28 Abuse Prevention and Mitigation

Prototypical answer:

In order to safeguard the security and stability of .TOKYO, as well as the Internet at large, GMO Registry, Inc. (the Applicant) takes abuse very seriously and employs proactive measures to mitigate abusive activities.

In general, the Applicant’s abuse mitigation strategies fall into the following broad areas:

- developing and publishing a set of comprehensive abuse policies including clear definitions of abusive activities;
- establishing and publishing a single abuse point of contact to address and resolve abuse complaints at registry startup and on an ongoing basis;
- developing procedures for handling complaints, including takedown requests, in a timely manner; and
- publishing Website Best Practices Information Page to introduce website best practices and prohibited activities under the TLD.

Draft Abusive Use Policy
The Applicant defines abuse as any activity that may harm the stability and security of the DNS and Internet, including, but not limited to:

- Illegal or fraudulent activities;
- Phishing;
- Pharming;
- Using or distributing malicious software (malware);
- Sending unsolicited bulk messages (spam);
- Posting, trading, or exchanging information that harms minors;
- Posting, trading, or exchanging child pornography;
- Posting information that encourages illegal acts, crimes, murders, or suicides;
- Posting information that is offensive to public order or morals; and
- Posting information that harms the national interest or reputation of Japan including Tokyo

The Applicant reserves the right to deny, cancel or transfer any registration or transaction, or place any domain name on lock, hold or similar status, at its sole discretion, to enforce the policy.

Abuse Public Contact Information
In order to comply with Specification 6.4.1 of New gTLD Agreement, the Applicant will provide to ICANN its Abuse contact details. The information will include a valid email and mailing address and a primary contact, and the Applicant will promptly provide to ICANN a notice of any changes to the contact.

Also, the Applicant will also publish its abuse public contact information on its website when it publicly releases the .TOKYO domain name registration policies. The abuse public contact will be responsible for handling complaints concerning abusive activities relating to domains registered under the .TOKYO TLD that violate the Abusive Use Policy and require expedited attention. The abuse public contact will be available 24 hours a day, 7 days a week. A person who wishes to contact the abuse public contact will be required to submit the Abuse Complaint Form via email or via the online Abuse Complaint Form on the registry web site.

Abuse Complaint Form
In order to gather pertinent information about a reported incident, facilitate accurate investigation, and avoid false alarms ⁄ positives, the Applicant will provide an Abuse Complaint form on the registry website. The Abuse complaint form is required at the time a person contacts the abuse public contact and can be submitted online or by email in the format specified on the registry website.

Draft Takedown Procedure
- Complaint is submitted using the abuse complaint form via email or the registry website;
- Upon receiving a complaint, the registry’s operational and registrar support team will
 assign a ticket number
 review complaint form
○ request additional information if complaint form is deemed insufficient to carry out effective investigation
 investigate the complaint to verify accuracy, and to record proof of abuse
 based on the nature of the abuse, assign level of severity: normal or emergency
○ Emergency: the registry will suspend the domain name in question and close the complaint ticket. At the same time, it will open a ticket to inform the sponsoring registrar of the suspension along with the reason.
○ Normal: open a ticket to inform the sponsoring registrar to take corrective actions. The registrar must inform the registry of actions taken. If the registrar does not take any action (that includes no response from the registrar) within a reasonable timeframe, the registry will suspend the domain name in question and close the complaint ticket.
 If the domain name was suspended by the registry, and the situation is remedied by the registrant, the registrar will contact the registry via the ticket number. The registry operational and registrar support team will verify that the issue has indeed been remedied and re-enable the domain name, closing the ticket.
 All actions by the operational and registrar support team will be logged

The Applicant understands that the Registration Abuse Policies Working Group has been working on developing best practices for registries and registrars addressing the fraudulent use of domain names. The Applicant will closely follow the working group discussions and documents, with a view of adopting the best practices to enhance abuse mitigation capabilities.

In addition, the Applicant will participate in security forums to keep track of the latest developments in abuse mitigation best practices and refine its abuse policies and procedures from time to time.

Website Best Practices Information Page
As stated in Question 18, one of the .TOKYO goals in terms of reputation is to maintain high quality contents on websites in the TLD namespace. In order to achieve the goal, the Applicant believes that it is important to mitigate abusive activities on the websites.

In addition to the mitigation mechanism described above, the Applicant will publish an information page on its website. The information page will include a list of prohibited activities under the TLD as well as best practices for web contents. The Applicant believes that the information page would help registrants understand the purpose of the TLD, clearly publicize usage restrictions of the TLD, and help mitigate abusive activities. All .TOKYO registrars will be required to place a link to the information page on their website or include it in domain name registration⁄renewal confirmation emails sent to the registrants.


Orphan Glue Records
The Applicant’s view on orphan glue records is consistent with the Security and Stability Advisory Committee Comment on Orphan Glue Records 〈http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf〉. The Applicant supports the use of orphan glue records for legitimate purposes. Upon receiving a complaint relating to an orphaned glue record used in connection with malicious activities, the Applicant will verify and take corrective actions in accordance with its takedown procedures.

Resourcing Plans
The implementation and operation of this aspect of registry operations involve the following roles:
● Technical Manager
● Network Engineer
● Applications Engineer
● Database Administrator
● System Architect
● Security Officer
● Technical Support
● Registry Administrators
● Trademark Protection Officer
● QA and Process Manager

Please note that some of these roles are included in outsourced functions.
Please refer to Question 31 for the overall FTE equivalent resources available to GMO Registry for the initial implementation and ongoing operations of the registry, of which abuse handlings a subset.

Initial Implementation
Initial implementation of this aspect of registry operations refers to:
● development of detailed procedures on the policies and procedures set forth above
● configuration of the customer support ticketing system for efficient handling of abuse complaints
● training of the operational staff

During this phase, all roles listed above are involved in the planning and implementation of their respective systems in support of this component.

Ongoing Maintenance
The ongoing maintenance of abuse mitigation involves:
● proactive monitoring of the SRS, Whois and DNS services to detect and curb abuse
● acting as the primary abuse point of contact to coordinate the handling of complaints received and escalating to relevant vendors as necessary
● monitoring of security mailing lists for takedown requests arising from security researchers and emergency response teams
● participating in relevant ICANN communities to engage in knowledge sharing, implementing best practices that may emerge


The follow roles are involved in this phase of the operations:
● Technical Manager
● Technical Support
● Security Officer
● Registry Administrator
● Trademark Protection Officer
● QA and Process Manager
Please note that some of these roles are included in outsourced functions.

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