29 Rights Protection Mechanisms

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.公益China Organizational Name Administration Centerconac.cnView

29 Rights Protection Mechanism
CONAC identifies rights protection as a core objective. CONAC not only establishes mechanisms for providing effective protections that meet ICANN’s minimum requirements, but also adopts additional measures that exceed minimum requirements of ICANN to protect registrants’ rights.

CONAC’s registration policy, with its Pre-registration Qualification Procedures (PQP) which includes pre-verification and re-verification of eligible registrants ensures a very high level of rights protection. Since the eligible registrants are made up of global public interest organizations that provide services in Chinese language, the risk of abuse is relatively low as these organizations fulfill public duties.

CONAC, registrars and registrants shall abide by the following rights protection mechanisms to guarantee interests of relevant parties:

1. The Rights Protection Mechanisms that CONAC shall follow include: safeguards against allowing unqualified registrations, PDDRP, measures for reducing phishing, pharming or other malicious behavior, trademark claims service and sunrise service, URS, preventing abusive use policies, takedown procedures, re-verification of PQP, periodic registration data monitoring, information sharing with anti-abuse community and annual registrar trainings.

2. Rights Protection Mechanisms that the registrars shall follow include: UDRP, Pre-verification of PQP, Continuous Compliance Mechanism, joining CONAC annual registrar training and Registry Registrar Agreement (RRA).

3. Rights Protection Mechanisms that registrants shall follow include: Registration Policies and Registration Agreement.

29.1 Minimum Protections of Rights
CONAC will implement rights protection mechanisms that comply with the minimum requirements in Specification 7 of the Registry Agreement and are consistent with the technical, operational, and financial approach of the registry. CONAC will comply with all current rights protection mechanisms and dispute resolution mechanisms. For those ICANN accredited registrars that enter into the RRA with CONAC, their compliance with the above rights protection mechanism is a compulsory requirement.

29.1.1 Safeguards against Allowing Unqualified Registrations and Other Rights Protection Mechanisms
CONAC’s registration policies, in particular the PQP and the naming conventions, will effectively mitigate domain name disputes. CONAC abides by ICANN mechanisms and has developed specific measures to effectively implement registration policies, and to prevent violations of the registration qualification and regulations. Registration Policies
CONAC has formulated a set of naming conventions, registration restrictions, reserved names and registration prohibitions to prohibit unqualified registrations (including eligibility requirements, which will be described in detail in Section 29.2.1).

In CONAC’s naming conventions, it is regulated that all applied-for domain names shall contain at least one Chinese character, digital numbers (0~9) and hyphen (-) are also allowed to use combined with Chinese characters; each level is separated by “.” or Chinese full stop “。”. The applied-for domain name can be the full name, the official abbreviation, the habitual abbreviation or other names of an organization. When using the full name or the official abbreviation of an organization, the domain name shall be consistent to the name approved by relevant authorities; when using the habitual abbreviation of an organization, the domain name shall be consistent to the name that is widely used. In principle, such “公益” domain names shall contain names of relevant administrative divisions, industry types (such as 教育” [education] and “科技” [science and technology], etc.) and organization forms (such as “院” [academy], “所” [institution], “校” [school] and “中心” [center], etc.) When using other names, the domain name shall be consistent to the functions and business scope of the organization that are approved by its governing authority; CONAC has also developed registration policies to deal with multiple application for a single domain name.

In CONAC’s restricted registration policies, it is regulated that if an applied for domain names containing the characters of “中国” (China), “中华” (China), “国家” (Nation), “全国” (Nationwide) or “中央” (Central), the applicant shall submit necessary approval documents; CONAC complies with Specification 5 of the Registry Agreement, and reserves names formed with the listed labels from initial registration within the TLD.

CONAC also prohibits domain name registrations under ten circumstances, including registrations that are against the basic principles prescribed in China’s Constitution. See responses to Question 18 (Section 18.2.4) for details about CONAC’s registration policies. See “Implementing Rules for ‘公益’ Domain Name Registration” for more details (http:⁄⁄www.conac.cn). Measures to Guarantee the Compliance with the Registration Policies
To guarantee compliance with the registration policies, CONAC requires the registrars to pre-verify all registration information received, and then submit the verified information to CONAC for re-verification.
1. Pre-verification by the Registrars
CONAC requires all registrars to initially review the policy compliance of all applied for domain names, items include:
1) the compliance with CONAC’s registration policy;
2) the compliance with the IDN table (.CN Chinese); and
3) the completeness of the submitted information.
Only a domain name that complies with CONAC’s registration policy, with character strings listed in the .cn IDN table and with complete registration information can pass the pre-verification by the registrars, otherwise, the registrar shall reject the unqualified application with reasons for the rejection given and “.公益” domain name registration policy attached.

The above terms will be included in the RRA (the draft will be posted on CONAC’s website, which is http:⁄⁄www.conac.cn, before ICANN pre-delegation check phase). Any registrar that violates the above terms will be liable for breach of the agreement.

2. Re-verification by CONAC
CONAC re-verifies the registration information submitted by the registrars with the same criteria as the pre-verification. A domain name can go live after passing registrar’s pre-verification and CONAC’s re-verification. CONAC Complies with PDDRP
In accordance with the Application Guidebook (AGB), the Trademark Post-Delegation Dispute Resolution Procedure (PDDRP) is intended to cover Trademark post-delegation dispute resolution proceedings generally. The parties to the dispute could be a trademark holder or a gTLD registry operator.

CONAC will comply with decisions made by the PDDRP expert panel, and adhere to and be bound by reasonable remedies ICANN imposes. CONAC will designate a legal staff to be responsible for PDDRP liaising, and for coordinating CONAC and the registrars to implement the panel’s decisions. Upon receiving the decision and the remedy from the PDDRP expert panel, if the party does not seek a de novo appeal or challenges the remedy, CONAC will implement the determination in three (3) business days after the end of appeal period and will notify the registrar of the status in three (3) business days. If a party appeals or challenges the remedy, CONAC will implement the final effective decision. In the RRA, CONAC will regulate that the registrars shall implement the related expert decisions, remedies or court verdicts. Any registrar that violates the term will be liable for breach of the RRA. CONAC Complies with the Uniform Domain Name Dispute Resolution Policy (UDRP)
CONAC will specify in the RRA that registrars must implement the UDRP policy. The registrars will be liable for breach of the requirements in the RRA.

The UDRP will be incorporated into the registrants’ Registration Agreement, and set forth the terms and conditions in connection with a dispute between the registrar and any party other than the registrar over the registration and use of an Internet domain name registered by the registrar. CONAC has good collaboration with Beijing Office of the Asian Domain Name Dispute Resolution Centre (ADNDRC), and receives prompt information regarding domain name complaints.

29.1.2 Measures for Reducing Network Phishing, Pharming and Other Malicious Behaviors
Malicious behaviors such as phishing and pharming are big threats to the domain name system’s security. In accordance with the definitions given by the Registration Abuse Policies Working Group (RAPWG), CONAC has established a set of mechanism to prevent, detect and resolve phishing, pharming and other malicious behaviors. These mechanisms are described as following. Further details can be found in the response to Question 28. Eligible registrants are made up of global public interest organizations that provide services in Chinese language, thus the risk of phishing, pharming and other malicious behaviors is relatively low as these organizations fulfill public duties. Protection Measures
CONAC will play an active role in education, and ensure that all parties including registrants and registrars are aware of the phishing and pharming risks and other malicious acts. CONAC enforces registrant PQP, authentication procedures and relevant technical measures to prevent malicious behaviors including phishing and pharming. For example, as pharming threats, especially those initiated from the DNS cache poison, can be largely alleviated by the deployment of DNSSEC, CONAC will promote the adoption of DNSSEC in the “.公益” subdomains. Additionally, CONAC will advocate and establish an emergency procedure to flush the spoofed domain or poisoned DNS cache and recover from the pharming attacks in cooperation with the Internet community upon the receipt of complaints of pharming attacks.

CONAC has added the abuse prohibition terms into the RRA, stipulating that registrars shall not conduct abusive behavior. Breaches of the RRA may inter alia result in CONAC ceasing the registration services of “.公益” domain names and terminating the RRA. CONAC requires the registrars incorporate abuse prohibition terms in the registrant’s Registration Agreement and all registrants must sign a letter of commitment before registering a “.公益” domain name. Detection Measures
CONAC foresees being alerted to suspected abuses through three channels: the first is by receiving complaints from affected parties, the second is by alarms given by the monitoring system deployed according to the characteristics of abuses, and the third is by the information reflected by anti-abuse communities.

The single point of contact’s hotline number, email box and postal address are posted on CONAC’s website (http:⁄⁄www.conac.cn) and complaints regarding abusive domain names registered in “.公益” TLD will be received 7x24x365.

CONAC requires all registrars to post the hotline number, postal address, email address and contact person on their websites. CONAC will keep ICANN and all relevant registrars updated if the information changes. Resolution Procedures
1. The Complaint Handling Institution and Its Responsibility
CONAC has set up an Anti-Abuse Working Group (AAWG). The working group is composed of 2 CONAC staff and 3 invited experts who are versed in the fields of computer network security, cryptography, intellectual property and community management. All working group members have deep understanding of the Internet and related laws, and have strong professional ethics and are able to independently and neutrally judge the abuse complaint. The working group holds meetings regularly, or Ad-Hoc Meetings if necessary.

The main tasks of the working group include:
1) To accept and handle abuse complaints;
2) To track the latest anti-abuse research outcomes and research on anti-abuse issues in the global domain name communities;
3) To identify and define abuse types that are related to “.公益” domain names;
4) To analyze abusive behavior and develop anti-abuse policies;
5) To establish a coordination and linkage mechanism for anti-abuse community with ICANN, China Internet Network Information Center (CNNIC) and National Computer network Emergency Response technical Team (CNCERT).

2. Measures for Handling Malicious Behaviors
A complaint regarding phishing, pharming and other malicious behaviors may be solved by the complainant and the respondents (collectively referred to as the parties) through consultations, be submitted to the AAWG established by CONAC for settlement, or be submitted as a legal action to a competent people’s court in China. CONAC will confirm with the complainant the receipt of a complaint with in one (1) business day, and AAWG will then inform the complainant whether the complaint is accepted within five (5) business days.

3. The Consequences of Handling Malicious Behaviors
CONAC Anti-Abuse Working Group will stay well informed of ICANN’s polices concerning abuse and correspondingly determine methods of identifying abuses, and implements normal⁄rapid handling process. (See Section 28.5.2, 28.2.2, 28.5.3 and 28.5.4 for details).In case the AAWG decides that the abuse has clear facts and irrefutable evidences and cause serious consequences, the AAWG will activate the rapid handling process and will suspend the domain name within 48 hours (See Section 28.5.4 for details). When the working group receives a request from a judicial authority, it will provide timely response and rapidly suspend the domain name concerned. Any abuse involving a crime will be referred to the judicial authority. If any party disagrees with the decision for abuse complaint by the AAWG, it is entitled to lodge a lawsuit with a competent people’s court in China within 15 days as of the date of the delivery of the decision. CONAC shall execute the verdict given by the court.

29.1.3 Trademark Claims Service and Sunrise Service
As the Trademark Clearing House is still in development, CONAC commits to comply with the policies and procedures when they are finalized. CONAC will utilize the Trademark Clearing House and implement a Trademark Claims service and Sunrise service in conjunction with the Trademark Clearing House. Given the nature of public interest organizations and the eligibility criteria of the “.公益” TLD, it is likely the number of trade mark claims will be limited.

In accordance with ICANN’s requirements, CONAC will provide the Trademark Claims service for marks contained in the Trademark Clearinghouse for the first 60 days that registration is open for registration. The Trademark Claims Notice will provide the prospective registrant a warning that the applied for domain name matches a trademark contained in the Trademark Clearinghouse Database. A similar notice will be sent to the Trademark owner notifying them that a person has registered a domain name that matches their trademark. CONAC will abide by the variant policies and procedures for Trademark clearing house (TCH) set by ICANN when providing trademark claims services.

CONAC provides a sixty (60) calendar days’ sunrise service, it doubles ICANN’s minimum requirement. CONAC will offer sunrise registration service during the sunrise period and a notice will be provided to all trademark holders in the Clearinghouse if someone is seeking a sunrise registration. During the sunrise process, the holders of eligible trademarks can apply for their corresponding domain name(s) directly under the “.公益” TLD before registration is open to the public. The fees associated with the sunrise services will be determined by the costs that CONAC will pay to the Trademark Clearing House Service Provider and reasonable profits. CONAC will abide by the variant policies and procedures for Trademark clearing house (TCH) set by ICANN when providing sunrise services.

In addition, CONAC will advertise our trademark claims services and sunrise services via popular Chinese TV channels, internet and magazines from the day “.公益” TLD is delegated until it pre-launches. CONAC will also explore establishing a hotline for sunrise service to ensure that trademark owners are aware of the sunrise period.

29.1.4 CONAC Complies with the Uniform Rapid Suspension system (URS)
Trademark holders can initiate a complaint by the Uniform Rapid Suspension system (URS) when their trademark rights are infringed. CONAC will comply with the URS, and implement decisions rendered under the URS on an ongoing basis. For the domain name involved in the dispute, CONAC establishes the following process flow below for responding to URS decisions. CONAC will also designate a legal staff in charge of contacting the URS provider, and feedback the results of the implementation of the decision to the URS provider and all parties.

As the implementer of the URS provider’s decision, CONAC will follow the guidance given by the URS provider. To the extent that the URS provider does not make clear whether both the domain name and its preferred variant should be locked,CONAC, in recognition of the complications associated with deciding whether the variant infringes the trademark rights, will contact the URS provider to seek clarification on the issue. and locking of domain names
CONAC will “lock” the domain name within 24 hours upon receipt of the Notice of Complaint from the URS provider, meaning that the updating, transfer and deletion of the domain name will be prohibited, but the domain name will continue to resolve. CONAC will notify the URS provider via email that this domain name has been locked. Upon receiving the decision notice
Upon receiving the decision notice from the URS provider, if the complainant wins the dispute, CONAC will immediately suspend this domain name for the remaining registration period, and the domain name will not be resolved to the original website. The domain name server shall redirect it to URS information prompt page provided by the URS provider. WHOIS data for the domain name will continue displaying all information of the original registrant, but not display the redirection of the name server. In addition, WHOIS will indicate that this domain name must not be transferred, deleted or modified in the current registration period. If the complainant loses the decision, the locked status of this domain name will be removed.

29.2 Additional Measures for Rights Protections that Exceed Minimum Requirements of ICANN
Besides measures that meet ICANN’s minimum requirements, CONAC takes additional measures to protect rights of the registrants and other obliges seriously.

29.2.1 The Pre-registration Qualification Procedures (PQP) Content of PQP
The PQP developed by CONAC extends the concept of the ordinary “pre-verification” procedure. The PQP covers all content stated in Section (registrar pre-verification and CONAC re-verification). Additionally, the PQP also verify the eligibility of the domain name applicant to ensure all registrants are eligible for registering the domain name. The strict PQP mechanism is determined by the special nature of “.公益” domain name registrants. The eligible public interest organizations register corresponding“.公益”domain names which may improve the public trust of the TLD, thus guarantee the interest of internet users and global public interest organizations that provide services in Chinese language. Detailed Steps of the PQP
1. Pre-verification by Registrars
CONAC requires all registrars to stipulate the term of pre-verification in their registration agreement signed with registrants. The PQP requires the registrars to pre-verify the eligibility of each registrant via registrant information and certificates provided. The PQP is designed to verify the following items:
That the registrant information is complete, true and accurate, and the Application Form has an official stamp of the registrant; that the registrant is legally established; that the contact information is true; that the applicant represents the organization whose name matches the applied-for domain name; and all content stated in Section applied-for domain name can pass the registrar’s pre-verification only when all the above information meets CONAC’s requirement, otherwise, the registrar shall reject the application with reasons for the rejection given and “.公益” domain name registration policy attached. The above terms will be included in the RRA. Any registrar that violates the above term will be liable for breach of the agreement.

The necessary information provided by the registrant organization includes: name and certificate of legal establishment, registrant contact, administrative contact and technical contact. If any of the registration information is inaccessible, CONAC will require the registrar to verify such information. If the inaccessibility remains unchanged for more than 3 months, the domain name cannot be registered.

2. Re-verification by CONAC
CONAC re-verifies the registration information submitted by the registrars with the same criteria as the pre-verification. A domain name can go live after passing registrar’s pre-verification and CONAC’s re-verification.

In terms of domain name transfers, all application material shall be initially reviewed by the registrar and then be submitted to CONAC for further reviews. Domain names that pass CONAC’s further review can be transferred.

CONAC implements a Staff Performance Appraisal Systems for rewarding and disciplining staff in the re-verification positions to ensure good quality in the procedure.

29.2.2 Authentication Procedures Content of Identity Authentication
The identity authentication is designed to ensure the domain name applicant has official representativeness of the entity that matches the domain name. CONAC authenticates applicants’ identities through registration data verification. The requirements for registration data include that: (1) the email address submitted must be working and responsive; (2) the organization address and name must correlate; and (3) true registration contact information must be provided. The applicant can pass the identity authentication only when all information above meets CONAC’s requirements. Procedure for Authentication
1. Measures Taken by CONAC
The deployed monitoring system performs a monthly scan of the entire registration database for the accuracy and completeness of registration data. The specific methods are as follows: the first method is an analysis of data completeness. CONAC checks some registration data at random semimonthly and adopts corresponding algorithms to select matching data in accordance with various patterns of previously incomplete data. The second method is an analysis of data accuracy. CONAC establishes interface with the authoritative databases owned by the registration authorities of global public interest organizations that provide services in Chinese language to make comparison between agency information in CONAC’s domain name database and that in the authoritative databases, in a bid to discover inaccurate data or no corresponding data in the authoritative databases. The third method is random sampling analysis. The data not drawn as sample data in the past three years is sampled and the proportion of random sampling will be determined in accordance with the domain name registrations of CONAC.

CONAC customer service staff will check and verify data accuracy for domain name holders and contact persons by phone or email. If there is any incomplete or inaccurate data, CONAC will establish an internal tracking list of incomplete information. At the same time, CONAC will urge the registrar to request the domain name holders to provide the missing information, and will request the registrar verify the information provided. In case the registrar fails to provide necessary information in time, the system will regularly give a notice to the registrar and determine the punishment in accordance with the implementation situation.

2. Measures Taken by Registrars
After the domain name registration becomes effective, the registrar shall conduct continuous review on the qualification of domain name applicant and the use condition of domain name in accordance with CONAC’s measures for domain name review. The registrar shall check that the registrant is the qualified holder of the domain name, and that the information is authentic and complete. When the check is successfully completed, the domain name may pass the CCM.

Follow-up handling measures include: 1) the domain name reviewed to be qualified will be continuously used; 2) in case of inconformity between the domain name holder and registration information, the registrar shall request that the domain name holder to submit valid documentary evidences within five (5) working days, otherwise the domain name will be suspended; 3) when the domain name holder requests to change domain name information, the same procedures of the PQP are applicable to the new information provided by the domain name holder so as to ensure that the changed domain name accords with CONAC’s registration policies.

29.2.3 Abuse Prevention Policies
CONAC will prevent and prohibit abuses to the greatest extent possible and to handle the abuse in a timely manner. Measures to Prevent Abuses
1. PQP and Authentication Procedures
CONAC enforces PQP and authentication procedures to prevent abuses. Theoretically, by executing PQP and authentication procedures, CONAC is capable of preventing the abuses including cyber squatting, Front‐running, Gripe sites, deceptive and⁄or offensive domain names, Name spinning to the greatest extend. See Section 29.2.1 and 29.2.2 for more details of PQP and authentication procedures.

2. Notifications before Expiration
To prevent Fake renewal notices, CONAC requires the registrars to send domain name expiration notifications to registrants thirty (30) days and sixty (60) days in advance, to list all domain names that will expire in sixth (60) days on CONAC’s website, and to provide information in the WHOIS, including domain name expiring date.

3. Information Sharing with Anti-Abuse Communities
CONAC will coordinate closely with the anti-abuse communities to stay abreast of the latest trends in registration abuse, domain name abuse behavior and registrant protection measures, in a bid to protect legal rights of registrants. CONAC also shares anti-abuse information with registrars. See 28.5.5 for more details.

4. Annual Training
CONAC requires all registrars to participate in annual training courses, sharing experiences of anti-malicious behaviors, and improve registrars’ capability of fighting abuses. When submitting a domain name application, the registrars are required by CONAC to verify the identity of the registrant through PQP to mitigate abuses and protect the interests of the registrant. Measures to Handle Abuses
CONAC has established a complete set of mechanisms to handle abuses, which cover regulating channels to detect abuses, establishing the AAWG, defining its role and working mechanism, specifying procedures and results for abuse handling. Since phishing, pharming and other malicious behavior belong to abuses, the working mechanism of the AAWG is applicable to phishing, pharming and other malicious behaviors as well as abusive behaviors. Please refer to and for detailed implementation measures.

In accordance with definitions of main types of abuses given by the Registration Abuse Policies Working Group (RAPWG), CONAC has developed specific measures and procedures to handle abuses in either a rapid or a normal handling process, See 28.5.2, 28.2.2, 28.5.3 and 28.5.4 for details.

The AAWG assesses the severity level of the abuse and decides whether the issue should proceed to the rapid or the normal handling process. This decision will be based on the way in which people are affected by the abuse and actual loss and damage brought about by the abuse. CONAC has regulated time limit for complaint acceptance and handling.
1. Ordinary Handling Process
CONAC’s abuse complaint process for normal cases sets out that the AAWG will notify the complainant whether the complaint is accepted within five (5) business days, and will handle the process to reach a decision within fifteen (15) business days.

When the complainant and the respondent agree with the decision of the Anti-Abuse Working Group, CONAC (or⁄and the domain name holder, registrar or other stakeholders) will execute the decision. The domain name with judged abuse will be taken down.

When the complainant or the respondent disagrees with the decision given by CONAC Anti-Abuse Working Group, it may lodge a lawsuit to a competent people’s court in China within 15 calendar days after the decision was delivered. CONAC will finally execute the verdict of the court.

2. Rapid Handling Process

In case the AAWG finds that the abuse has clear facts and irrefutable evidence and cause serious consequences, especially the abuse identified by URS and Anti-Phishing Alliance of China (APAC) or a complaint concerning criminal acts, the AAWG will activate the rapid handling process and will deliver a decision within 48 hours.

The AAWG will activate the rapid handling process and will suspend the domain name within 48 hours (See Section 28.5.4 for details). When the working group receives a request from a judicial authority or law enforcement, it will launch a rapid handling process and give timely response and rapidly suspend the domain name concerned within 48 hours. Any abuse involving crime will be reported to judicial authority in a timely manner.

CONAC will notify the stakeholders, including complainant, respondent, domain name holder, registrar and anti-abuse joint action community about the decision within three (3) business days after the suspension.

The domain name holder may lodge a complaint in three (3) business days after receiving the notice. CONAC will make a decision on the complaint within 15 business days. If the evidence provided by the domain name holder is sufficient enough, the domain name holder may succeed in the claim with the domain name restored in 48 hours by CONAC; if the domain name holder does not respond to the claim or fails to prove the claim, CONAC will take down the domain name in 48 hours after the claim expiring date or the failure date (See Section 28.5.4 for details).

29.2.4 Initiate Takedown Procedures Conditions for takedown
CONAC initiates domain name takedown procedures in the following circumstances:
1) In accordance with PDDRP, ICANN imposes the remedies to delete registrations (when registrants have been shown to be officers, directors, agents, employees, or entities under common control with CONAC), and the party does not challenge the remedy or fails in challenging the remedy.
2) When a domain name suspension is decided by the AAWG, with no appeal being lodged before the end of appeal period or appeal failure or a domain name abuse is finally affirmed by courts through judicial process. Working Procedures for Takedown
CONAC offers “Takedown” in the SRS to takedown certain domain names. The domain name and its corresponding variant form which infringes legitimate rights will be immediately removed from the “.公益” zone file. CONAC will notify the registrant according to the contact information included in the content registration form. The Registrar of record (as listed in the WHOIS) will be copied on this correspondence.

29.3 Resourcing Plan
In addition to the resource identified in the response to Question 28, CONAC will allocate 4 people in the positions of marketing and customer support. The resource is sufficient for the initial implementation and ongoing maintains. The detailed resource allocations are as follows:

1 Legal Affairs Staff (Legal Affairs role B: 1 Staff), responsible for communicating with service providers of PDDRP, URS and UDRP, etc., notifying the outcomes to relevant parties; and responding disputes regarding “.公益” domain names.

3 Customer Support Staff (Customer Support role D: 3 Staff), including the following three distinct positions:
1 staff is responsible for notifications regarding trademark claim services and sunrise services;
1 staff is responsible for initiating takedown procedure;
1 staff is responsible for distributing shared information to the anti-abuse community and carries out annual registrar trainings.

All the aforementioned staff are currently in place. Detailed skillset requirements on the staff can be found in section 31.3.3 in the response to Question 31.

Costs of resources allocation are detailed in costs and capital expenditure of Question 47a and 47b.

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