28 Abuse Prevention and Mitigation

Prototypical answer:

Question 28 - Abuse Prevention and Mitigation



The dot XFINITY Top Level Domain (TLD) will be a closed registry. All domain names will be registered to and used by authorised representatives of Comcast, the registry operator. As such, domain names will be subject to direct controls by the registry operator to avoid abuse and the risk of abusive registrations will therefore be significantly mitigated.



Abuse



Abuse is defined as action in the registration or usage of a domain in the TLD that would cause actual and substantial harm, and is illegal or illegitimate. Such abuse may occur at any stage of the domain name lifecycle.



In the context of domain name registration, abuse includes infringement of a third party right where the domain is used in a way that is unfairly detrimental to that third party. Abuse also includes phishing, pharming, botnets, fraud and other abuses that are identified in the future or that are brought to the Registryʹs attention.



Abusive activity also includes that which gives rise to the registryʹs reasonable belief that the dot XFINITY domain space is being brought into disrepute; or where the activity related to a dot XFINITY domain name risks placing the Registry in breach of any applicable laws, government rules or requirements; requests of law enforcement; or where any such activity would be likely to give rise to any liability, civil or criminal, on the part of the Registry Operator and Registry Services Provider, affiliates, subsidiaries, officers, directors, and employees.



Single point of contact



In advance of the launch of the dot XFINITY TLD, a single abuse point of contact responsible for addressing matters requiring expedited attention will be published. This will be clearly visible on the registryʹs existing website at comcast.com and on the new registry website.



Registration policy



Comcast will establish a Naming Committee to be responsible for the development, maintenance and enforcement of the dot XFINITY Registry Domain Management Policy (DMP). This policy defines the rules associated with eligibility and domain name allocation, sets out the license terms governing the use of a dot XFINITY domain name and describes the dispute resolution policies for the dot XFINITY TLD. This policy is intended to be updated and revised regularly to reflect Comcastʹs strategic plans and, where appropriate, ICANN consensus policies.



The policy sets out that registration must comply with the following regarding abuse prevention:

- Domains must be used solely for purposes that enhance the strategic goals of Comcast.

- dot XFINITY domains may not be used in a way which knowingly infringes any third party intellectual property rights.

- A dot XFINITY registration must be an acceptable term that will not give rise to any moral or public order questions or in any way damage the strategic interests or reputation of Comcast.

- All dot XFINITY domains will carry accurate and up to date registration records.

- dot XFINITY domain names may not be used for illegal activities

- dot XFINITY domain names may not be used for other activities that would be considered as abusive. This includes, but is not limited to : phishing, pharming, fraud, distribution of malware.



The Naming Committee reserves the right to place the domain name in ʹserverHoldʹ status, thus removing it from the zone file, or to delete a Comcast domain name at any time.



Complaints policy and procedure



Comcast treats complaints from members of the public extremely seriously and will establish a complaints procedure to enable members of the public to complain about dot XFINITY domain names, or any content accessed via those domain names. The procedure will be publicised on the Registryʹs existing website at comcast.com and at the new Registry website. It will provide a first stage complaints procedure to Comcastʹs dedicated complaints team, a second stage internal appeals procedure to the Naming Committee and a third stage procedure for further appeal, to Comcastʹs senior management team. Complainants will be able to submit their complaint via the website, by post or by telephone and Comcast will generally respond to complaints within 10 working days. Comcastʹs response may include, if appropriate, an apology and an explanation as to how Comcast intends to resolve the complaint.



Any person wishing to complain about alleged abusive registrations or other activities concerning the operation of the dot XFINITY domain would be entitled to utilise this complaints procedure in the usual manner.



In the event that resolving a complaint requires the suspension (removing the domain name from the zone file, but not from Whois records) or cancellation of a domain name, this will be handled by the Naming Committee.



Rights holders will also have the option to complain via the UDRP and URS about any registration that they regard as abusive, but the Applicant would encourage any concerned rights holders to contact it in the first instance to attempt to resolve their concerns informally. Further details regarding rights protection can be found in the answer to question 29.



Nominet, the registry provider, has well-established relationships with Law Enforcement agencies. Nominet and Comcast will work together to respond to complaints by these agencies, and such complaints will be acknowledged by Nominetʹs abuse team within twenty four hours.



Following review, the complaint may result in one of the following actions:



- Modification of the usage of the domain name

- Suspension of the domain name

- Cancellation of the domain name.



Proposed measures for removal of orphan glue records



The default process for dot XFINITY is to automatically detect and remove orphan glue records. However, where clear evidence in written form is presented that orphan glue records are present in the zone files of dot XFINITY, Nominet, the registry service provider, will take the following action:

- A change request will be presented to Nominetʹs second line support team by the person handling the complaint. The orphan glue record will be manually removed from the register and, if necessary, locks will be put in place which will prevent any further changes being made to the domain name record in question.

- The dot XFINITY zone files update dynamically and so within 5 minutes of the change being made on the register the zone files will reflect the changed name server record.

Nominet runs a daily audit of the contents of its zone files and compares these against the contents of the registry database. In the event of a mismatch, Nominet personnel are alerted and the mismatch is corrected. This audit will help to reduce the occurrence of orphan glue records.



Measures to promote WHOIS accuracy



Comcast is committed to transparency in relation to domain name registration records and to the provision of complete and accurate Whois records.



As a closed registry, in which only Comcast personnel will be able to register second level domain names and only for business purposes, Comcast will be able to ensure the accuracy and completeness of all Whois records.



All domain names must be registered through the Naming Committee. As part of this process, Comcast personnel requesting the registration of a new second level domain will be required to provide a statement as to their business need for the domain name as well as full contact details of their name, position and business area.



The Naming Committee will perform regular audits to ensure this data remains up to date and accurate.



Information sharing



Nominet is well established in national and international industry networks covering registry specific threats as well as threats to the broader Internet landscape. It will continue this work, ensuring dot XFINITY is as resilient and secure as it can be.



Nominet provides an aggregated feed of information highlighting domain names in its domains used for phishing purposes to the relevant registrar. This feed is collated from trusted sources and allows registrars to take prompt action against abusive domains. In the event that any dot XFINITY domain names appear in the feed, action will be taken by Comcastʹs Naming Committee to remove abusive content or to place the domain name in ʹserverHoldʹ



Controls to ensure proper access to domain functions



The ability to register domain names and amend details on the register will be limited to members of the Naming Committee. Access to the mechanisms by which such changes can be made will be password protected as a minimum, and consideration will be given to implementing further security measures (such as multi-factorial authentication). Records will be kept of all registration and amendment requests to maintain a full audit trail.



Resource plan



Comcast will establish a Naming Committee that will be responsible for all domain name registrations for Comcast. It is anticipated that this team will be responsible for the accuracy of Whois details.



In addition, Comcast has a dedicated team responsible for responding to complaints. As to whether additional personnel will be required to accommodate any uplift in complaints as a result of the operation of dot XFINITY will be closely monitored and addressed as necessary.



Nominet has a large customer support team from which it operates the dot UK registry. It will provide sufficient resources to deal with orphan glue records and Law enforcement complaints. It is expected that this will require less than one hour per week from this team.

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