29 Rights Protection Mechanisms
|gTLD||Full Legal Name||E-mail suffix||Detail|
|.doctor||DotMedico TLD Inc.||radixregistry.com||View|
DotMedico TLD Inc. is a wholly owned subsidiary within the Directi Group. The Directi Group runs various businesses including several ICANN Accredited Domain Registrars (including ResellerClub.com and BigRock.com) and Web Hosting companies. At Directi, through our decade long experience as a domain name registrar, we have consciously strived to ensure that domain registrations through our platform do not violate the intellectual property or other rights of any person or organization.
Our experience as a domain name registrar gives us insight into the necessity and importance of rights protection, and the mechanisms that must be employed to assure it. With .Doctor, we shall leverage our experience to implement a comprehensive set of policies and procedures that will uphold intellectual property rights to the greatest possible extent.
The protection of trademark rights is a core goal of .Doctor. .Doctor will have a professional plan for rights protection. It will incorporate best practices of existing TLDs, going above and beyond the ICANN mandated RPMs to prevent abusive registrations and rapidly take-down abuse when it does occur.
1. PREVENT ABUSIVE REGISTRATIONS
We will put into place the following measures to ensure prevention of registrations that infringe the IP rights of others
1.1 ELIGIBILITY REQUIREMENTS
.Doctor will have a well defined eligibility requirements policy for domain registrations within .Doctor along with a dispute resolution process (Eligibility Restrictions Dispute Resolution Process - ERDRP) to resolve potential abuse. Our Eligibility policy and process has the following impact on RPMs -
* Ensures that general domain names within .Doctor are registered by licensed medical doctors
* Ensures that in the unlikely scenario of a registrant or domain name that violates our eligibility criteria the same can be addressed through the ERDRP
* Ensures that the identity of the registrant is validated before the domain name is activated
1.1.1 ELIGIBILITY POLICY SUMMARY
This section provides salient aspects of our proposed eligibility policy. The actual policy will be drafted in line with the tenets described herein. Details regarding the implementation of these policies are provided in the next section of this response
* General Names will be available for registration to licensed medical doctors
* The identity of the registrant must be validated before a domain name is activated
* The above applies to general domain names whether registered during sunrise, landrush or general availability
* Registry reserved generic domain names within .Doctor maybe allocated in the future through other equitable means (including auctions) such as to registrants who can demonstrate business plans that will promote the .Doctor namespace and benefit the registrants of general names within .Doctor.
By ensuring that a general domain name is only activated after the validation of eligibility requirements policy and identify verification we ensure zero abuse of the name space, and digital assertion of the Registrant. The validation will be performed by an external 3rd party agency.
1.1.2 ELIGIBILITY POLICY IMPLEMENTATION
188.8.131.52 GENERATING AWARENESS
* The Eligibility policy implementation plan and ERDRP will be published on our Registry website which will be accessible and have clear links from the home page
* The policies will also be clearly communicated to potential Registrants during the registration process
184.108.40.206 REGISTRATION STEPS
* A customer applies to register a domain name
* Locks are applied to a Domain name upon initial registration to prevent any updates
* The domain is directed to a temporary landing page providing next steps to the Registrant
* The domain name and the Registrant information is sent to an external agency to validate. The agency validates the domain name against the eligibility requirements policy. The agency also validates the accuracy of the Registrant identity and contact information. We will appoint an agency that will perform this validation process for us. A sample quote for such a service has been provided in the financial answers.
* Upon successful validation, the locks are removed. The Registrant will be able to modify the nameservers of the domain and activate the same
* If the validation fails the domain name is deleted
220.127.116.11 CONTRACTUAL ENFORCEMENT
The following features of the Eligibility policy described above will be executed by the inclusion of corresponding clauses in our RRA, which will require inclusion in registrars’ Domain Name Registration Agreements:
* The Registrant must maintain accurate contact information for a domain name
* The Registrant must agree to the Eligibility policy, and to proceedings under the ERDRP
1.2 SUNRISE PROCESS
Our sunrise registration service will provide trademark holders with atleast a 30-day priority period in which to register their trademarks as domain names.
Sunrise Timeline -
Day 1:Single sunrise round opens
Day 30:Sunrise round closes
Day 31:Sunrise allocation begins and Sunrise period ends
1.2.1 SUNRISE POLICY SUMMARY AND SDRP SUMMARY
This section provides a summary of our Sunrise Policy and SDRP. We have formulated our policies and processes based on existing guidance concerning Sunrise and TMCH provided by ICANN. Any additional guidance in the future that requires changes to our process and policies will be implemented.
Through our Sunrise Policy we will offer atleast one 30-day sunrise round in which trademark holders satisfying the Sunrise eligibility requirements proposed in the ‘gTLD Applicant Guidebook’ will be eligible to apply for a domain name. This sunrise period will be the first opportunity for registration of domain names in .Doctor. Trademarks upon which sunrise applications are based must meet the criteria defined in the ‘gTLD Applicant Guidebook’ and be supported by an entry in the TMCH.
Sunrise allocation will start at the end of the 30-day sunrise period. If one validated application is received for a domain name, the same will be allocated to the applicant in the 10-day period following the end of the sunrise period. Where multiple validated applications are received for a domain name, the name will be allocated by auction. Domain names registered during the sunrise period will have a min. term of 1 yr.
We will adopt a Sunrise Dispute Resolution Policy (‘SDRP’) to allow any party to raise a challenge on the four grounds identified in the ‘gTLD Applicant Guidebook’. All registrants will be required to submit to proceedings under the SDRP. SDRP claims may be raised at any time after registration of a domain name.
18.104.22.168 SUNRISE PRICING
We plan to charge a non-refundable Sunrise application fee or validation fee of $80 for every Sunrise application. We have arrived at the fee to offset the cost of the trademark validation and other administrative over-heads.
22.214.171.124 SUNRISE IMPLEMENTATION PLAN
1. Prior to sunrise, trademark holders should apply for inclusion of their marks in the TMCH database.
2. Our Sunrise Policy and SDRP will be published on our website.
3. A trademark holder satisfying the sunrise eligibility requirements will pay the non-refundable sunrise application fee and submit its application corresponding to its TMCH entry to a registrar along with evidence of the corresponding TMCH entry.
4. Registrars will send the sunrise applications to ARI. They will be charged the application fee at this time.
5. ARI will perform standard checks to ensure that the domain name is technically valid and hold the application for subsequent allocation.
6. Upon conclusion of the 30-day sunrise period, ARI will compile a list of applied-for names and reserve these from registration in land rush and general availability.
7. Sometime during this process ARI or the registrar (as prescribed) will identify all sunrise applications which constitute an ‘Identical Match’ (as defined in the ‘gTLD Applicant Guidebook’) with a TMCH entry and provide notice to the holders of the filing of a sunrise registration.
8. Where a single sunrise application exists for a particular domain name ARI will enable the sponsoring registrar to CREATE the domain name and we will charge the sunrise registration fee to the registrar.
9. Where multiple sunrise applications exist for a domain name, ARI will compile and communicate to a 3rd-party auction services provider appointed by us a list of competing applicants, who will be invited to participate in an auction for the domain name.
10. The auction services provider will facilitate the auction process and upon completion of the auction will notify all participants of the outcome and collect the auction payment from the winning participant.
11. Upon payment of the auction bid, the auction services provider will communicate to ARI the details of the winning auction participant and will submit the revenue collected to ARI.
ARI will validate the communication from the auction services provider and enable the sponsoring registrar to CREATE the domain name.
126.96.36.199 SDRP IMPLEMENTATION PLAN
When a domain is awarded and granted to a registrant, that domain will be available for lookup in the public WHOIS.
After a Sunrise name is awarded it will also remain under a “Sunrise Lock” status for at least 60 days. During this period the domain will not resolve and cannot be modified, transferred, or deleted by the sponsoring registrar. A domain name will be unlocked at the end of that lock period only if it is not the subject of a Sunrise Challenge. Challenged domains will remain locked until the dispute resolution provider has issued a decision, which the registry operator will promptly execute.
SDRP filings will be handled by an appropriate service provider as per ICANN guidance and policy.
188.8.131.52 IMPLEMENTATION THROUGH CONTRACTUAL RELATIONSHIPS
The following features of the Sunrise and SDRP implementation plans described above will be executed by the inclusion of corresponding clauses in our RRA, which will require inclusion in registrars’ Domain Name Registration Agreements:
* By making a sunrise application the applicant agrees to purchase the domain name if that name is allocated to the applicant.
* The sunrise application fee is non-refundable.
* All sunrise applicants must submit to proceedings under the SDRP.
1.3 TRADEMARK CLAIMS SERVICE
For atleast 60 days during general availability we will offer the trademark claims service as described in the ‘gTLD Application Guidebook’.
184.108.40.206 TRADEMARK CLAIMS SERVICE IMPLEMENTATION PLAN
This process will be executed for atleast the first 60 days of general availability:
1. an applicant will make an application to a registrar for a domain name.
2. Registrars will be required to communicate land rush application information to our registry backend provider - ARI.
3. ARI or Registrars (as prescribed) will interface with the TMCH to determine whether an applied-for domain name constitutes an ‘Identical Match’ with a trademark in the TMCH. If an ‘Identical Match’ is identified, the registrar will provide to the land rush applicant a Trademark Claims Notice in the form prescribed by the ‘gTLD Applicant Guidebook’. Following receipt of this notice a land rush applicant must communicate to the registrar its decision either to proceed with or abandon the registration.
4. ARI or Registrar (as prescribed) will interface with the TMCH to promptly notify relevant mark holders of the registration of a domain name constituting an ‘Identical Match’ to their TMCH entry.
220.127.116.11 IMPLEMENTATION THROUGH CONTRACTUAL RELATIONSHIPS
The following features of our Trademark Claims Service Implementation Plan described above will be executed by the inclusion of corresponding clauses in our RRA:
* Registrars must comply with the TMCH as required by ICANN and the TMCH Service Provider⁄s.
* Registrars must not in their provision of the trademark claims service make use of any other trademark information aggregation, notification or validation service other than the TMCH.
* In order to prevent a chilling effect on registration, registrars must ensure that land rush applicants are not prevented from registering domain names considered an ‘Identical Match’ with a mark in the TMCH.
* Registrars must provide clear notice in the specific form provided by the ‘gTLD Applicant Guidebook’ to the prospective registrant of relevant entries in the TMCH.
* Registrars must interface with the TMCH as prescribed to relevant mark holders of the registration of a domain name constituting an ‘Identical Match’ to their TMCH entry.
2. ONGOING RIGHTS PROTECTION AND ABUSE PREVENTION
Below we describe ongoing RPMs which we will implement to mitigate cybersquatting and other types of abusive behaviour such as phishing and pharming.
2.1 UNIFORM RAPID SUSPENSION (URS)
The URS (Uniform Rapid Suspension) procedure is a new RPM the implementation of which is mandated in all new gTLDs. Understanding that a fundamental aim of the URS is expediency, all of the steps in our Implementation Plan below will be undertaken as soon as practical but without compromising security or accuracy.
18.104.22.168 URS IMPLEMENTATION PLAN
1. We will provide to each URS provider an email address to which URS-related correspondence can be sent. On an ongoing basis, our compliance desk will monitor this email address for receipt of communications from URS providers, including the Notice of Complaint, Notice of Default, URS Determination, Notice of Appeal and Appeal Panel Findings.
2. We will validate correspondence from a URS provider to ensure that it originates from the URS Provider.
3. We will within 24 hours of receipt of a URS Notice of Complaint lock the domain name⁄s the subject of that complaint by restricting all changes to the registration data, including transfer and deletion of the domain name. The domain name will continue to resolve while in this locked status.
4. We will immediately notify the URS provider in the manner requested by the URS provider once the domain name⁄s have been locked.
5. Upon receipt of a favourable URS Determination we will unlock the domain name and redirect the nameservers to an informational web page provided by the URS provider. While a domain name is locked, our backend provider - ARI - will continue to display all of the WHOIS information of the original registrant except for the redirection of the nameservers and the additional statement that the domain name will not be able to be transferred, deleted or modified for the life of the registration.
6. Upon receipt of notification from the URS provider of termination of a URS proceeding we will promptly unlock the domain name and return full control to the registrant.
7. Where a default has occurred (because a registrant has not submitted an answer to a URS complaint in accordance with the ‘gTLD Applicant Guidebook’) and a Determination has been made in favour of the complainant, in the event that we receive notice from a URS provider that a Response has been filed in accordance with the ‘gTLD Applicant Guidebook’, we will as soon as practical restore a domain name to resolve to the original IP address while preserving the domain’s locked status until a Determination from de novo review is notified to us.
8. We will ensure that no changes are made to the resolution of a registration the subject of a successful URS Determination until expiry of the registration or the additional registration year unless otherwise instructed by a UDRP provider.
9. We will make available to successful URS complainants an optional extension of the registration period for one additional year.
22.214.171.124 IMPLEMENTATION OF THE URS THROUGH CONTRACTUAL RELATIONSHIPS
The following features of our URS Implementation Plan described above will be executed by the inclusion of corresponding clauses in our RRA:
* In the event that a Registrant does not submit an answer to a URS complaint in accordance with the ‘gTLD Applicant Guidebook’, registrars must prevent registrants from making changes to the WHOIS information of a registration while it is in URS default.
* Registrars must prevent changes to a domain name when a domain is in locked status to ensure that both the Registrar’s systems and Registry’s systems contain the same information for the locked domain name.
* Registrars must not take any action relating to a URS proceeding except as in accordance with a validated communication from us or a URS provider.
The UDRP (Uniform Domain Name Dispute Resolution Policy) is applicable to domain name registrations in all new gTLDs. It is available to parties with rights in valid and enforceable trade or service marks and is actionable on proof of all of the following three grounds:
1. The registrant’s domain name is identical or confusingly similar to a trademark or service mark in which the complainant has rights.
2. The registrant has no rights or legitimate interests in respect of the domain name.
3. The registrant’s domain name has been registered and is being used in bad faith.
The remedies offered by the UDRP are cancellation of a domain name or transfer of a domain name registration to a successful UDRP claimant.
126.96.36.199 UDRP IMPLEMENTATION PLAN
We have two responsibilities in order to facilitate registrars’ implementation of the UDRP -
1. Our backend provider – ARI - will maintain awareness of UDRP requirements and be capable of taking action when required and sufficiently skilled and flexible to respond to any changes to UDRP policy arising from future consensus policy reviews.
2. We will provide EPP and the SRS web interfaces to enable registrars to perform required UDRP functions in accordance with the Policy on Transfer of Registrations between Registrars.
188.8.131.52 IMPLEMENTATION OF THE UDRP THROUGH CONTRACTUAL RELATIONSHIPS
The UDRP is applicable to domain name registrations in all new gTLDs by force of a contractual obligation on Registry Operators to use only ICANN-accredited registrars, who in turn are contractually required to incorporate the UDRP in their Domain Name Registration Agreements.
3. ADDITIONAL RIGHTS PROTECTION MECHANISMS
The protection of trademark rights is a core goal of .Doctor. Our Right Protection Mechanisms, policies and procedures go significantly above and beyond the minimum mandated RPMs to prevent abusive registrations, rapidly take-down abuse when it occurs, and foster a clean namespace for .Doctor
This section describes several other RPMs that .Doctor will implement that exceed the minimum requirements for RPMs and align with our goal of creating a namespace that provides maximum protection to trademark holders.
3.1 REGISTRANT PRE-VERIFICATION
.Doctor will have a well defined eligibility requirements and name selection policy for domain registrations within .Doctor along with a dispute resolution process (Eligibility Restrictions Dispute Resolution Process - ERDRP).
As described in section 1, domain names will not be activated before an extensive manual verification is done for each registration against our Eligibility criteria and Name selection policy and until the identity of the Registrant is validated thus ensuring zero abuse of the name space, and digital assertion of the Registrant. The validation will be performed by an external 3rd party agency.
3.2 OPTIONAL TRADEMARK DECLARATION
This is a unique feature of our .Doctor. During General Availability, we will continue to make available, the EPP Trademark extension fields that are provided during sunrise. Registrants will be able to specify their IPR details against their domain names even after sunrise. The fields will include – word mark, registration number, applied date, registration date, jurisdiction, class. These fields will be editable by the Registrant and visible in Whois.
The ability for a Registrant to voluntarily declare Trademark data even during general availability will reduce potential confusion amongst mark holders and the general public and reduce unnecessary UDRP procedures.
3.3 PROFILING & BLACKLISTING
This process, currently in practice for our registrar businesses within the Directi Group, is used for gathering intelligence on known offenders. We maintain abuse ratios for each of the 1,000,000 plus registrants and 65,000 plus resellers who use Directi.
Experience has enabled us to use these ratios accurately to uncover registrants who are known and repeated offenders. Expert offenders rarely reuse the same registrant profile and often maintain a myriad number of profiles to mask their true identity. Through pattern mapping we try and group registrant profiles that we believe belong to the same operator.
The same process is followed at the reseller level too, to identify those resellers who are knowingly harboring offenders, or are themselves involved in abuse.
When a registrant profile is confirmed to be involved in organized abuse, including but not limited to cybersquatting, phishing, pharming etc., our immediate step is to suspend that customer’s control over his abusive domain portfolio. Our compliance team then carefully analyzes each domain name to identify those which are abusive and not already taken-down. The necessary action is undertaken to diffuse any ongoing abuse.
We plan to adopt the ‘Profiling and Blacklisting’ process within our registry operations. Since all of our compliance resources will be trained and experienced in running this process, its implementation into .Doctor will be simple. Specifics of this policy and process, as it applies to our registry business, will be drawn out.
3.4 PROACTIVE DOMAIN QUALITY ASSURANCE
As a preventive safeguard against abusive domain registration, we follow a consistent review process for domain registrations on our registrar, where a sample of newly registered domain names are analyzed for potential abusive activity. Coupled with our profiling process (described above), it enables us to take proactive measures against domain names that are registered solely to perpetrate malicious activities such as phishing, or otherwise infringe on the rights of others. This helps us curb abusive activity before it can affect too many Internet users. We shall seek to implement similar safeguards for .Doctor, and encourage registrars to incorporate this practice as part of their abuse mitigation processes.
3.5 INDUSTRY COLLABORATION
3.5.1 ACTIVE INVOLVEMENT WITH SECURITY AGENCIES
In order to mitigate abuse of domain names on our registrar business, our abuse team has active involvement in helping security vendors and researchers fight domain abuse. They provide us a constant feed of abuse instances and help us identify domain names involved in activities like phishing or pharming. Some of the prominent organizations we work with include PhishLabs (phishing), LegitScript (illegal pharmaceutical distribution), Artists Against 419 (financial scams), Knujon (spam) etc. We will leverage these relationships to ensure oversight for all domain names registered within .Doctor.
3.5.2 APWG REVIEW
Every six months, the Anti-Phishing Working Group (APWG) publishes its latest Global Phishing Survey [See http:⁄⁄www.apwg.org⁄resources.html#apwg]. This study contains an analysis of phishing per TLD. We will review the performance of our anti-abuse program against the APWG reports, and other metrics created by the security community. We will work closely with APWG to combat phishing within .Doctor
3.5.3. MESSAGE OF ZERO TOLERANCE
Our Anti-Abuse Policy will put Registrants on notice of the ways in which we will identify and respond to abuse and serve as a deterrent to those seeking to register and use domain names for abusive purposes. The policy will be made easily accessible on the Abuse page of our Registry website which will be accessible and have clear links from the home page along with FAQs and contact information for reporting abuse.
The Directi Group has vast experience in minimizing abusive registrations. Our zero tolerance procedures and aggressive proactive takedown measures as a Domain Registrar have resulted in a white-hat reputation discouraging abusive registrations to begin with. We intend on following the same approach with respect to Registry operations for .Doctor. Our proactive abuse procedures are geared towards building a reputation that discourages miscreants and malicious intent. Once it is known that abusive registrations and registrations in violation of our policies are suspended rapidly, this will directly result in discouraging abusive registrations and creating a clean namespace. While following this path will mean a higher compliance and abuse vigilance cost for us, we believe this effort will pay us long term rewards through abusers keeping away and .Doctor becoming recognized as a reputable namespace.
4. REDUCING PHISHING AND PHARMING
All of the measures we have described in the preceding sections significantly reduce phishing and pharming within .Doctor. These include RPMs like URS, UDRP and Eligibilty restrictions.
Over and above this our coordination with APWG, Industry Collaboration, Profiling and Blacklisting processes and Proactive measures described in Section 3 above will go a long way in ensuring a clean namespace for .Doctor and considerably reduced phishing and pharming activities.
5. PREVENTING TRADEMARK INFRINGEMENT IN OPERATING THE REGISTRY
We take seriously our responsibilities in running a registry and we understand that while offering a sunrise registration service and the trademark claims service during start-up of our TLD and the URS and UDRP on an ongoing basis serves to minimise abuse by others, this does not necessarily serve to minimise trademark infringement in our operation of the TLD. This responsibility is now clearly expressed and imposed upon registries through the new Trademark PDDRP [Post-Delegation Dispute Resolution Procedure], which targets infringement arising from the Registry Operator’s manner of operation or use of its TLD.
Whilst we will as required under the Registry Agreement agree to participate in all Trademark PDDRP procedures and be bound by the resulting determinations, we will also have in place procedures to identify and address potential conflicts before they escalate to the stage of a Trademark PDDRP claim.
1. We will notify to the Trademark PDDRP provider⁄s contact details to which communications regarding the Trademark PDDRP can be sent.
2. We will publish our Anti-Abuse Policy on a website specifically dedicated to abuse handling in our TLD.
3. Using the single abuse point of contact discussed in detail in our response to Q28, a complainant can notify us of its belief that that one or more of its marks have been infringed and harm caused by our manner of operation or use of our TLD
4. We will receive complaints submitted through the single abuse point of contact.
5. The Compliance Team will acknowledge receipt of the complaint and commence investigation of the subject matter of the complaint and good faith negotiations with the complainant in accordance with the ‘gTLD Applicant Guidebook’.
6. On an ongoing basis, our Compliance Team will monitor the email address notified to the Trademark PDDRP provider⁄s for all communications from the Trademark PDDRP provider, including the threshold determination, Trademark PDDRP complaint, complainant’s reply, notice of default, expert panel determinations, notice of appeal and determinations of an appeal panel.
7. In the event that a complaint cannot be resolved and a Trademark PDDRP claim is made, we will do the following:
* File a response to the complaint in accordance with Trademark PDDRP policy section 10 (thus avoiding, whenever possible, a default situation).
* Where appropriate, make and communicate to the Trademark PDDRP provider decisions regarding the Trademark PDDRP proceeding, including whether to request a three-person Trademark PDDRP Expert Panel, request discovery, request and attend a hearing, request a de novo appeal, challenge an ICANN-imposed Trademark PDDRP remedy, initiate dispute resolution under the Registry Agreement, or commence litigation in the event of a dispute arising under the Trademark PDDRP.
* Where appropriate, undertake discovery in compliance with Trademark PDDRP policy section 15, attend hearings raised under section 16 if required, and gather evidence in compliance with sections 20.5 and 20.6.
8. We will upon notification of an Expert Panel finding in favour of the Claimant (Trademark PDDRP policy section 14.3), reimburse the Trademark PDDRP Claimant.
9. We will implement any remedial measures recommended by the expert panel pursuant to Trademark PDDRP policy and take all steps necessary to cure violations found by the expert panel and notified by ICANN.
6. RESOURCING PLANS
Functions described herein will be performed by:
* Directi Group Abuse and Compliance team under contract with us -
** Overseeing Sunrise process
** Abuse complaints concerning RPM
** Coordinating with an external agency for Registrant and domain name validation as per our registration policies
* ARI’s backend Registry
* Service Providers that are selected wrt TMCH, UDRP, URS, ERDRP and SDRP
* Director of Technology at .Doctor & Account Management staff at .Doctor
** Overseeing Sunrise process
** Communication of the sunrise process to Registrars
Directi Group possesses an exemplary track record of diffusing abuse on 4 million plus domains under their Registrar business. The Rights protection and abuse mitigation function of our Registry will be handled by the same team that currently manages this process for the registrar businesses.
The existing compliance team comprises of:
* 1 Compliance Manager
* 1 Team Supervisor
* 4 Cyber Security Analysts
* 9 Compliance Officers
The compliance function is staffed on a 24⁄7⁄365 basis and capable of handling up to a peak of 52,800 unique abuse incidents per year. Each incident by itself can relate to a few to hundreds of domain names.
While this team is trained to investigate and verify all types of issues, they can also fall back on support from our technical staff when required. Similarly, abuse cases following new or unexpected parameters may also be escalated to legal support staff for expert counsel.
Our estimates of resource sizing are directly derived from the abuse case incident volumes currently experienced. On a base of 4 million domains as a Registrar, we experience approximately the following incidents per year:
* UDRP Cases - 200
* Other RPM incidents - 20 cases
This averages an incident rate of approximately 220 cases of abuse per year or 0.055 incidents per 1000 names. Given that this is based on a more mature base of names, it would be prudent to assume a higher rate of activity for .Doctor. Based on our experience we have assumed the increase in activity rate to be three fold (300% of the current rate) and increase it to 0.165 per 1000 names.
Based on our projections, we expect .Doctor to reach 64,896 domain names at the end of the third year. Extrapolating from our estimated rate of 0.165 incidents per 1000 names, we can expect around 11 incidents yearly. Including the estimated 182 Abuse incidents that the registry will handle (details in our response to Q28), brings our total projected incident count to 193.
The Compliance desk works as a centralized team and all team members are responsible for all abuse complaints across all businesses of Directi. Costs of the Compliance team are then allocated to each business based on the % utilization of the compliance team by each business. We have assumed 15% of 2 compliance officers’ time towards .Doctor. Given that our 15 people team has the capacity to handle 52,800 incidents yearly, 2 officers with 15% of their time, will have a total capacity to handle 1056 incidents annually which is more than adequate for the Registry. It is important to point out that 15% of the 2 officers is merely a cost allocation method and in actuality all 15 members and more of the Compliance team will be available to resolve abuse issues for TLD.
Our planning provides us redundant capacity of 10X in Y1, 6X in Y2 and 4.5X in Y3, to handle both abuse as well as RPM related cases such as those involving URS. This leaves substantial headroom for rapid growth of domains under management, or a sudden surge in abuse incident rates per domain.
It is also important to note that there exist some economies of scale in our operations since a large number of these cases are dealt with in bulk, or large batches, as they relate to the same instigator(s).
The Abuse and Compliance team has a structured training program in place which enables them to rapidly scale-up resources when required. Typically a team of recruits are given four weeks of training and two weeks on the floor before they are fully activated.
Given our rapid growth rate and business expansion plans, we will continue to hire and maintain a sizable buffer over and above anticipated growth.
6.2 FINANCIAL COSTS
The usage of Directi Group’s staff is included in our contract with Directi attached to Q46. This cost is shown in the financial answers.
The Eligibility requirements validation will be conducted by an external agency and the costs for the same are shown in the financial answers.
This completes our response to Q29.
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