirm that all registry services explained below are engineered and will be provided in compliance with the new gTLD Registry Agreement, ICANN consensus policies (such as Inter-Registrar Transfer Policy and AGP Limits Policy), and applicable technical standards. Except for the registry services described herein, no other services will be provided by the Registry that relate to (i) receipt of data from registrars concerning registrations of domain names and name servers; (ii) provision to registrars of status information relating to the zone servers for the TLD; (iii) dissemination of TLD zone files; (iv) operation of the Registry zone servers; or (v) dissemination of contact and other information concerning domain name server registrations in the TLD as required by the Registry Agreement. 
Except as described herein, there are no other products or services that the Registry Operator will provide by reason of (i) the establishment of a Consensus Policy, or (ii) MLG being designated as the Registry Operator. 
Any changes to the registry services that may be required in the course of MLG operating the registry will be addressed using rules and procedures established by ICANN, such as the Registry Services Evaluation Policy. 
MLG proposes to operate the following registry services utilizing CentralNicʹs registry system: 

23.1. Receipt of Data From Registrars 
CentralNic will operate a Shared Registry System (SRS) for the TLD. The SRS consists of a database of registered domain names, host objects, and contact objects accessible via an Extensible Provisioning Protocol (EPP) interface and a web based Registrar Console. Registrars will use these interfaces to provide registration data to the registry. 
The SRS will be hosted at CentralNicʹs primary operations centre in London, UK. The primary operations centre comprises a resilient, fault-tolerant network infrastructure with multiple high quality redundant links to backbone Internet carriers. The primary operations centre is hosted in Level 3ʹs flagship European data centre and boasts significant physical security capabilities, including 24x7 patrols, CCTV, and card-based access controls. 
CentralNicʹs existing SRS system currently supports more than 250,000 domain names managed by over 1,500 registrars. CentralNic has effective and efficient 24x7 customer support capabilities to support these domain names and registrars, and this capability will be expanded to meet the requirements of the .CLUB TLD and provide additional capacity during periods of elevated activity (such as during Sunrise periods). 
The SRS and EPP systems are described more fully in §24 and §25. The Registrar Console is described in §31. 
EPP is an extensible protocol by definition. Certain extensions have been put in place to comply with the new gTLD registry agreement, ICANN Consensus Policies, and other technical standards, as follows: 
1. Registry Grace Period Mapping - compliant with RFC 3915 
2. DNSSEC Security Extensions - compliant with RFC 5910 
3. Launch Phase Extension - will be only active during the Sunrise phase, before the SRS opens for the general public. The extension is compliant with the current Internet Draft https:⁄⁄github.com⁄wil⁄EPP-Launch-Phase-Extension-Specification⁄blob⁄master⁄draft-tan-epp-launchphase.txt 
More information on EPP extensions is provided in §25. 
The SRS will implement and support all ICANN Consensus Policies and Temporary Policies, including: 
• Uniform Domain Name Dispute Resolution Policy 
• Inter-Registrar Transfer Policy 
• Whois Marketing Restriction Policy 
• Restored Names Accuracy Policy 
• Expired Domain Deletion Policy 
• AGP Limits Policy 

23.2. Provision to Registrars of Status Information Relating to the Zone Servers 
CentralNic will operate a communications channel to notify registrars of all operational issues and activity relating to the authoritative DNS servers for the .CLUB TLD. This includes notifications relating to: 
1. planned and unplanned maintenance; 
2. denial-of-service attacks; 
3. unplanned network outages; 
4. delays in publication of DNS zone updates; 
5. security incidents such as attempted or successful breaches of access controls; 
6. significant changes in DNS server behaviour or features; and
7. DNSSEC key rollovers. 
Notifications will be sent via email (to preregistered contact addresses), with additional notifications made via an off-site maintenance site and via social media channels. 

23.3. Dissemination of TLD Zone Files 
CentralNic will make TLD zone files available via the Centralized Zone Data Access Provider according to specification 4, section 2 of the Registry Agreement. 
MLG will allow any Internet user to enter into an agreement allowing the user to access an Internet host server or servers designated by MLG and download zone file data. The agreement will be standardized, facilitated and administered by a Centralized Zone Data Access Provider (the “CZDA Provider”). MLG will provide access to zone file data using the file format described in Section 2.1.4 of Specification 4 of the New gTLD Registry Agreement. 
MLG, facilitated by CZDA Provider, will request each user to provide it with information sufficient to correctly identify and locate the user. Such user information will include, without limitation, company name, contact name, address, telephone number, facsimile number, email address, and the Internet host machine name and IP address. 
MLG will provide the Zone File FTP (or other Registry supported) service for an ICANN-specified and managed URL for the user to access the Registry’s zone data archives. MLG will grant the user a non-exclusive, non-transferable, limited right to access MLG’s Zone File FTP server, and to transfer a copy of the top-level domain zone files and any associated cryptographic checksum files no more than once per 24 hour period using FTP or other data transport and access protocols that may be prescribed by ICANN. 
MLG will provide zone files using a sub-format of the standard Master File format as originally defined in RFC 1035, Section 5, including all the records present in the actual zone used in the public DNS. 
MLG, through CZDA Provider, will provide each user with access to the zone file for a period of not less than three (3) months. MLG will allow users to renew their Grant of Access. 
MLG will provide (and CZDA Provider will facilitate) access to the zone file to users at no cost. 

23.4. Operation of the Registry Zone Servers 
The TLD zone will be served from CentralNicʹs authoritative DNS system. This system has operated at 100% service availability since 1996 and is a secure and stable platform for domain resolution. Partnering with Community DNS, CentralNicʹs DNS system includes nameservers in more than forty cities on five continents. The DNS system fully complies with all relevant RFCs and all ICANN specifications, and has been engineered to ensure resilience and stability in the face of denial-of-service attacks, with substantial overhead and geographical dispersion. 
The DNS system is described further in §35. 

23.5. Dissemination of Contact and Other Information Concerning Domain Name Server Registrations 
CentralNic will operate a Whois service for the TLD. The Whois service will provide information about domain names, contact objects, and name server objects stored in the Shared Registry System via a port-43 service that complies with RFC 3912. The Whois service will permit interested parties to obtain information about the Registered Name Holder, as well as Administrative, Technical and Billing contacts for domain names. The Whois service will return records in a standardised format which complies with ICANN specifications. 
CentralNic will provide access to the Whois service at no cost to the general public. 
CentralNicʹs Whois service supports a number of features, including rate limiting to prevent abuse, privacy protections for natural persons, and a secure Searchable Whois Service. The Whois service is more fully described in §26. 
Should ICANN specify alternative formats and protocols for the dissemination of Domain Name Registration Data, CentralNic will implement such alternative specifications as soon as reasonably practicable. 

23.6. DNSSEC 
The TLD zone will be signed by DNSSEC. CentralNic uses the award-winning signer technology from Xelerance Corporation. Zone files will be signed using NSEC3 with opt-out, following a DNSSEC Practice Statement detailed in §43. 
CentralNicʹs DNSSEC implementation complies with RFCs 4033, 4034, 4035, and 4509 and follows the best practices described in RFC 4641. Hashed Authenticated Denial of Existence (NSEC3) will be implemented, which complies with RFC 5155. The SRS will accept public-key material from child domain names in a secure manner according to industry best practices (specifically the secDNS EPP extension, described in RFC 5910). CentralNic will also publish on its website the DNSSEC Practice Statements (DPS) describing critical security controls and procedures for key material storage, access and usage for its own keys, and secure acceptance of registrants’ public-key material. CentralNic will publish its DPS following the format described in the “DPS-framework” Internet Draft within 180 days of that draft becoming an RFC. 

23.7. Rights Protection Mechanisms 
Applicant will provide all mandatory Rights Protection Mechanisms that are specified in the Applicant Guidebook (version 11 January 2012), namely Trademark Claims Service (section 6.1) and Sunrise service (section 6.2). All the required RPM-related policies and procedures such as UDRP, URS, PDDRP, and RRDRP will be adopted and used in the TLD. More information is available in §29. 
In addition to such RPMs, MLG may develop and implement additional RPMs that discourage or prevent registration of domain names that violate or abuse another party’s legal rights. MLG will include all ICANN mandated and independently developed RPMs in the registry-registrar agreement entered into by ICANN-accredited registrars authorised to register names in the TLD. MLG will implement these mechanisms in accordance with requirements established by ICANN for each of the mandatory RPMs set forth in the Trademark Clearinghouse. 
The ʺLaunchPhaseʺ EPP extension (described above) will be used to implement an SRS interface during the Sunrise period for the TLD. Depending on the final specification for the Trademark Claims Service (details of which have not yet been published), an additional EPP extension may be required in order to implement this service. If this is necessary, the extension will be designed to minimise its effect on the operation of the SRS and the requirements on registrars, and will only be in place for a limited period while the Trademark Claims Service is in effect for the TLD. 

23.8. Registrar Support and Account Management 
CentralNic will leverage its 16 years of experience of supporting over 1,500 registrars to provide high-quality 24x7 support and account management for the .CLUB TLD registrars. CentralNicʹs experienced technical and customer support personnel will assist the TLD registrars during the on-boarding and OT&E process, and provide responsive personal support via email, phone, and a web based support ticketing system. 

23.9. Reporting to ICANN 
Applicant and CentralNic will compile and transmit a monthly report to ICANN for the .CLUB TLD. This report will comply with Specification 3 of the New gTLD Registry Agreement. 

23.10. Personnel Resources of CentralNic 
The technical, operations, and support functions of the registry will performed in-house by CentralNicʹs personnel. These personnel perform these functions on a full-time basis. 

23.10.1. Technical Operations 
Technical Operations refers to the deployment, maintenance, monitoring, and security of the registry system, including the SRS and the other critical registry functions. Technical Operations staff design, build, deploy, and maintain the technical infrastructure that supports the registry system, including power distribution, network design, access control, monitoring and logging services, and server and database administration. Internal helpdesk and incident reporting is also performed by the Technical Operations team. The Technical Operations team performs 24x7 monitoring and support for the registry system and mans the Network Operations Centre (NOC) from which all technical activities are co-ordinated. 
CentralNic will maintain a Technical Operations team that will be responsible for managing, developing and monitoring the registry system for the TLD on a 24x7 basis. This teams consists of the following positions: 
• Senior Operations Engineer(s) 
• Operations Engineer(s) 
• Security Engineer 

23.10.2. Technical Development 
The Technical Development team develops and maintains the software which implements the critical registry functions, including the EPP, Whois, Zone file generation, data escrow, reporting, backoffice, web-based management systems (intranet and extranet), and open-source registrar toolkit software. All critical registry software has been developed and maintained in-house by this team. 
CentralNic will maintain a Technical Development team responsible for maintaining and developing the registry software which will support the TLD, consisting of the following positions:
• Senior Technical Developer x 2 
• Technical Developer x 3 

23.10.3. Technical Support 
Technical Support refers to 1st, 2nd, and 3rd line support for registrars and end-users. Areas of support include technical support for systems and services, billing, and account management. Support personnel also deal with compliance and legal issues such as UDRP and URS proceedings, abuse reports, and enquiries from law enforcement. 
1st line support issues are normally dealt with by these personnel. 2nd and 3rd line support issues (relating to functional or operational issues with the registry system) are escalated to Technical Operations or Technical Development as necessary. 
The Technical Support team will consist of the following positions: 
• Operations Manager 
• Support Manager 
• Support Agent(s) 
Our overseas account managers also perform basic support functions, escalating to the support agents in London where necessary. 

23.10.4. Key Personnel 

23.10.4.1. Gavin Brown - Chief Technology Officer 
Gavin has worked at CentralNic since 2001, becoming CTO in 2005. He has overall responsibility for all aspects of the SRS, Whois, DNS, and DNSSEC systems. He is a respected figure in the domain industry and has been published in several professional technical journals, and co-authored a book on the Perl programming language. He also participates in a number of technical, public policy, and advocacy groups as well as several open source projects. Gavin has a BSc (hons) in Physics from the University of Kent. 

23.10.4.2. Jenny White - Operations Manager 
Jenny has been with CentralNic for nine years. Throughout this time she has expertly managed customer relations with external partners, prepared new domain launch processes and documentation, managed daily support and maintenance for over 1,500 Registrars, carried out extensive troubleshooting within the registrar environment to ensure optimum usability for registrars across communication platforms, handled domain disputes (from mediation to WIPO filing), and liaised with WIPO to implement changes to the Dispute Resolution Procedure when necessary. 

23.10.4.3. Adam Armstrong - Senior Operations Engineer 
Adam has recently joined CentralNic as Senior Operations Engineer. In this role he is responsible for the operation and development of the system and network infrastructure for the registry system. Adam has previously worked at a number of large UK ISPs including Jersey Telecom and Packet Exchange. He is also the lead developer of Observium, a network management system used by ICANN (amongst others). Adam has brought his strong knowledge of network design, management, and security to bear at CentralNic and will oversee the operation of the SRS for the TLD. 

23.10.4.4. Milos Negovanovic - Senior Technical Developer 
Milos has worked at CentralNic since 2009. He has a background in building rich web applications and protocol servers. His main areas of responsibility are the Registrar Console, EPP, and backoffice functions. 

23.10.4.5. Mary OʹFlaherty - Senior Technical Developer 
Mary has worked at CentralNic since 2008. She plays an integral role in the ongoing design, development, and maintenance of the registry as a whole and has specific experience with the EPP system, Registrar Console, and Staff Console. Mary has a 1st class Honors degree in Computer Science from University College Cork and has previously worked for Intel and QAD Ireland. 

23.10.5. Job Descriptions 
CentralNic will recruit a number of new employees to perform technical duties in relation to the TLD and other gTLDs. The following job descriptions will be used to define these roles and select candidates with suitable skills and experience. 

23.10.5.1. Operations Engineer 
Operations Engineers assist in the maintenance and development of the network and server infrastructure of the registry system. Operations Engineers have a good knowledge of the TCP⁄IP protocol stack and related technologies, and are familiar with best practice in the areas of network design and management and system administration. They should be competent system administrators with a good knowledge of Unix system administration, and some knowledge of shell scripting, software development, and databases. Operations Engineers have 1-2 yearʹs relevant commercial experience. Operations Engineers report to and work with the Senior Operations Engineer, who provides advice and mentoring. Operations Engineers participate in manning the NOC on a 24x7 basis and participate in the on-call shift rota. 

23.10.5.2. Security Engineer 
Security Engineers enhance and assure the security of the registry system. Day-to-day responsibilities are: responding to security incidents, performing analysis and remediating vulnerabilities, conducting tests of access controls, refining system configuration to improve security, training other team members, reviewing source code, maintaining security policies and procedures, and gathering intelligence relating to threats to the registry. Security Engineers have 1-2 years of relevant commercial experience. Staff in this role report to and work with the Senior Operations Engineer and CTO. Security Engineers participate in manning the NOC on a 24x7 basis and participate in the on-call shift rota. 

23.10.5.3. Technical Developer 
Technical Developers maintain the software which supports the registry. Day-to-day responsibilities are developing new systems in response to requests from management and customers, and correcting bugs and improving performance of existing software. Technical Developers have a good knowledge of general programming practices including use of revision control and code review systems. Developers have an awareness of security issues, such as those described in advisories published by the oWASP Project. Developers have at least one year of commercial experience in developing applications in programming languages such as PHP, Perl, and Python, although knowledge of domain technologies such as EPP and DNS is not critical. Technical Developers work as part of a team with advice and mentoring from the Senior Technical Developers, to whom they report. 

23.10.6. Resource Matrix 
To provide a means to accurately and objectively predict human resource requirements for the operation of the registry system, CentralNic has developed a Resourcing Matrix, which assigns a proportion of each employeeʹs available time to each aspect of registry activities. These activities include technical work such as operations and development, as well as technical support, registrar account management, rights protection, abuse prevention, and financial activity such as payroll, cash collection, etc. This matrix then permits the calculation of the total HR resource assigned to each area. 
A copy of the Resourcing Matrix is included as Appendix 23.2. It is important to note that the available resources cover the operation of CentralNicʹs entire registry operations, including CentralNicʹs own domain registry portfolio (uk.com, us.com, etc), the .LA ccTLD, as well as the gTLDs which CentralNic will provides registry service for. 
The actual proportion of human technical resources required specifically for the .CLUB TLD is determined by the relative size of the TLD to the rest of CentralNicʹs operations. This calculation is based on the projected number of domains after three years of operation. The optimistic scenario is used to ensure that sufficient personnel are on hand to meet periods of enhanced demand. 
CentralNic has calculated that, if all of its TLD clients are successful in their applications and in meeting their optimistic projections after three years, the .CLUB TLD will require approximately 2% of CentralNicʹs total available HR resources in order operate fully and correctly. In the event that registration volumes exceed projections, CentralNic will proactively increase the size of the Technical Operations, Technical Development, and other support teams to ensure that the needs of the TLD are fully met. Revenues from the additional registration volumes will fund the salaries of new hires. Nevertheless, CentralNic is confident that the staffing outlined above is sufficient to meet the needs of the TLD for at least the first 18 months of operation. 

Question No. 24
Except where specified, this answer refers to the operations of the Applicantʹs outsource Registry Service Provider, CentralNic. 
24.1. Registry Type 
CentralNic operates a ʺthickʺ registry in which the registry maintains copies of all information associated with registered domains. Registrars maintain their own copies of registration information, thus registry-registrar synchronization is required to ensure that both registry and registrar have consistent views of the technical and contact information associated with registered domains. The Extensible Provisioning Protocol (EPP) adopted supports the thick registry model. See §25 for further details. 

24.2. Architecture 
Figure 24.1 provides a diagram of the overall configuration of the SRS. This diagram should be viewed in the context of the overall architecture of the registry system described in §32. 
The SRS is hosted at CentralNicʹs primary operations centre in London. It is connected to the public Internet via two upstream connections, one of which is provided by Qube. Figure 32.1 provides a diagram of the outbound network connectivity. Interconnection with upstream transit providers is via two BGP routers which connect to the firewalls which implement access controls over registry services. 
Within the firewall boundary, connectivity is provided to servers by means of resilient gigabit ethernet switches implementing Spanning Tree Protocol. 
The registry system implements two interfaces to the SRS: the standard EPP system (described in §25) and the Registrar Console (described in §31). These systems interact with the primary registry database (described in §33). The database is the central repository of all registry data. Other registry services also interact with this database. 
An internal ʺStaff Consoleʺ is used by CentralNic personnel to perform management of the registry system. 

24.3. EPP System Architecture 
A description of the characteristics of the EPP system is provided in §25. This response describes the infrastructure which supports the EPP system. 
A network diagram for the EPP system is provided in Figure 24.2. The EPP system is hosted at the primary operations centre in London. During failover conditions, the EPP system operates from the Isle of Man Disaster Recovery site (see §34). 
CentralNic’s EPP system has a three-layer logical and physical architecture, consisting of load balancers, a cluster of front-end protocol servers, and a pool of application servers. Each layer can be scaled horizontally in order to meet demand. 
Registars establish TLS-secured TCP connections to the load balancers on TCP port 700. Load is balanced using DNS round-robin load balancing. 
The load balancers pass sessions to the EPP protocol servers. Load is distributed using a weighted-least-connections algorithm. The protocol servers run the Apache web server with the mod_epp and mod_proxy_balancer modules. These servers process session commands (〈hello〉, 〈login〉 and 〈logout〉) and function as reverse proxies for query and transform commands, converting them into plain HTTP requests which are then distributed to the application servers. EPP commands are distributed using a weighted-least-connections algorithm. 
Application servers receive EPP commands as plain HTTP requests, which are handled using application business logic. Application servers process commands and prepare responses which are sent back to the protocol servers, which return responses to clients over EPP sessions. 
Each component of the system is resilient: multiple inbound connections, redundant power, high availability firewalls, load balancers and application server clusters enable seamless operation in the event of component failure. This architecture also allows for arbitrary horizontal scaling: commodity hardware is used throughout the system and can be rapidly added to the system without disruption to meet an unexpected growth in demand. 
The EPP system will comprise the following systems: 
• 4x load balancers (1U rack mount servers with quad-core Intel processors, 16GB RAM, 40GB solid-state disk drives, running the CentOS operating system using the Linux Virtual Server see http:⁄⁄www.linuxvirtualserver.org⁄) 
• 8x EPP protocol servers (1U rack mount servers with dual-core Intel processors, 16GB RAM, running the CentOS operating system using Apache and mod_epp) 
• 20x application servers (1U rack mount servers with dual-core Intel processors, 4GB of RAM, running the CentOS operating system using Apache and PHP) 

24.3.1. mod_epp 
mod_epp is an Apache server module which adds support for the EPP transport protocol to Apache. This permits implementation of an EPP server using the various features of Apache, including CGI scripts and other dynamic request handlers, reverse proxies, and even static files. mod_epp was originally developed by Nic.at, the Austrian ccTLD registry. Since its release, a large number of ccTLD and other registries have deployed it and continue to support its development and maintenance. Further information can be found at http:⁄⁄sourceforge.net⁄projects⁄aepps. CentralNic uses mod_epp to manage EPP sessions with registrar clients, and to convert EPP commands into HTTP requests which can then be handled by backend application servers. 

24.3.2. mod_proxy_balancer 
mod_proxy_balancer is a core Apache module. Combined with the mod_proxy module, it implements a load-balancing reverse proxy and includes a number of load balancing algorithms and automated failover between members of a cluster. CentralNic uses mod_proxy_balancer to distribute EPP commands to backend application servers. 

24.4. Performance 
CentralNic performs continuous remote monitoring of its EPP system, including measuring the performance of various parts of the system. As of writing, the average round-trip times (RTTs) for various functions of the EPP system were as follows: 
• connect time: 87ms 
• login time: 75ms 
• hello time: 21ms 
• check time: 123ms 
• logout time: 20ms 
These figures include an approximate latency of 2.4ms due to the distance between the monitoring site and the EPP system. They were recorded during normal weekday operations during the busiest time of the day (around 1300hrs UTC) and compare very favourably to the requirement of 4,000ms for session commands and 2,000ms for query commands defined in the new gTLD Service Level Agreement. RTTs for overseas registrars will be higher than this due to the greater distances involved, but will remain well within requirements. 

24.5. Scaling 
Horizontal scaling is preferred over vertical scaling. Horizontal scaling refers to the introduction of additional nodes into a cluster, while vertical scaling involves using more powerful equipment (more CPU cores, RAM etc) in a single system. Horizontal scaling also incorporates effective mechanisms that ensure high-availability and eliminate single points of failure in the system. 
Vertical scaling leverages Mooreʹs Law: when units are depreciated and replaced, the new equipment is likely to be significantly more powerful. If the average lifespan of a server in the system is three years, then its replacement is likely to be around four times as powerful as the old server. 
For further information about Capacity Management and Scaling, please see §32. 

24.6. Registrar Console 
The Registrar Console is a web-based registrar account management tool. It provides a secure and easy-to-use graphical interface to the SRS. It is hosted on a virtual platform at the primary operations centre in London. As with the rest of the registry system, during a failover condition it is operated from the Isle of Man. The virtual platform is described in Figure 24.3. 
The features of the Registrar Console are described in §31. 
The virtual platform is a utility platform which supports systems and services which do not operate at significant levels of load, and which therefore do not require multiple servers or the additional performance that running on ʺbare metalʺ would provide. The platform functions as a private cloud, with redundant storage and failover between hosts. 
The Registrar Console currently sustains an average of 6 page requests per minute during normal operations, with peak volumes of around 8 requests per minute. Volumes during weekends are significantly lower (less than 1 request per minute). Additional load resulting from this and other new gTLDs is expected to result in a trivial increase in Registrar Console request volumes, and CentralNic does not expect additional hardware resources to be required to support it. 

24.7. Quality Assurance 
CentralNic employs the following quality assurance (QA) methods: 
1. 24x7x365 monitoring provides reports of incidents to NOC 
2. Quarterly review of capacity, performance and reliability 
3. Monthly reviews of uptime, latency and bandwidth consumption 
4. Hardware depreciation schedules 
5. Unit testing framework 
6. Frequent reviews by QA working group 
7. Schema validation and similar technologies to monitor compliance on a real-time, ongoing basis 
8. Revision control software with online annotation and change logs 
9. Bug Tracking system to which all employees have access 
10. Code Review Policy in place to enforce peer review of all changes to core code prior to deployment 
11. Software incorporates built-in error reporting mechanisms to detect flaws and report to Operations team 
12. Four stage deployment strategy: development environment, staging for internal testing, OT&E deployment for registrar testing, then finally production deployment 
13. Evidence-based project scheduling 
14. Specification development and revision 
15. Weekly milestones for developers 
16. Gantt charts and critical path analysis for project planning 
Registry system updates are performed on an ongoing basis, with any user-facing updates (i.e. changes to the behaviour of the EPP interface) being scheduled at specific times. Disruptive maintenance is scheduled for periods during which activity is lowest. 

24.8. Billing 
CentralNic operates a complex billing system for domain name registry services to ensure registry billing and collection services are feature rich, accurate, secure, and accessible to all registrars. The goal of the system is to maintain the integrity of data and create reports which are accurate, accessible, secured, and scalable. Debit accounts established for each registrar are the basis of the process. CentralNic will withdraw all domain fees from the registrar’s account on a per-transaction basis. CentralNic will provide fee-incurring services (e.g., domain registrations, registrar transfers, domain renewals) to a registrar for as long as that registrar’s account shows a positive balance. 
Once ICANN notifies Applicant that a registrar has been issued accreditation, CentralNic will begin the registrar on-boarding process, including setting up the registrarʹs financial account within the SRS. 

24.9. Registrar Support 
CentralNic provides a multi-tier support system on a 24x7 basis with the following support levels: 
• 1st Level: initial support level responsible for basic customer issues. The first job of 1st Level personnel is to gather the customer’s information and to determine the customer’s issue by analyzing the symptoms and figuring out the underlying problem. 
• 2nd Level: more in-depth technical support level than 1st Level support containing experienced and more knowledgeable personnel on a particular product or service. Technicians at this level are responsible for assisting 1st Level personnel solve basic technical problems and for investigating elevated issues by confirming the validity of the problem and seeking for known solutions related to these more complex issues. 
• 3rd Level: the highest level of support in a three-tiered technical support model responsible for handling the most difficult or advanced problems. Level 3 personnel are experts in their fields and are responsible for not only assisting both 1st and 2nd level personnel, but with the research and development of solutions to new or unknown issues. 
CentralNic provides a support ticketing system for tracking routine support issues. This is a web based system (available via the Registrar Console) allowing registrars to report new issues, follow up on previously raised tickets, and read responses from CentralNic support personnel. 
When a new trouble ticket is submitted, it is assigned a unique ID and priority. The following priority levels are used: 
1. Normal: general enquiry, usage question, or feature enhancement request. Handled by 1st level support. 
2. Elevated: issue with a non-critical feature for which a work-around may or may not exist. Handled by 1st level support. 
3. Severe: serious issue with a primary feature necessary for daily operations for which no work-around has been discovered and which completely prevents the feature from being used. Handled by 2nd level support. 
4. Critical: A major production system is down or severely impacted. These issues are catastrophic outages that affect the overall Registry System operations. Handled by 3rd level support. 
Depending on priority, different personnel will be alerted to the existence of the ticket. For example, a Priority 1 ticket will cause a notification to be emailed to the registrar customer support team, but a Priority 4 ticket will result in a broadcast message sent to the pagers of senior operations staff including the CTO. The system permits escalation of issues that are not resolved within target resolution times. 

24.10. Enforcement of Eligibility Requirements 
The SRS supports enforcement of eligibility requirements, as required by specific TLD policies. 
Figure 24.4 describes the process by which registration requests are validated. Prior to registration, the registrantʹs eligibility is validated by a Validation Agent. The registrant then instructs their registrar to register the domain. The SRS returns an ʺObject Pendingʺ result code (1001) to the registrar. 
The request is sent to the Validation Agent by the registry. The Validation Agent either approves or rejects the request, having reconciled the registration information with that recorded during the eligibility validation. If the request has been approved, the domain is fully registered. If it is rejected, the domain is immediately removed from the database. A message is sent to the registrar via the EPP message queue in either case. The registrar then notifies the registrant of the result. 

24.11. Interconnectivity with Other Registry Systems 
The registry system is based on multiple resilient stateless modules. The SRS, Whois, DNS and other systems do not directly interact with each other. Interactions are mediated by the database which is the single authoritative source of data for the registry as a whole. Individuals modules perform ʺCRUDʺ (create, read, update, delete) actions upon the database. These actions then affect the behaviour of other registry systems: for example, when a registrar adds the ʺclientHoldʺ status to a domain object, this is recorded in the database. When a query is received for this domain via the Whois service, the presence of this status code in the database results in the ʺStatus: CLIENT HOLDʺ appearing in the whois record. It will also be noted by the zone generation system, resulting in the temporary removal of the delegation of the domain name from the DNS. 

24.12. Resilience 
The SRS has a stateless architecture designed to be fully resilient in order to provide an uninterrupted service in the face of failure or one or more parts of the system. This is achieved by use of redundant hardware and network connections, and by use of continuous ʺheartbeatʺ monitoring allowing dynamic and high-speed failover from active to standby components, or between nodes in an active-active cluster. These technologies also permit rapid scaling of the system to meet short-term increases in demand during ʺsurgeʺ periods, such as during the initial launch of a new TLD. 

24.12.1. Synchronisation between Servers and Sites 
CentralNicʹs system is implemented as multiple stateless systems which interact via a central registry database. As a result, there are only a few situations where synchronisation of data between servers is necessary: 
1. Replication of data between active and standby servers (see §33). CentralNic implements redundancy in its database system by means of an active⁄standby database cluster. The database system used by CentralNic supports native real-time replication of data allowing operation of a reliable hot standby server. Automated heartbeat monitoring and failover is implemented to ensure continued access to the database following a failure of the primary database system. 
2. Replication is used to synchronise the primary operations centre with the Disaster Recovery site hosted in the Isle of Man (see §34). Database updates are replicated to the DR site in real-time via a secured VPN, providing a ʺhotʺ backup site which can be used to provide registry services in the event of a failure at the primary site. 

24.13. Operational Testing and Evaluation (OT&E) 
An Operational Testing and Evaluation (OT&E) environment is provided for registrars to develop and test their systems. The OT&E system replicates the SRS in a clean-room environment. Access to the OT&E system is unrestricted and unlimited: registrars can freely create multiple OT&E accounts via the Registrar Console. 

24.14. Resourcing 
As can be seen in the Resourcing Matrix found in Appendix 23.2, CentralNic will maintain a team of full-time developers and engineers which will contribute to the development and maintenance of this aspect of the registry system. These developers and engineers will not work on specific subsystems full-time, but a certain percentage of their time will be dedicated to each area. The total HR resource dedicated to this area is equivalent to more than one full-time post. 
CentralNic operates a shared registry environment where multiple registry zones (such as CentralNicʹs domains, the .LA ccTLD, this TLD and other gTLDs) share a common infrastructure and resources. Since the TLD will be operated in an identical manner to these other registries, and on the same infrastructure, then the TLD will benefit from an economy of scale with regards to access to CentralNicʹs resources. 
CentralNicʹs resourcing model assumes that the ʺdedicatedʺ resourcing required for the TLD (i.e., resourcing required to deal with issues related specifically to the TLD and not to general issues with the system as a whole) will be equal to the proportion of the overall registry system that the TLD will use. CentralNic has calculated that, if all its TLD clients are successful in their applications, and all meet their optimistic projections after three years, this TLD will require approximately 2% of the total resources available for this area of the registry system. 
In the event that registration volumes exceed projections, CentralNic will proactively increase the size of the Technical Operations, Technical Development, and support teams to ensure that the needs of the TLD are fully met. Revenues from the additional registration volumes will fund the salaries of new hires. Nevertheless, CentralNic is confident that the staffing outlined above is sufficient to meet the needs of the TLD for at least the first 18 months of operation. 

Question No. 25
Except where specified this answer refers to the operations of the Applicantʹs outsource Registry Service Provider, CentralNic. 
The Extensible Provisioning Protocol (EPP) is an application layer client-server protocol for the provisioning and management of objects stored in a shared central repository. EPP defines generic object management operations and an extensible framework that maps protocol operations to objects. EPP has become established as the common protocol by which domain registrars can manage domains, nameservers and contact details held by domain registries. It is widely deployed in the gTLD and ccTLD registry space. 
CentralNic has operated its EPP system since 2005, and it currently operates at significant load in terms of registrars, sessions and transaction volumes. CentralNicʹs EPP system is fully compliant with the following RFC specifications: 
• 5730 - Base Protocol 
• 5731 - domains 
• 5732 - Host Objects 
• 5733 - Contact Objects 
• 5734 - TCP Transport 
• 3735 - Extension Guidelines 
• 3915 - RGP Extension 
• 5910 - DNSSEC Extension 

25.1. Description of Interface 
EPP is a stateful XML protocol layered over TCP (see RFC 3734). Protected using lower-layer security protocols, clients exchange identification, authentication, and option information, and engage in a series of client-initiated command-response exchanges. All EPP commands are atomic (there is no partial success or partial failure) and designed so that they can be made idempotent (executing a command more than once has the same net effect on system state as successfully executing the command once). 
EPP provides four basic service elements: service discovery, commands, responses, and an extension framework that supports definition of managed objects and the relationship of protocol requests and responses to those objects. 
EPP servers respond to client-initiated communication (which can be either a lower-layer connection request or an EPP service discovery message) by returning a greeting to a client. The server then responds to each EPP command with a coordinated response that describes the results of processing the command. 
EPP commands fall into three categories: session management, queries, and transform commands. Session management commands are used to establish and end persistent sessions with an EPP server. Query commands perform read-only object information retrieval operations. Transform commands perform read-write object management operations. 
Commands are processed by a server in the order they are received from a client. The protocol includes features that allow for offline review of transform commands before the requested action is completed. In such situations, the response clearly notes that the command has been received but that the requested action is pending. The corresponding object then reflects processing of the pending action. The server will also notify the client when offline processing of the action has been completed. Object mappings describe standard formats for notices that describe completion of offline processing. 
EPP uses XML namespaces to provide an extensible object management framework and to identify schemas required for XML instance parsing and validation. These namespaces and schema definitions are used to identify both the base protocol schema and the schemas for managed objects. 

25.1.1. Objects supported 
Registrars may create and manage the following object types in the CentralNic EPP system: 
• domains (RFC 5731) 
• host objects (RFC 5732) 
• contact objects (RFC 5733) 

25.1.2. Commands supported 
CentralNic supports the following EPP commands: 
• 〈hello〉 - retrieve the 〈greeting〉 from the server 
• 〈login〉 and 〈logout〉 - session management 
• 〈poll〉 - message queue management 
• 〈check〉 - availability check 
• 〈info〉 - object information 
• 〈create〉 - create object 
• 〈update〉 - update object 
• 〈renew〉 - renew object 
• 〈delete〉 - delete object 
• 〈transfer〉 - manage object transfer 

25.2. EPP state diagram 
Figure 25.1 describes the state machine for the EPP system. Clients establish a connection with the server, which sends a greeting. Clients then authenticate, and once a login session is established, submits commands and receive responses until the server closes the connection, the client sends a logout command, or a timeout is reached. 

25.3. EPP Object Policies 
The following policies apply to objects provisioned via the EPP system: 

25.3.1. domains 
1. domains must comply with the syntax described in RFC 1035 §2.3.1. Additionally, the first label of the name must be between 3 and 63 characters in length. 
2. domains must have a registrant attribute which is associated with a contact object in the database. 
3. domains must have an administrative contact attribute which is associated with a contact object in the database. 
4. domains must have a technical contact which attribute is associated with a contact object in the database. 
5. domains may have an billing contact attribute which is associated with a contact object in the database. 
6. domains may have between 0 (zero) and 13 DNS servers. A domain with no name servers will not resolve and no records will be published in the DNS 
7. the host object model for domains is used rather than the host attribute model. 
8. domains may have a number of status codes. The presence of certain status codes indicates the domainʹs position in the lifecycle, described further in §27. 
9. where policy requires, the server may respond to a 〈domain:create〉 command with an ʺObject Pendingʺ (1001) response. When this occurs, the domain is placed onto the pendingCreate status while an out-of-band validation process takes place. 
10. when registered, the expiry date of a domain may be set up to ten years from the initial date of registration. Registrars can specify registration periods in one-year increments from one to ten. 
11. when renewed, the expiry date of a domain may be set up to ten years from the current expiry date. Registrars can specify renewal periods in one-year increments from one to ten. domains which auto-renew are renewed for one year at a time. 
12. domains must have an authInfo code which is used to authenticate inter-registrar transfer requests. This authInfo code may contain up to 48 bytes of UTF-8 character data. 
13. domains may have one or more DS records associated with them. DS records are managed via the secDNS EPP extension, as specified in RFC 5910. 
14. only the sponsoring registrar of the domain may submit 〈update〉, 〈renew〉 or 〈delete〉 commands for the domain. 

25.3.2. Host objects 
1. host names must comply with RFC 1035. The maximum length of the host name may not exceed 255 characters. 
2. in-bailiwick hosts must have an IPv4 address. They may optionally have an IPv6 address. 
3. multiple IP addresses are not currently permitted. 
4. sponsorship of hosts is determined as follows: if an object is in-bailwick (ie child of a domain in the database, and therefore also child to a TLD in the system), then the sponsor is the sponsor of the parent domain. If the object is out-of-bailiwick, the sponsor is the registrar which created the contact. 
5. if a registrar submits a change to the name of a host object, if the new host name is subordinate to an in-bailiwick domain, then that registrar must be the sponsor of the new parent domain. 
6. registrars are not permitted to create hosts that are subordinate to a non-existent in-bailiwick domain, or to change the name of a host object so that it us subordinate to a non-existent in-bailiwick domain. 
7. a host cannot be deleted if one or more domains are delegated to it (the registry deletes hosts to remove orphan glue, see §28). 
8. inter-registrar transfers are not permitted. 
9. only the sponsoring registrar of the host may submit 〈update〉 or 〈delete〉 commands for the object. 

25.3.3. Contact objects 
1. contact IDs may only contain characters from the set A-Z, 0-9, . (period), - (hyphen) and - (underscore) and are case-insensitive. 
2. phone numbers and email addresses must be valid as described in RFC 5733 §2.5 and §2.6. 
3. contact information is accepted and stored in ʺinternationalizedʺ format only: that is, contact objects only have a single 〈contact:postalInfo〉 element and the type attribute is always ʺintʺ. 
4. the 〈contact:org〉, 〈contact:sp〉, 〈contact:pc〉, 〈contact:phone〉 and 〈contact:fax〉 elements are optional. 
5. contacts must have an authInfo code which is used in inter-registrar transfers. This code may contain up to 48 bytes of UTF-8 character data. 
6. a contact cannot be deleted if one or more domains are associated with it. 
7. only the sponsoring registrar of the contact may submit 〈update〉 or 〈delete〉 commands for the object. 

25.4. EPP Extensions 
CentralNic supports the following EPP extensions. CentralNicʹs implementations fully comply with the required specifications. 

25.4.1. Registry Grace Period Mapping 
Various grace periods and hold periods are supported by the Registry Grace Period mapping, as defined in RFC 3915. This is described further in §27. 

25.4.2. DNSSEC Security Extensions Mapping 
Registrars may submit Delegation Signer (DS) record information for domains under their sponsorship. This permits the establishment of a secure chain-of-trust for DNSSEC validation. 
CentralNic supports the specification defined in RFC 5910. This supports two interfaces: the DS Data Interface and Key Data Interface. CentralNic supports the former interface (DS Data), where registrars submit the keytag, algorithm, digest type and digest for DS records as XML elements, rather than as key data. Key data is stored if provided as a child element of the 〈secDNS:dsData〉 element. The maxSigLife element is optional in the specification and is not currently supported. 

25.4.3. Launch Phase Extension 
CentralNic has assisted development of a standard EPP extension for registry ʺlaunch phasesʺ (ie Sunrise and Landrush periods), during which the steady-state mode of ʺfirst-come, first-servedʺ operation does not apply. This extension permits registrars to submit requests for domains with claimed rights such as a registered trademark. The extension is currently described in an Internet-Draft (see http:⁄⁄tools.ietf.org⁄html⁄draft-tan-epp-launchphase-00). It is hoped that this draft will eventually be published as an RFC which can be implemented by other registries and registrars. 
CentralNicʹs system implements this extension and will support the most recent version of the draft during the initial launch of the TLD. Once the TLD enters General Availability, this extension will no longer be available for use by registrars. Example frames describing the use of this extension are included in Appendix 25.2. As of writing, the current draft does not include a full schema definition, but a schema from a previous version has been included in Appendix 25.3. When the Draft is updated to include a schema, it will be based on this version. 

25.5. Registrar Credentials and Access Control 
Registrars are issued with a username (their registrar ID) and a password. This password cannot be used to access any other service and only this password can be used to access the EPP system. Registrar officers with the ʺManagementʺ access level can change their EPP password via the Registrar Console. 
RFC 5730 requires ʺmutual, strong client-server authenticationʺ. CentralNic requires that all registrars connect using an SSL certificate. This certificate may be obtained from a recognised certificate authority, or it may be a self-signed certificate registered with CentralNic via the Registrar Console. Registrar officers with the ʺManagementʺ access level can upload SSL certificates for their account. 

25.6. Session Limits and Transaction Volumes 
There are no limits on the number of active sessions a registrar can maintain with the server. Similarly, there are no limits on the volume of transactions a registrar may send. However the system is fully capable of imposing connection limits and this measure may be used in future to ensure equal access amongst registrars. 

25.7. Transaction Logging and Reporting 
All ʺtransformʺ commands are logged. Transform commands are: 〈create〉, 〈renew〉, 〈update〉, 〈delete〉 and 〈transfer〉. The system logs the time and date when the command was received, the registrar which submitted it, the request and response frames, the result code and message. All commands, whether successful or not, are logged. 
The transaction log is stored in the primary registry database. Registrars have access to the log for their account via the Registrar Console. The log viewer permits filtering by command, object type, object ID (domain, host name, contact ID), result code and timestamp. 
Query commands (〈check〉, 〈info〉, 〈poll op=ʺreqʺ〉) and session commands (〈login〉, 〈logout〉 and 〈hello〉) are not logged due to the large volume of such queries (particularly 〈check〉 queries). The EPP system uses counters for these commands to facilitate generation of monthly reports. 

25.8. EPP Message Queue 
The EPP protocol provides a message queue to provide registrars with notifications for out-of-band events. CentralNic currently supports the following EPP message notifications: 
• approved inbound transfer 
• rejected inbound transfer 
• new outbound transfer 
• cancelled outbound transfer 
• approved or rejected domain registration request (where TLD policy requires out-of-band approval of 〈domain:create〉 requests) 

25.9. Registrar Support, Software Toolkit 
CentralNic has supported EPP for many years. CentralNic has released a number of open source client libraries for several popular programming languages. These are used by registrars and registries around the world. CentralNic maintains the following open source EPP libraries: 
• Net::EPP, a general purpose EPP library for Perl. See http:⁄⁄code.google.com⁄p⁄perl-net-epp⁄ 
• Preppi, a graphical EPP client written in Perl. See https:⁄⁄www.centralnic.com⁄company⁄labs⁄preppi 
• Net_EPP, a PHP client class for EPP. See https:⁄⁄github.com⁄centralnic⁄php-epp 
• Simpleepp, a Python client class for EPP. See https:⁄⁄bitbucket.org⁄milosn⁄simpleepp 
• tx-epp-proxy, a EPP reverse proxy for shared-nothing client architectures written in Python. See https:⁄⁄bitbucket.org⁄milosn⁄tx-epp-proxy 
These libraries are available for anyone to use, at no cost. CentralNic develops these libraries, and accepts submissions and bug reports from users around the world. 

25.10. Quality Assurance, RFC Compliance 
To ensure that its EPP system fully complies with the relevant specifications documents, CentralNic has implemented the following: 

25.10.1. Schema Validation 
The EPP system automatically validates all response frames against the XSD schema definitions provided in the RFCs. Should a non-validating response be sent to a registrar, an alert is raised with the NOC to be investigated and corrected. By default, this feature is disabled in the production environment but it is enabled in all other environments (as described below). 

25.10.2. Multi-stage Deployment and Testing 
EPP system code is developed, tested and deployed in a multi-stage environment: 
1. Developers maintain their own development environment in which new code is written and changes are prepared. Development environments are configured with the highest level of debugging and strictness to provide early detection of faults. 
2. All changes to the EPP system are subjected to peer review: other developers in the team must review, test and sign off the changes before being committed (or, if developed on a branch, being merged into the stable branch). 
3. Changes to EPP system code are then deployed in the OT&E environment. Registrars continually test this system as part of their own QA processes, and this additional phase provides an additional level of quality assurance. 

25.10.3. Registrar Feedback 
Registrars are provided with an easy way to report issues with the EPP system, and many perform schema validation on the responses they receive. When issues are detected by registrars, they are encouraged to submit bug reports so that developers can rectify the issues. 

25.11. EPP System Resourcing 
As can be seen in the Resourcing Matrix found in Appendix 23.2, CentralNic will maintain a team of full-time developers and engineers which will contribute to the development and maintenance of this aspect of the registry system. These developers and engineers will not work on specific subsystems full-time, but a certain percentage of their time will be dedicated to each area. The total HR resource dedicated to this area is equivalent to more than one full-time person. 
CentralNic operates a shared registry environment where multiple registry zones (such as CentralNicʹs domains, the .LA ccTLD, this TLD and other gTLDs) share a common infrastructure and resources. Since the TLD will be operated in an identical manner to these other registries, and on the same infrastructure, then the TLD will benefit from an economy of scale with regards to access to CentralNicʹs resources. 
CentralNicʹs resourcing model assumes that the ʺdedicatedʺ resourcing required for the TLD (i.e., resourcing required to deal with issues related specifically to the TLD and not to general issues with the system as a whole) will be equal to the proportion of the overall registry system that the TLD will use. CentralNic has calculated that, if all its TLD clients are successful in their applications, and all meet their optimistic projections after three years, this TLD will require approximately 2% of the total resources available for this area of the registry system. 
In the event that registration volumes exceed projections, CentralNic will proactively increase the size of the Technical Operations, Technical Development, and support teams to ensure that the needs of the TLD are fully met. Revenues from the additional registration volumes will fund the salaries of new hires. Nevertheless, CentralNic is confident that the staffing outlined above is sufficient to meet the needs of the TLD for at least the first 18 months of operation. 

Question No. 26
Except where specified this answer refers to the operations of the Applicantʹs outsource Registry Service Provider, CentralNic. 
Whois is one of the oldest Internet protocols still in use. It allows interested persons to retrieve information relating to Internet resources (domain names and IP addresses). Whois services are operated by the registries of these resources, namely TLD registries and RIRs. 
Whois is described by RFC 3912, which serves as a description of existing systems rather than requiring specific behaviours from clients and servers. The protocol is a query-response protocol, in which both the query and the response are opaque to the protocol, and their meanings are known only the server and to the human user who submits a query. Whois has a number of limitations, but remains ubiquitous as a means for obtaining information about name and number resources. 

26.1. Compliance 
The Whois service for the TLD will comply with RFC3912 and Specifications 4 and 10 of the New gTLD Registry Agreement. The service will be provided to the general public at no cost. If ICANN specify alternative formats and protocols (such as WEIRDS) then CentralNic will implement these as soon as reasonably practicable. 
CentralNic will monitor its Whois system to confirm compliance. Monitoring stations will check the behaviour and response of the Whois service to ensure the correctness of Whois records. CentralNic will maintain a public Whois contact to which bug reports and other questions about the Whois service can be directed. The Whois service will additionally comply with all requisite data protection laws (with regards to the collection and retention of personal data), including all relevant European Union privacy directives.

26.2. Domain Name 
By default, any query is assumed to be a domain name unless a keyword is prepended to the query. If the domain exists, then registration is returned, including the following fields: 
• Domain ROID 
• Domain Name 
• Domain U-label (if IDN) 
• Creation Date 
• Last Updated 
• Expiration Date 
• EPP status codes 
• Registrant Contact Information 
• Administrative Contact Information 
• Technical Contact Information 
• Billing Contact Information (if any) 
• Sponsoring Registrar ID 
• Sponsoring Registrar Contact Information 
• DNS servers (if any) 
• DNSSEC records (if any) 
An example of a domain whois response is included in Appendix 26.1. The Domain ROID is the Repository Object Identifier as described in RFC 5730, §2.8. The ROID field corresponds to the 〈domain:roid〉 element of EPP 〈info〉 responses. 
A domain may be associated with one or more status codes. These are represented in Whois responses as phrases rather than EPP mnemonics. A domain may have any of the following status codes: 
• PENDING CREATE - a 〈domain:create〉 command has been received through the SRS, but the registration has not yet been finalised as an out-of-band review process has not yet been completed. 
• ADD PERIOD - the domain is in the Add Grace Period 
• CLIENT HOLD - the registrar has added the clientHold status 
• DELETE PROHIBITED - this may be present if the domain has either clientDeleteProhibited or serverDeleteProhibited (or both) 
• INACTIVE - the domain has no DNS servers 
• PENDING DELETE - the domain has left the Redemption Grace Period and is scheduled for deletion 
• PENDING DELETE RESTORABLE - the domain is in the Redemption Grace Period 
• PENDING RESTORE - a restore request has been received, but the Restore Report has not been received 
• PENDING TRANSFER - there is an active inter-registrar transfer for the domain 
• RENEW PERIOD - the domain is either in the Renew Grace Period or the Auto-Renew Grace Period 
• RENEW PROHIBITED - this may be present if the domain has either clientRenewProhibited or serverRenewProhibited (or both) 
• SERVER HOLD - the registry has added the serverHold status 
• TRANSFER PERIOD - the domain is in the Transfer Grace Period 
• TRANSFER PROHIBITED - this may be present if the domain has either clientTransferProhibited or serverTransferProhibited (or both) 
• UPDATE PROHIBITED - this may be present if the domain has either clientUpdateProhibited or serverUpdateProhibited (or both) 
• OK - present if none of the above apply. 
The Registrant, Administrative, Technical and Billing Contact sections of the Whois record display the contact information for the contact objects that are associated with the domain. The information displayed replicates the information showed for a contact query (see below). The server shows similar information for the sponsoring registrar. 
Domains may have 0-13 DNS servers. If a domain name has no DNS servers, then the ʺINACTIVEʺ status code appears in the Status section. If the registrant provided DS records for their DNSSEC-signed domain, then these are included. For each DS record, then the key tag, algorithm, digest type and digest are displayed. 

26.3. Contact 
Users can query for information about a contact by submitting a query of the form ʺcontact IDʺ, where ʺIDʺ is the contact ID equivalent to the 〈contact:id〉 element in EPP 〈info〉 responses. This is also the ID used when referring to contacts in domain responses. 
The following information is included in Dontact records: 
• Contact ID 
• Sponsoring Registrar 
• Creation Date 
• Last Updated Date 
• EPP Status Codes 
• Contact Name 
• Organisation 
• Street Address (1-3 fields) 
• City 
• State⁄Province 
• Postcode 
• Country Code (2 character ISO-3166 code) 
• Phone number (e164a format) 
• Fax number (e164a format) 
• Email address 
An example of a contact object whois response is included in Appendix 26.2. A contact object may be associated with one or more status codes. These are represented in Whois responses as phrases rather than EPP code mnemonics. A contact object may have any of the following status codes: 
• DELETE PROHIBITED - present if the contact object has either clientDeleteProhibited or serverDeleteProhibited (or both) 
• TRANSFER PROHIBITED - present if the contact object has either clientTransferProhibited or serverTransferProhibited (or both) 
• UPDATE PROHIBITED - present if the contact object has either clientUpdateProhibited or serverUpdateProhibited (or both) 
• PENDING TRANSFER - there is an active inter-registrar transfer for the contact object 
• LINKED - the contact object is associated with one or more domain names. A LINKED contact object automatically has the DELETE PROHIBITED status 

26.4. Host Objects 
Users can query for information about a host object by submitting a query of the form ʺnameserver HOSTʺ. The following information is included in host records: 
• Server Name 
• IPv4 address (if any) 
• IPv6 address (if any) 
• EPP status codes 
• Sponsoring Registrar 
• Creation Date 
• Referral URL (if any) 
An example of a host whois response is included in Appendix 26.3. A host object may have an IPv4 or IPv6 address if the host is ʺin-bailiwickʺ, ie subordinate to a domain name within a TLD operated by the registry. IP address information is not shown for ʺout-of-bailiwickʺ hosts. 
Host objects may only have two status codes: 
• INACTIVE - the host is not associated with any domain names 
• LINKED - the host is associated with one or more domain names 
The Referral URL is the website of the Sponsoring Registrar for this host. If the host is subordinate to a domain name in the TLD, this will be the sponsoring registrar of the parent name. If the host is out-of-bailiwick, then the sponsoring registrar is the registrar who issued the original 〈create〉 request. 

26.5. Character Encoding 
Responses are encoded as UTF-8. Queries are assumed to be encoded in UTF-8. 

26.6. IDN Support 
The Whois service supports Internationalised Domain Names. Users may submit queries for IDN domains using either the U-label or the A-label. 

26.7. Bulk Access 
CentralNic will provide up-to-date registration data to ICANN on a weekly basis (the day to be designated by ICANN). CentralNic will provide the following data for all registered domain names: domain name, repository object id (roid), registrar id (IANA ID), statuses, last updated date, creation date, expiration date, and name server names. For sponsoring registrars it will provide: registrar name, registrar repository object id (roid), hostname of registrar Whois server, and URL of registrar. Data will be provided in the format specified in Specification 2 for Data Escrow (including encryption, signing, etc.) but including only the fields mentioned in the above. 
At ICANNʹs request, CentralNic will provide ICANN with up-to-date data for the domain names of de-accredited registrar to facilitate a bulk transfer. The data will be provided in the format specified in Specification 2 for Data Escrow. The file will only contain data related to the domain names of the losing registrar. CentralNic will provide the data within 2 business days. 

26.8. Load Projections 
As described in §31, CentralNicʹs existing Whois system receives an average of 0.36 queries per day for each domain name in the registry, including misses for non-existent objects as well as hits. 
The number of daily queries per domain for each existing gTLD was calculated using figures for the month of November 2011 published by ICANN. This analysis may be found in Appendix 26.6. It shows little correlation between the number of domains in the TLD and the number of queries that each domain receives. Smaller gTLDs such as .aero and .museum receive more queries per domain than larger gTLDs, but .jobs (which is much larger than either .aero or .museum) received more queries per domain than either. It should be noted that the high volumes observed for .XXX are very likely due to activities surrounding the Landrush and initial launch of that TLD. 
CentralNic believes that the query rate observed for its own registry system is mainly affected by its efforts to deter abuse, and outreach to registrars, who often use whois to perform availability checks, to encourage them to EPP instead. CentralNic believes this query rate will also apply for the TLD. A projection of query load for the Whois system for the first 24 months of operation can be found in Appendix 26.4. This model also includes data transit rates and bandwidth projections for the same period. As can be seen, the data and bandwidth requirements are relatively small compared to those for the Shared Registry System and authoritative DNS. 

26.9. Technical Implementation 
A diagram describing the infrastructure supporting the Whois service may be found in Figure 26.1. During normal operations, the Whois service is operated at the primary operations centre in London. During failover conditions, it is operated at the Disaster Recovery site in the Isle of Man (see §34). 
Queries pass through the firewalls to one of two front-end load balancers. Round-robin DNS distributes queries between the devices. Load balancers are configured in High Availability mode so that if one a server fails, the other will resume service on its IP address until the server can be restored. Queries are distributed to backend application servers via weighted least connections algorithm. 

26.9.1. Application Server Architecture 
Application servers are built on commodity hardware running CentOS. The service is provided using the mod_whois Apache module (see http:⁄⁄modwhois.sf.net⁄) which causes Apache to listen on port 43 and accept queries, which are then handled using a PHP script, which generates and returns the response. 

26.9.2. Caching 
Application servers use caching to reduce database load. Subsequent identical queries are returned a cached record until the cache expires, after which a new record is generated. Records are currently cached for 600 seconds (ten minutes), so if a domain is updated immediately after its Whois record has been cached, the updated record will be visible after ten minutes. This compares favourably to the 60 minute requirement in the gTLD Service Level Agreement. Records are cached in a shared Memached server. Memcached is a high-performance caching server used by some of the largest sites in the world, including Wikipedia, Flickr, Wordpress.com and Craigslist. 

26.9.2. Database 
The Whois service draws data directly from the primary database. The query volume required to sustain the Whois service is comparable to that of a modest web application such as a small e-commerce site, and as a result a dedicated database for the Whois system is not required. As can be seen in Figure 26.1, a separate logging database is used to aggregate log data for use with the rate limiting system. 

26.10. Web based Whois Service 
CentralNic provides a web interface to the Whois service on its website. In addition, MLG will provide a similar service on the TLD registry website. The web Whois acts as a proxy to the port 43 Whois service: users enter a query into a form, and a server-side process submits the query to the Whois server, and displays the response. This service will not be subjected to the rate limiting described above, but users will be required to complete a CAPTCHA to prevent high-volume automated access. 

26.11. Searchable Whois Service 
MLG will provide a Searchable Whois Service (SWS). This service will be made available on the TLD website. The SWS provides third parties with a search interface that allows queries for partial matches against a number of domain name properties, including: 
• domain name (partial match) 
• registrant name, organisation, address, email 
• administrative, technical and billing contact information 
• Nameservers 
• Nameserver IPv4⁄IPv6 address 
Access to the SWS is restricted. Users must submit an account request via the website, and agree to the terms and conditions which governs their access to the the system. These terms are included as Appendix 26.5. Once their request has been reviewed and approved, they are issued with credentials which permit them to login to the SWS. 
To prevent abuse of the SWS, users may only make fifty queries per day initially. This limit can be increased upon request and demonstration of legitimate need. 

26.12. Anti-Abuse Mechanisms 
CentralNic has implemented measures to mitigate the threat of abuse of the Whois service. The primary threat to the Whois service are so-called ʺdictionaryʺ attacks, where an attacker attempts to enumerate the database by flooding the server with queries for domains taken from a precompiled list: as zone files are easy to obtain, this presents a threat to the privacy of contact information in the registry database. The information harvested can be used to compile email databases for spamming, or to send domain renewal scam letters, for example. 
The Whois service implements rate-limiting to impede dictionary attacks. For each query, a counter associated with the client IP address is incremented. For subsequent queries, this counter determines the number of queries received within the previous hour. If the number of queries exceeds a pre-set maximum (currently 240 queries per hour), then the server returns an error, warning the user that they have exceeded the permitted query rate. If the user stops sending queries, then eventually the query rate will drop below the limit, and subsequent queries will be permitted. If the user continues to send queries, and the query rate exceeds the limit by a further 25% (300 queries per hour), then the IP address is permanently blocked. For queries over IPv6 (where an attacker might have access to billions of IP addresses), the enclosing ⁄48 will be blocked. 
Experience indicates that is an effective mechanism for preventing abuse of the Whois. The rate limit has been tuned to ensure that legitimate uses of the Whois are allowed, but abusive use of the whois is restricted to levels which are unappealing for attackers. 
CentralNic keeps a ʺwhite listʺ of IP addresses used by legitimate users of the Whois service, including law enforcement agencies and other research and anti-abuse entities. Registrar access lists are also incorporated into the white list, and IP addresses registered on ICANNʹs RADAR system will also be included. Queries from IP addresses that appear on the white list are not rate-limited. Interested parties can request addition to the white list by contacting CentralNicʹs public customer service team. 
The web-based Whois does not implement rate-limiting, but users of this service must complete a CAPTCHA to access Whois records. 

26.12.1. Denial-of-Service Attacks 
The rate-limiting system in place provides protection against DoS and DDoS attacks, as any host that attempts to flood the Whois service with queries will be quickly blocked. However, a DDoS attack could still saturate upstream links requiring filtering at the edges of CentralNicʹs network, as well as their upstream providers. Continuous surveillance and monitoring of the Whois system (see §42) proactively detects these threats. As the Whois service directly queries the primary SRS database, CentralNic rate-limits on the database backend to prevent an attack against the Whois service from disrupting the SRS. 

26.13. Monitoring and Logging 
Remote monitoring is used to verify the availability of the service and to record the round-trip times for different queries (warm hit, warm miss). Local monitoring records query volumes. 

26.14. Resourcing 
As can be seen in the Resourcing Matrix found in Appendix 23.2, CentralNic will maintain a team of full-time developers and engineers which will contribute to the development and maintenance of this aspect of the registry system. These developers and engineers will not work on specific subsystems full-time, but a certain percentage of their time will be dedicated to each area. The total HR resource dedicated to this area is equivalent to almost one full-time person (83%. 
CentralNic operates a shared registry environment where multiple registry zones (such as CentralNicʹs domains, the .LA ccTLD, this TLD and other gTLDs) share a common infrastructure and resources. Since the TLD will be operated in an identical manner to these other registries, and on the same infrastructure, then the TLD will benefit from an economy of scale with regards to access to CentralNicʹs resources. 
CentralNicʹs resourcing model assumes that the ʺdedicatedʺ resourcing required for the TLD (ie, that required to deal with issues related specifically to the TLD and not to general issues with the system as a whole) will be equal to the proportion of the overall registry system that the TLD will use. CentralNic has calculated that, if all its TLD clients are successful in their applications, and all meet their optimistic projections after three years, this TLD will require approximately 2% of the total resources available for this area of the registry system. 
In the event that registration volumes exceed projections, CentralNic will proactively increase the size of the Technical Operations, Technical Development and support teams to ensure that the needs of the TLD are fully met. Revenues from the additional registration volumes will fund the salaries of these new hires. Nevertheless, CentralNic is confident that the staffing outlined above is sufficient to meet the needs of the TLD for at least the first 18 months of operation. 

Question No. 27
Except where specified this answer refers to the operations of the Applicantʹs outsource Registry Service Provider, CentralNic. 
The lifecycle of a domain in the registry is described in Figure 27.1, and closely follows that of domain names in existing gTLD registries. The lifecycle is described below. 

27.1. Available 
The domain is not registered. No delegation (or any other records) exist in the DNS, and the whois system will return a ʺNOT FOUNDʺ response to queries. An EPP 〈check〉 command will return an ʺavailʺ status of 1. 

27.2. Registered 
A registar submits an EPP 〈create〉 command or registers the domain name via the Registrar Console. The registration fee is deducted from the registrarʹs balance. The initial registration period may be any whole number of years between one (1) and ten (10). 
For five (5) calendar days after the registration of the domain, the registrar can delete the domain and receive a credit for the registration fee (subject to the Add Grace Period Limits Policy). 
While the domain is registered, it is delegated to the specified name servers and will resolve normally. During this time, the registrar may update the domain nameʹs DNS settings, lock statuses and contact associations, and may extend the registration period (subject to a maximum of ten (10) years) by submitting a 〈renew〉 EPP command or using the Registrar Console. 
The domain may also be transferred to a different sponsoring registrar. Upon such transfer the domain name is automatically renewed for one year. 

27.3. Expired 
When the expiry date is reached, the domain name is automatically renewed for a period of one year, and the renewal fee is deducted from the registrarʹs account. 
For forty-five (45) days after the auto-renewal (Auto-Renew Grace Period), the registrar can delete the domain and receive a credit for the renewal fee. 

27.4. Redemption Grace Period 
Should the registrar delete the domain, the domain enters the Redemption Grace Period. During this period, the domain name will no longer resolve as all delegation information is removed from the TLD zone. 
For the first thirty (30) days after receipt of the delete request, the domain is in the ʺPending Delete Restorableʺ state. During this time, the registrar may submit an RGP restore request via EPP or the Registrar Console. The domain is then placed into the ʺPending Restoreʺ state. 
The registrar must then submit an RGP Restore Report detailing the reason why the restore request has been submitted. If the Restore Report is received within five (5) calendar days of the original restore request, then the domain is restored. However, if the Restore Report is not received within this period, then the domain falls back into the ʺPending Delete Restorableʺ state. 

27.5. Redemption Period State Diagram 
Figure 27.2 describes the state diagram for domain names in the Redemption Grace Period. This diagram is taken from RFC 3915. 

27.6. Pending Delete 
Forty (40) days after the receipt of the delete request, the domain leaves the ʺPending Delete Restorableʺ and enters the ʺPending Deleteʺ status. The registrar cannot submit a Restore Request during this period. 

27.7. Released 
Five (5) days after the domain enters the ʺPending Deleteʺ status the domain name is purged from the database and is once again available for registration. 

27.8. Other Grace Periods 
The registry also implements the following grace periods. In general, these grace periods allow registrars to delete domain names following billable transactions and receive a refund. 

27.8.1. Add Grace Period 
As described above, the Add Grace Period (AGP) is the five (5) calendar days following the initial registration of the domain. 

27.8.2. Auto-renew Grace Period 
As described above, the Auto-renew Grace Period is the forty five (45) calendar days following the auto-renewal of the domain. 

27.8.3. Renew Grace Period 
The Renew Grace Period is the five (5) calendar days following the renewal of the domain via an EPP 〈renew〉 command, or via the Registrar Console. 

27.8.4. Transfer Grace Period 
The Transfer Grace Period is the five (5) calendar days following the successful completion of an inter-registrar transfer. 

27.9. Hold Periods 
The registry implements the following hold periods: 

27.9.1. Registration Hold Period 
The Registration Hold Period forbids inter-registrar transfers of domain names within sixty (60) days of initial registration. 

27.9.2. Transfer Hold Period 
The Transfer Hold Period forbids transfers of domain names within sixty (60) days of a previous inter-registrar transfer. This Hold Period does not affect disputed transfers that are undone by the registry following the outcome of a Transfer Dispute Resolution process. 

27.10. Lock Statuses 
The registry system permits the following lock statuses for domain names: 

27.10.1. clientHold 
This status may be set by registrars using an EPP 〈update〉 command, or via the Registrar Console. Domains with this status are removed from the DNS and will not resolve. 

27.10.2. clientDeleteProhibited 
This status may be set by registrars using an EPP 〈update〉 command, or via the Registrar Console. When set, all attempts by the registrar to delete the domain using an EPP 〈delete〉 command will be refused with EPP response code 2304 (Status Prohibits Operation). Registrars must remove the code using an EPP 〈update〉 command before they can delete the domain. 

27.10.3. clientRenewProhibited 
This status may be set by registrars using an EPP 〈update〉 command, or via the Registrar Console. When set, all attempts by the registrar to renew the domain using an EPP 〈renew〉 command will be refused with EPP response code 2304 (Status Prohibits Operation). Registrars must remove the code using an EPP 〈update〉 command before they can renew the domain. 

27.10.4. clientUpdateProhibited 
This status may be set by registrars using an EPP 〈update〉 command, or via the Registrar Console. When set, all attempts by the registrar to update the domain using an EPP 〈update〉 command will be refused with EPP response code 2304 (Status Prohibits Operation), unless the 〈update〉 request frame includes a 〈rem〉 element to remove this status. Once the status has been removed, subsequent 〈update〉 commands will succeed. 

27.10.5. clientTransferProhibited 
This status may be set by registrars using an EPP 〈update〉 command, or via the Registrar Console. When set, all attempts by other registrars to submit a transfer request for the the domain using an EPP 〈transfer〉 command, or via the Registrar Console, will be refused with EPP response code 2304 (Status Prohibits Operation). The sponsoring registrar must remove this status before any other registrar can submit a transfer request. 

27.10.6. serverHold 
This status is set by the registry in accordance with policy. It cannot be removed by registrars. Domains with this status are removed from the DNS and will not resolve. 

27.10.7. serverDeleteProhibited 
This status is set by the registry in accordance with policy. It cannot be removed by registrars. When set, all attempts by the registrar to delete the domain using an EPP 〈delete〉 command will be refused with EPP response code 2304 (Status Prohibits Operation). 

27.10.8. serverUpdateProhibited 
This status is set by the registry in accordance with policy. It cannot be removed by registrars. When set, all attempts by the registrar to update the domain using an EPP 〈update〉 command will be refused with EPP response code 2304 (Status Prohibits Operation). 

27.10.9. serverRenewProhibited 
This status is set by the registry in accordance with policy. It cannot be removed by registrars. When set, all attempts by the registrar to renew the domain using an EPP 〈renew〉 command will be refused with EPP response code 2304 (Status Prohibits Operation). 

27.10.10. serverTransferProhibited 
This status is set by the registry in accordance with policy. It cannot be removed by registrars. When set, all attempts by the registrar to transfer the domain using an EPP 〈transfer〉 command will be refused with EPP response code 2304 (Status Prohibits Operation). 

27.11. Lifecycle Processing 
Domain names move through the lifecycle in one of two ways: in real-time as a result of registrar activity, or during daily billing runs. 
Billing runs take place once per day. The billing run performs the following batch jobs: 
• auto-renewal of expired domains 
• processing of registration and renewal fees for domains that move outside their grace periods 
• processing of domains in the RGP state (from restorable to not restorable, checking for missing restore reports, etc) 
• purging of domains scheduled for deletion 
The billing runs also perform registrar account management functions such as generation of invoices, sending balance warnings, and generation of internal reports. 

27.12. Inter-Registrar Transfer Period 
When a transfer request is received, the action date of the transfer is set to five (5) calendar days from the moment of the original request. Successful transfers are approved at the end of this period. 

27.13. pendingCreate Status 
The Registry system supports the ʺpendingCreateʺ status for domain names, as described in RFC 5731, §3.3. Domains in this state are fully registered in the database (subsequent 〈create〉 commands would fail with an Object Exists error) but are not present in the DNS. 
This status is used when a particular TLD implements a policy whereby registration requests are verified by a third party such as a Sponsoring Organisation or Validation Agent. Following out-of-band review of the request, the registration may be approved or denied. 
If a request is denied, then the domain is immediately purged from the registry system, and the registrar notified via email and the EPP message queue. The registrar also receives a credit for the registration fee. If approved, then the pendingCreate status is removed from the domain which begins to resolve. 

27.14. Resourcing 
The domain registration lifecycle is managed through automated backend processes that generally require no human intervention, and real-time business logic implemented in Shared Registry System application code. Operations personnel will be responsible for maintaining and developing the computing infrastructure which supports the lifecycle processing systems. Backend systems are hosted on a flexible virtual infrastructure hosted at the primary operations centre at the Goswell Road Data Centre in London. 
The domain registration lifecycle does have customer and registrar support requirements, so a proportion of the time of the Operations Manager, Support Manager and Support Agent has been dedicated to this area. This time primarily relates to dealing with questions and comments from registrars and registrants about the status of their domain names. 
As can be seen in the Resourcing Matrix found in Appendix 23.2, CentralNic will maintain a team of full-time developers and engineers which will contribute to the development and maintenance of this aspect of the registry system. These developers and engineers will not work on specific subsystems full-time, but a certain percentage of their time will be dedicated to each area. The total HR resource dedicated to this area is equivalent to 30% of a full time person. Because of the maturity and stability of this system (which has been in use for more than 16 years), only 5% of time of a technical developer has been allocated to this area. 
CentralNic operates a shared registry environment where multiple registry zones (such as CentralNicʹs domains, the .LA ccTLD, this TLD and other gTLDs) share a common infrastructure and resources. Since the TLD will be operated in an identical manner to these other registries, and on the same infrastructure, then the TLD will benefit from an economy of scale with regards to access to CentralNicʹs resources. 
CentralNicʹs resourcing model assumes that the ʺdedicatedʺ resourcing required for the TLD (i.e., resourcing required to deal with issues related specifically to the TLD and not to general issues with the system as a whole) will be equal to the proportion of the overall registry system that the TLD will use. CentralNic has calculated that, if all its TLD clients are successful in their applications, and all meet their optimistic projections after three years, this TLD will require approximtely 2% of the total resources available for this area of the registry system. 
In the event that registration volumes exceed projections, CentralNic will proactively increase the size of the Technical Operations, Technical Development, and support teams to ensure that the needs of the TLD are fully met. Revenues from the additional registration volumes will fund the salaries of new hires. Nevertheless, CentralNic is confident that the staffing outlined above is sufficient to meet the needs of the TLD for at least the first 18 months of operation. 

Question No. 28
Except where specified this answer refers to the operations of the Applicantʹs outsource Registry Service Provider, CentralNic. 
Top Level Domain registries stand in a unique position within the global DNS infrastructure. 
TLD registries collect registrants’ registration data and thus often “know” the entity responsible for a particular domain name. TLD registries record associations between domain names, registrars, and registrants and therefore are at the core of the control chain for every domain name in the TLD. Registries also directly control the delegation records and therefore have the power to enable or disable a particular domain name in the DNS. 
This unique position gives power and calls for responsibility. MLG, as a future TLD registry, recognizes its important role in maintaining law and order and is committed to acting in the best interests of the public. 
The following is a description of the principles and procedures we will apply to mitigate abusive conduct. 

28.1. Single Abuse Point of Contact 
To streamline the information flow and to facilitate ease of communication with the public, MLG will dedicate a single abuse point of contact responsible for addressing matters requiring expedited attention and providing a timely response to abuse complaints concerning all names registered in the TLD. The contact information will consist of at least an email address and a telephone number. This point of contact will be prominently published on the registry website by the commencement of the Sunrise period. 
MLG will ensure that: 
• The e-mail account is continuously monitored and all communication securely stored; 
• The telephone number is either answered by a live person or diverted to a monitored voicemail account;
• Abuse contact information will be kept current and will be updated should it ever change in a timely manner. 
Messages received through the published abuse point of contact will be processed via the same procedure and within the same timeframe as the signals coming from the monitoring systems. Each message, both via email and phone channels, triggers the creation of a support ticket in a dedicated queue and procedures for ticket escalation exist. Messages originating from law enforcement authorities are by default assigned an escalated level. For critical tickets, personnel are available 24x7 to react accordingly. 
MLG and CentralNic commit to responding to all abuse complaints within 24 hours of receipt (on a 24x7 basis). During the time periods when its global offices are open (typically 8am-6pm in London, Los Angeles and Dubai) response times are expected to be substantially faster, at around 2-3 hours. 

28.2. Policy on Handling Complaints Regarding Abuse 
MLG is prepared to deal with situations where registry intervention may be required in order to stop illegal activity, prevent abusive conduct, or to enforce the law. 
MLG will adopt a comprehensive Acceptable Use Policy that will establish what constitutes acceptable use of the domain and will contain a description of registry procedures that will apply to enforce the Policy. The initial draft of this policy is provided in answer to Question 29. 
An enforcement action may be triggered by a variety of events including complaints from the public, registrars, or ICANN, or from decisions of a competent dispute resolution provider, outreach from a governmental agency, or findings produced by internal investigation or monitoring processes. 
Normally if abusive behaviour in a TLD is encountered, the reports of such behaviour and the evidence available will be analysed by the Registry. If the Registry, in its sole discretion, concludes that a Domain Name Holder has indeed violated a TLD Policy, the registrant will be given a notice and opportunity to correct the breach. 
Furthermore, the registry reserves the right to lock the domain name or put it on hold (preventing domain resolution in the DNS). In extreme cases where a domain is involved in malicious or illegal activity, there are provisions for rapid takedown of the domain name in question. The situations in which rapid takedown provisions may be applied, include, but are not limited to: 
• Phishing 
• Pharming 
• Distribution of illegal content 
• Distribution of malware 
• Fast flux hosting 
• Botnetting 
• Unauthorized access to information systems 
• Threats to the security and⁄or stability of the TLD 
The .CLUB Acceptable Use Policy will be incorporated into the Registry-Registrar agreements. Registrars will be required to pass on to registrants the requirements to comply with the policy. MLG will take reasonable steps to investigate and respond to any reports of illegal activity in connection with the use of the TLD and will cooperate with competent governmental agencies in such investigations. 
MLG will utilize the expert services of its registry services provider CentralNic to implement and enforce all of our anti-abuse policies in our TLD. CentralNic has dedicated and scalable resources for this function, described below. 
CentralNic has long experience in the domain registry business, and is an industry leader with respect to its anti-abuse policies. CentralNic has a dedicated Dispute Resolution Policy in place with WIPO, found at WIPO’s website: http:⁄⁄www.wipo.int⁄amc⁄en⁄domains⁄gtld⁄cnic⁄index.html. This policy mirrors the UDRP policy for new gTLDs and, as a result, CentralNic already has real-time experience working with WIPO to implement and execute a similar policy. CentralNic has trained personnel who handle interaction with WIPO, to ensure that panelists’ decisions are carried out expeditiously as required by the DRP. 
CentralNic also enforces a Policy on Phishing and Fraud, found at its dedicated Phishing & Abuse page at the following website: https:⁄⁄www.centralnic.com⁄support⁄abuse. Pursuant to clause 13, sections (f) and (h) of CentralNicʹs Terms and Conditions, CentralNic may cancel the registration or suspend registration of a domain name: 
(f) if CentralNic believes that the domain name was registered for use in a ʺphishingʺ attack or other illegal activity of any kind. 
(h) if inaccurate or false contact details are provided. 
Further to these conditions, CentralNic operates the following policy regarding suspected ʺphishingʺ domain names: 
- If we have a reasonable suspicion that a domain name registered at CentralNic is being used in a phishing attack, or otherwise being used for other illegal activities, we will place the domain name ʺOn Holdʺ and under a Registry Lock. - We will then notify the current registrar for the domain name. If the registrar can provide confirmation that the domain name was registered in ʺgood faithʺ by the registrant, then CentralNic will immediately unlock the domain name and place it on the ʺLiveʺ status. - If no confirmation is received, or the registrars agree that the domain name was registered in ʺbad faithʺ, the domain name will be placed onto ʺPending Deletionʺ, and will be fully deleted from the database after 45 days. 

28.3. Orphan Glue 
CentralNicʹs registry system includes effective measures to prevent the abuse of orphan glue records. 
Firstly, the Shared Registry System will reject any request to create host object that is the child of a non-existent domain name. That is, if EXAMPLE.CLUB does not exist, then NS0.EXAMPLE.CLUB cannot be created. If the parent domain name does exist, then only the sponsoring registrar of that domain is permitted to create child host objects. 
CentralNicʹs registry system currently follows the third model described in the SAC 048 report: orphan glue records are deleted from the registry and removed from the DNS when the parent domain name is deleted. If other domains in the database are delegated to orphan hosts that are removed, then the delegation is also removed from these domains. 

28.4. Measures to Maintain Whois Accuracy 
MLG will operate a “thick” WHOIS system, in which all registrants’ contact information will be stored in a single database maintained by the registry. Accredited registrars will have the ability to change the records in that database through the Shared Registration System. The Registry-Registrar agreement requires registrars to ensure that the WHOIS data is accurate at the time of submission and also requires the information provided on the system to be updated in a timely manner in case of any changes. Corresponding provisions also exist in the Registrar Accreditation Agreement (RAA), para. 3.7.7. 
In addition to the standard measures described above, the .CLUB WHOIS system will feature extra levels of reliability with regards to Whois information. 

28.4.1. Extra checks on WHOIS data 
MLG, through its Registry-Registrar agreements will require registrars to perform the following additional checks on the WHOIS data: 
• Verify syntactic correctness of email addresses and phone numbers by validating them against the corresponding standards 
• Verify that the domain holder receives email at the addresses listed in WHOIS as registrant’s email address and administrative contact email address, by requiring them to click a unique web link that is sent to those addresses. 
28.4.2. Random audits of WHOIS records by the Registry 
MLG will periodically (at least once every 12 months) perform a random check of WHOIS records in .CLUB for prima facie evidence of fraudulent or inaccurate WHOIS information. For those suspicious records that may be found, MLG will further require registrars to conduct a reasonable investigation and to respond with one of the three possible actions: 
• confirm that the information provided in WHOIS is accurate, or 
• correct the WHOIS information, or 
• delete the domain name(s). 
The measures described above exceed the ICANN requirements and are adequate to improve accuracy of WHOIS information while maintaining low implementation cost for registrars and good user experience for registrants. 

28.5. Resourcing 
MLG and CentralNic will provide abuse response on a 24x7 basis. The resourcing to fulfill this function will be provided by a combined team of support and operations personnel. The first response function will be provided by support agents during normal office hours, with this responsibility being passed to the Network Operations Centre (NOC) during 24x7 operations. 
As can be seen in the Resourcing Matrix found in Appendix 23.2, CentralNic will maintain a team of full-time developers and engineers who will contribute to the development and maintenance of this aspect of the registry system. These developers and engineers will not work on specific subsystems full-time, but a certain percentage of their time will be dedicated to each area. The total HR resource dedicated to this area is equivalent to 75% of a full-time role. 
CentralNic operates a shared registry environment where multiple registry zones (such as CentralNicʹs domains, the .LA ccTLD, this TLD and other gTLDs) share a common infrastructure and resources. Since the TLD will be operated in an identical manner to these other registries, and on the same infrastructure, then the TLD will benefit from an economy of scale with regards to access to CentralNicʹs resources. 
CentralNicʹs resourcing model assumes that the ʺdedicatedʺ resourcing required for the TLD (ie, that required to deal with issues related specifically to the TLD and not to general issues with the system as a whole) will be equal to the proportion of the overall registry system that the TLD will use. CentralNic has calculated that, if all its TLD clients are successful in their applications, and all meet their optimistic projections after three years, this TLD will require approximately 2% of the total resources available for this area of the registry system. 
In the event that registration volumes exceed projections, CentralNic will proactively increase the size of the Technical Operations, Technical Development and support teams to ensure that the needs of the TLD are fully met. Revenues from the additional registration volumes will fund the salaries of these new hires. Nevertheless, CentralNic is confident that the staffing outlined above is sufficient to meet the needs of the TLD for at least the first 18 months of operation. 

28.6. Periodic review of anti-abuse policies 
MLG acknowledges that new types of abusive behaviour emerge in cyber space and is prepared to take steps to counter any new types of abuse. MLG will periodically (once every 12 months, or more frequently depending on the circumstances) require CentralNic to provide reports regarding the received abuse-related complaints. Such reports should contain categorisation of the abusive behaviour reported, actions taken, and response time. MLG will analyse the reports and will review its anti-abuse policies to continually improve the handling of abuse complaints. 

Question No. 29
Except where specified this answer refers to the operations of the Applicantʹs outsource Registry Service Provider, CentralNic. 
MLG affirms that providing appropriate mechanisms to protect legal rights of others is one of the core objectives of the Registry. MLG will follow rules and policies developed by ICANN with regards to Rights Protection Mechanisms (RPMs). MLG will fully comply with Specification 7 of the new gTLD registry agreement and will provide additional rights protection mechanisms over and above the ICANN requirements. Both standard and additional RPMs are described below. 

29.1. Sunrise Period 
Prior to the open registration phase MLG will offer a priority registration period for owners of trademarks and service marks. This period will last at least 30 days. 
MLG will support Trademark Clearinghouse (TCH) once it is implemented by ICANN. Owners of trademarks pre-validated by the Clearinghouse will be able to secure their domain registrations during the Sunrise period without further verification of their intellectual property rights. 
The flowchart of the Sunrise and eligibility validation process is available in Figure 24.4. 

29.1.1. Sunrise Eligibility Requirements 
Any entity that holds a trademark or service mark will be qualified to register a domain during the Sunrise period. Registrations obtained during the Sunrise Period will be subject to challenge as described below. 
As a minimum, the Registry will recognize as qualifying all word marks that: 
• Are nationally or regionally registered and for which proof of use is available, or 
• Marks that have been validated by the court, or 
• Marks that are specifically protected by a statute or treaty. 
All the Sunrise Eligibility requirements will have to be met by the cut-off date which will be announced in due course. 
Full details of the Sunrise registration process will be finalized after the Trademark Clearinghouse service is implemented and full documentation, policies, terms and conditions are made available. For guidance, data items that will need to be provided by the qualifying applicant to apply for a .CLUB Sunrise registration are listed below: 
• name or description of the trademark 
• registration number 
• registration date 
• country of registration 
• capacity of the applicant 
• reference to the Trademark Clearinghouse database record 
• representation that the information provided is true and correct 

29.1.2. Sunrise Challenge Process 
The result of the evaluation of Sunrise applications will be published on the Registry website. A process will be in place to allow third parties to dispute the registrant rights to own a domain name. MLG will engage a reputable adjudicator to manage the Sunrise challenge process. The adjudicator will charge a reasonable fee for Sunrise challenges. 
The Sunrise Challenge rules will allow challenges based on at least the following four grounds: 
• at the time the challenged domain name was registered, the registrant did not hold a trademark registration of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; 
• the domain name is not identical to the mark on which the registrant based its Sunrise registration; 
• the trademark registration on which the registrant based its Sunrise registration is not of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; or 
• 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. 

29.2. Trademark Claims Service 
The Trademark Claims service will be launched by the registry as soon as the open registration period starts and will be provided for at least 90 days (exceeding the period mandated by ICANN). MLG will review the effect of the Trademark Claims service and based on the results of such review, MLG is prepared to consider providing the Trademark Claims service on an ongoing basis. 
The essence of the Trademark Claims service is as follows: if a domain name registration is attempted for which there exists a matching record in the Trademark Clearinghouse database, then the prospective registrant will be presented with a notice that third party trademark rights exist for a matching designation and will be required to provide a statement that to the best of his or her knowledge, the registration and use of the requested domain name will not infringe on the rights of the trademark holders. 
If the registrant chooses to proceed with the registration, the corresponding trademark holder(s) will be notified that such registration has taken place. 
Operational rules of the Trademark Claims service are heavily dependent on the specific implementation of the Trademark Clearinghouse which is not yet available in writing. Therefore full details of the Trademark Claims service will be finalized after the TCH is implemented by ICANN and full documentation, policies, terms, and conditions become available. 

29.3. Uniform Domain Name Dispute Resolution Policy (UDRP) 
The Uniform Domain Name Dispute Resolution Policy is an ICANN consensus policy for adjudication of disputes between domain name holders and owners of matching trademarks. Every registrant must agree to this mandatory administrative procedure in its Domain Registration Agreement with the registrar. Registrars have certain responsibilities to facilitate adjudication of UDRP disputes and to enforce the decisions of the arbitration panels. 
.CLUB will comply with the Uniform Domain Name Dispute Resolution Policy or with any successor thereof. The UDRP will be incorporated by reference into Registry-Registrar Agreements. Similarly, Registrars will be required to incorporate it into their Domain Registration agreements with the Registrants. 
The UDRP process does not provide for any participation by the Registry and is fully borne by the Registrar, Registrant, Complainant, and the Dispute Resolution Provider. However, MLG is prepared to collaborate with all relevant stakeholders to ensure UDRP decisions are implemented. 
CentralNic, MLG’s registry services provider, has maintained a similar dispute resolution policy with WIPO which is available at http:⁄⁄www.wipo.int⁄amc⁄en⁄domains⁄gtld⁄cnic⁄index.html. CentralNic has dedicated personnel trained to address these types of complaints and to communicate with WIPO and other relevant stakeholders. 

29.4. Uniform Rapid Suspension System (URS) 
The Uniform Rapid Suspension System (URS) described in the ICANN gTLD Applicant Guidebook is a new Rights Protection Mechanism for rapid takedown of domain names that by clear and convincing evidence infringe on legitimate trademark rights of third parties. 
As opposed to the UDRP procedure, registries are required to participate in the URS procedure and enforcement of the URS decisions. MLG will comply with the URS policy once implemented by ICANN. 
The current URS procedure as described in the Applicant Guidebook is as follows: within 24 hours of receipt of the Notice of Complaint from a URS Provider, the Registry has to lock the domain, restricting all changes to the registration data, including transfer and deletion. The domain name will continue to resolve at this stage. The Registry will notify the URS Provider immediately upon locking the domain name. 
If the URS Determination is in favour of Complainant, upon receipt of the Determination the Registry will suspend the domain name which is intended to remain suspended for the balance of the registration period and will not resolve to the original web site. Instead, the nameservers will be redirected to an informational web page provided by the URS Provider about the URS. The Whois record for the domain name will continue to display all of the information of the original Registrant except for the redirection of the nameservers. In addition, the Whois will reflect that the domain name will not be able to be transferred, deleted or modified for the life of the registration. 
If the URS Determination is in favour of the Respondent, the Registry will remove the lock status from the domain name allowing the registrant to continue using it normally. 
The URS compliance function will be performed by CentralNic and overseen by MLG. Given CentralNic’s long-standing experience in dealing with trademark-related disputes in domain names, MLG has no doubt that this function will be performed by CentralNic flawlessly. 

29.5 Mediation 
CentralNic has implemented a solution that complements the UDRP by adopting a best practice of Nominet and other ccTLDs. CentralNic has experienced a high percentage of domain disputes resolved without the need for filing a formal and relatively expensive UDRP complaint, by offering informal mediation to any person or entity who submits a Request for Mediation to the registry. The Mediation rules that CentralNic intends to apply to gTLDs are copied below: 
ʺCentralNicʺ means CentralNic Ltd, 35-39 Moorgate, London EC2R 6AR, United Kingdom. 
ʺComplainantʺ means the party submitting a Request for Mediation concerning a Domain Name registration pursuant to the CentralNic Mediation Rules. 
ʺDomain Nameʺ means any domain name registered under a sub-domain provided by CentralNic. 
ʺMediationʺ means a mediation conducted by CentralNic in accordance with the CentralNic Mediation Rules that are incorporated by reference and made a part of the Registration Agreement. 
ʺPartyʺ means a Complainant or a Respondent. 
ʺRegistration Agreementʺ means the agreement between CentralNic and a Domain Name holder. 
ʺRespondentʺ means the holder of a Domain Name registration in respect of which a Request for Mediation is submitted pursuant to the CentralNic Mediation Rules. 
1. Request for Mediation: (a) Any person or entity may submit a Request for Mediation relating to a Domain Name registration in accordance with the CentralNic Mediation Rules. A copy of the Request for Mediation shall be sent to the Respondent and to CentralNic. (b) The Request for Mediation shall be submitted in writing by e-mail and shall: (i) State that the Complainant wishes to submit the dispute to Mediation in accordance with the CentralNic Mediation Rules; (ii) Provide the name, postal and e-mail addresses, and the telephone and telefax numbers of the Complainant and of any representative authorized to act for the Complainant in the Mediation; (iii) Specify a preferred method for communications directed to the Complainant in the Mediation (including person to be contacted, medium, and address information); (iv) Provide the name of the Respondent and all information (including any postal and e-mail addresses and telephone and telefax numbers) known to Complainant regarding how to contact the Respondent or any representative of the Respondent, including contact information based on pre-Request dealings; (v) Specify the Domain Name(s) that is⁄are the subject of the Request; (vi) Contain a brief statement of the nature of the dispute. (c) The Request for Mediation may relate to more than one Domain Name, provided that the Domain Names are registered by the same Domain-Name holder. 
2. Commencement: (a) The date of commencement of the Mediation shall be the date on which the Request for Mediation is received by CentralNic. (b) CentralNic shall inform the Parties of the receipt by it of the Request and of the date of commencement of the Mediation. 
3. Mediation: (a) CentralNic shall conduct the Mediation in a manner which CentralNic, in its sole discretion, considers appropriate. (b) The language of the Mediation shall be English, unless decided otherwise by CentralNic. (c) CentralNic will not reveal details of the Mediation to any third parties unless ordered by a court of competent jurisdiction or required by applicable laws or regulations or except as may be provided under the CentralNic Dispute Resolution Policy and the Rules for CentralNic Dispute Resolution Policy. 
4. Termination of the Mediation: The Mediation will terminate ten (10) calendar days after the date of commencement. At the request of the Parties or on its own motion, CentralNic may, in exceptional cases, extend the period of time for the Mediation. The fact of termination shall be recorded by CentralNic. 
5. Fees: No fees shall be payable by either party for the conduct of the Mediation. 
6. Exclusion of Liability: Except in the case of deliberate wrongdoing, CentralNic shall not be liable to a Party for any act or omission in connection with the Mediation. 
7. Waiver of Defamation: The Parties agree that any statements or comments, whether written or oral, made or used by them or their representatives in preparation for or in the course of the Mediation shall not be relied upon to found or maintain any action for defamation, libel, slander or any related complaint, and this Paragraph may be pleaded as a bar to any such action. 
8. Amendments: CentralNic reserves the right to modify these Rules at any time. CentralNic will post the revised Rules at at least thirty (30) calendar days before they become effective. The version of these Rules in effect at the time of the submission of the Request for Mediation to CentralNic shall apply to the Mediation commenced thereby. 
MLG notes this is CentralNic’s current policy for its current registry businesses. MLG may make modifications to this Policy, without limitation by charging a reasonable fee and⁄or by specifying the mediation mechanism, as its business plans develop prior to launch of the TLD. However, MLG remains committed to offering a less formal and less expensive procedure than the UDRP, and perhaps even the URS, to the extent commercially feasible. 

29.6 Abusive use⁄takedown policies 
The answer to question 28 contains a detailed description of measures that MLG will take to prevent and mitigate abusive registrations and the description of policies that MLG will apply to handle complaints regarding abuse and take down abusive registrations. In summary,
• MLG will dedicate a single abuse point of contact. Correspondence and complaints coming through that point of contact will be continuously monitored and responded to within 24 hours. 
• MLG will adopt a comprehensive Eligibility and⁄or Acceptable Use Policy that will set forth the limits of acceptable use of domains and the procedures the Registry will apply in case of violations of applicable laws or policies, including takedown procedures. The initial Acceptable Use Policy is provided in this section below. 
• MLG will delete orphan glue records once the parent domain is deleted to prevent abuse of these orphan glue records.
• MLG will require registrars to perform extra checks on WHOIS data to improve its accuracy.
• MLG will perform random audits of WHOIS data and will flag suspicious registrations via registrars.

29.7. Post-Delegation Dispute Resolution Procedure 
MLG reaffirms its intent to comply with the ICANN-mandated Post-Delegation Dispute Resolution Procedure (PDDRP). 
MLG believes that its choice of TLD string and the way the TLD is intended to be operated represents a good faith offering of Top Level Domain Registry service and does not infringe on any legitimate third party trademark rights. 

MLG also reaffirms its commitment to maintain .CLUB free of violations of third party trademark rights through second level domain registration and use. MLG has all the required resources, policies and procedures in place to address any situations of abuse without the need to invoke the PDDRP procedure. 

29.8. Resourcing 
The Rights Protection Mechanisms described above include a combination of both technical and non-technical systems: for example, the Trademark Claims Service may (depending on the final specification published by ICANN) require development, maintenance and support of an EPP extension, as well as real-time integration with the TCH API, whereas the UDRP is a primarily manual process of managing and responding to communications from complaints, respondents and UDRP service providers. 
As can be seen in the Resourcing Matrix found in Appendix 23.2, CentralNic will maintain a team of full-time developers and engineers which will contribute to the development and maintenance of this aspect of the registry system. These developers and engineers will not work on specific subsystems full-time, but a certain percentage of their time will be dedicated to each area. The total HR resource dedicated to this area is equivalent to half of a full-time role. 
CentralNic operates a shared registry environment where multiple registry zones (such as CentralNicʹs domains, the .LA ccTLD, this TLD and other gTLDs) share a common infrastructure and resources. Since the TLD will be operated in an identical manner to these other registries, and on the same infrastructure, then the TLD will benefit from an economy of scale with regards to access to CentralNicʹs resources. 
CentralNicʹs resourcing model assumes that the ʺdedicatedʺ resourcing required for the TLD (i.e., resourcing required to deal with issues related specifically to the TLD and not to general issues with the system as a whole) will be equal to the proportion of the overall registry system that the TLD will use. CentralNic has calculated that, if all its TLD clients are successful in their applications, and all meet their optimistic projections after three years, this TLD will require approximately 2% of the total resources available for this area of the registry system. 
In the event that registration volumes exceed projections, CentralNic will proactively increase the size of the Technical Operations, Technical Development, and support teams to ensure that the needs of the TLD are fully met. Revenues from the additional registration volumes will fund the salaries of new hires. Nevertheless, CentralNic is confident that the staffing outlined above is sufficient to meet the needs of the TLD for at least the first 18 months of operation. 

29.9 Proposed TLD Eligibility and Acceptable Use Policy 

This policy is subject to all ICANN requirements for new gTLDs, including the URS and UDRP, and will be made compliant with any future ICANN requirements as and when necessary.

Question No. 30(a)
Except where specified this answer refers to the operations of the Applicantʹs outsource Registry Service Provider, CentralNic. 
30(a).1. Introduction 
CentralNicʹs Information Security Management System (ISMS) complies with ISO 27001. CentralNic is working towards achieving full ISO 27001 certification and has secured the services of Lloydʹs Register Quality Assurance (LRQA), a UKAS accredited certifier for its ISO 27001 certification. A letter from LRQA confirming this engagement is included in Appendix 30(a).1. Stage One of this process is scheduled during May 2012, with Stage Two occurring in July 2012. The ISMS is part of a larger Management System which includes policies and procedures compliant to ISO 9001. 

30(a).2. Independent Assessment 
As part of ISO 27001 compliance, CentralNicʹs security policies will be subjected to annual external audit. Further details can be found in §30(b). 

30(a).3. Augmented Security Levels 
MLG believes that the TLD requires no additional security levels above those expected of any gTLD registry operator. Nevertheless, MLG and CentralNic will operate the TLD to a high level of security and stability in keeping with its status as a component of critical Internet infrastructure. 
Registry systems are hardened against attack from external and internal threats. Access controls are in place and all systems are monitored and audited to mitigate the risk of unauthorised access, distribution or modification of sensitive data assets. The Authoritative DNS System has been designed to meet the threat of Distributed Denial-of-Service (DDoS) attacks by means of over-provisioning of network bandwidth, and deployment of Shared Unicast (ʺAnycastʺ) addresses on nameservers. Whois services have been designed with built-in rate limiting and include mechanisms for protection of personal information. The stability of the registry is supported by use of high-availability technologies including a ʺhotʺ Disaster Recovery site in the Isle of Man, as well as a backup provider relationship with GMO Registry in Japan. 

30(a).4. Commitments to Registrars 
MLG and CentralNic will make the following commitments to the TLD registrars: 
• The SRS will be operated in a secure manner. Controls will be in place to prevent unauthorised access and modification of registry data. 
• The Whois service will prevent unauthorised bulk access to domain name registration data, and provide tools to protect personal information. 
• The DNS system will be designed to provide effective defence against DDoS attacks. The registry will proactively monitor the DNS system to provide early warning against threats to the stability of the TLD. 
• The DNSSEC system will be operated in accordance with best practices and recommendations as described in the relevant RFC documents (described in §43). 
• Security incidents reported by registrars, registrants and other stakeholders will be acted upon in accordance with the Security Incident Response Policy (see below). 
• Security vulnerabilities reported to the registry will be acknowledged and remediated as quickly as possible. 
• Registrars will be promptly notified of all incidents that affect the security and stability of the registry system and their customers, and will be kept informed as incidents develop. 

30(a).5. Access Controls 
CentralNic operates an access control policy for the registry system. For example, the web-based Staff Console which is used to administer the SRS and manage registrar accounts supports a total of ten different access levels, ranging from ʺTraineeʺ, who have read-only access to a subset of features, to ʺSystem Administratorʺ who have full access to all systems. 
Underlying server and network infrastructure is also subjected to access control. A centralised configuration manager is used to centrally control access to servers. Individual user accounts are created, managed and deleted via the configuration server. Access to servers is authenticated by means of SSH keys: only authorised keys may be used to access servers. Operations personnel can escalate privileges to perform administration tasks (such as updating software or restarting daemons) using the ʺsudoʺ command which is logged and audited as described below. 
Only operations personnel have access to production environments. Development personnel are restricted to development, staging and OT&E environments. 

30(a).6. Security Enforcement 
Security controls are continually monitored to ensure that they are enforced. Monitoring includes use of intrusion detection systems on firewalls and application servers. Attempted breaches of access controls (for example, port scans or web application vulnerability scans) trigger NOC alerts and may result in the execution of the Security Incident Response Policy (see below). 
Since CentralNic operates a centralised logging and monitoring system (see &sect42;), access logs are analysed in order to generate access reports which are then reviewed by NOC personnel. This includes access to servers via SSH, to web-based administration systems, and to security and networking equipment. Unexpected access to systems is investigated with a view to correcting any breaches and⁄or revoking access where appropriate. 

30(a).8. Security Incident Response Policy 
CentralNic operates a Security Incident Response Policy which applies to all events and incidents as defined by the policy, and to all computer systems and networks operated by CentralNic. 
The Policy provides a mechanism by which security events and incidents are defined (as observable change to the normal behaviour of a system attributable to a human root cause). It also defines the conditions under which an incident may be defined as escalated (when events affect critical production systems or requires that implementation of a resolution that must follow a change control process) and emergencies (when events impact the health or safety of human beings, breach primary controls of critical systems, or prevent activities which protect or may affect the health or safety of individuals). 
The Policy established an Incident Response Team which regularly reviews status reports and authorises specific remedies. The IST conduct an investigation which seeks to determine the human perpetrator who is the root cause for the incident. Very few incidents will warrant or require an investigation. However, investigation resources like forensic tools, dirty networks, quarantine networks and consultation with law enforcement may be useful for the effective and rapid resolution of an emergency incident. 
The Policy makes use of CentralNicʹs existing support ticketing and bug tracking systems to provide a unique ID for the event, and means by which the incident may be escalated, information may be reported, change control processes put into effect, and ultimately resolved. The Policy also describes the process by which an incident is escalated to invoke an Emergency Response, which involves Lock-Down and Repair processes, monitoring and capturing of data for forensic analysis, and liaison with emergency services and law enforcement as necessary. 

30(a).9. Role of the Network Operations Centre (NOC) 
In addition to its role in managing and operating CentralNicʹs infrastructure, the NOC plays a key role in managing security. The NOC responds to any and all security incidents, such as vulnerability reports received from registrars, clients and other stakeholders; monitoring operator and security mailing lists (such as the DNS-OARC lists) to obtain intelligence about new security threats; responding to security-related software updates; and acting upon security alerts raised by firewall and intrusion detection systems. 

30(a).10. Information Security Team 
CentralNic maintains an Information Security Team (IST) to proactively manage information security. The IST is a cross-functional team from relevant areas of CentralNic. These key members of staff are responsible for cascading rules, regulations and information to their respective departments. They are also the first port of call for their departmental staff to report potential security incidences and breaches, the IST are all members of an internal email group used to co-ordinate and discuss security related issues. 
The IST is comprised of the CEO, CTO, Operations Manager, Senior Operations Engineer and Security Engineer. 
IST responsibilities include: 
• Review and monitor information security threats and incidents. 
• Approve initiatives and methodologies to enhance information security. 
• Agree and review the security policy, objectives and responsibilities. 
• Review client requirements concerning information security. 
• Promote the visibility of business support for information security company-wide. 
• Manage changes to 3rd party services that may impact on Information Security 
• Perform internal audits with the assistance of Blackmores. 

30(a).11 Auditing and Review 
ISO 27001 includes processes for the auditing and review of security systems and policies. Audits are performed annually by an independent assessor. The IST periodically reviews the ISMS and conducts a gap analysis, identifying areas where performance does not comply with policy, and where the Risk Assessment has identified the need for further work. 

30(a).12. Testing of Controls and Procedures 
CentralNic will conduct bi-annual penetration tests of its registry systems to ensure that access controls are properly enforced and that no new vulnerabilities have been introduced to the system. Penetration tests will include both ʺblack boxʺ testing of public registry services such as Whois and the Registrar Console, ʺgrey boxʺ testing of authenticated services such as EPP, and tests of physical security at CentralNicʹs offices and facilities. 
CentralNic will retain the services of a reputable security testing company such as SecureData (who, as MIS-CDS, performed the 2009 assessment of CentralNicʹs security stance). The results of this test will be used in annual reviews and audits of the ISMS. 

30(a).13. Applicant Security Policy 
MLG will have strict security policies in place for all offices, staff, and equipment in regards to all gTLD operations.
All offices established for the operation of the gTLD will be physically separated from the general offices of MLG. In the case that gTLD offices are established within existing MLG office space, the gTLD office will have its own fire rated security doors which will be access restricted to gTLD staff, and which will remain locked at all times. Access to gTLD offices will be gained via scannable ID cards, which will automatically unlock the doors and will create a log of traffic in and out of the office. These records will be audited regularly to ensure compliance with security policies, and any discrepancies will be investigated by the Managing Director of the gTLD and the Executive Director of MLG. Visitors to the gTLD office will sign in and out and will be escorted by a staff member at all times.
All workstations and servers will be audited to ensure they adhere to best-practices for security, including needing a password to log in, which will comply with complexity requirements, and must be changed a minimum of every 30 days. Workstations and servers will be locked at all times not in use. All hard drives will be encrypted using PGP Hybrid Cryptographic Optimizer (HCO) technology, and will be FIPS 140-2 validated, CAPS-approved, DIPCOG-approved, CC EAL 4+ certified. Any data that needs to be kept on removable media for any reason will be encrypted using the same standards, and said media will be kept in a fire rated locked safe.
There will be regular audits to ensure that physical security, computer software (including anti-virus and anti-malware), and firmware are kept up to date and patched to fix the latest vulnerabilities. There are no plans to have any wireless access in the office due to security concerns with such technology. No computer cabling will extend outside the office, and all servers and network equipment will be kept in a secure room with separate locks and cooling. This server room will be kept locked at all times and only Brendon Ralfe and Evatt Merchant will have access to open this room for inspection, maintenance, or other purposes. All server and network equipment will have a redundant power supply. All servers will be backed up off-site to a 3rd party using 128 bit encryption and stored there for disaster recovery on encrypted hard drives at a minimum of 2 locations.
The offices will be secured with both a monitored alarm system, and 24 hour digital CCTV surveillance, footage from which will be kept for a minimum of 6 months.
MLG is working with CentralNic and other security experts to enhance site and network security measures in addition to policy development, employee training, and enhanced physical security measures.