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27 Registration Life Cycle

gTLDFull Legal NameE-mail suffixDetail
.incUniregistry, Corp.internet.proView
TABLE OF CONTENTS

27.1 DOMAIN REGISTRATION LIFECYCLE
27.1.1 Note on the Status Codes
27.1.2 Initial Registration ⁄ Add-Grace
27.1.3 Registration Changes Affecting The Registration Lifecycle
27.1.4 Expiration of Registration Term
27.1.5 Delete Cycle and Redemption Grace Period
27.1.6 Deletion
27.2 RESOURCING PLANS
27.2.1 Human Resources
27.3 ABOUT THIS RESPONSE

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27.1. DOMAIN REGISTRATION LIFECYCLE

The domain registration cycle for second-level domain name registrations in .INC is substantially the same as the well-understood life cycle in the existing generic top-level domains.

Second-level domain names are registered for a term which is an integer number of years, up to a maximum registration term of ten years.

An initial Add Grace Period (AGP) of five days is provided during which domain names registered as a consequence of error or registrar malfunction can be canceled. To deter the abusive practice of “domain tasting” or “domain kiting” registrars must provide a report of circumstances under which the Add Grace Period is invoked, and are limited to a fixed proportion of such instances.

During the registration period, second-level domain names may be transferred from one registrant to another, and from one registrar to another. Such names are subject to transfers, cancellations, and de-activation in accordance with intellectual property protection and abuse policies described under the relevant responses of this Application.

A substantial improvement to security and stability is provided through the addition of a “quiet period” that occurs after expiration of a domain name and prior to deletion of that domain name from the registry. While ICANN has addressed the practice of Add Grace abuse at the initial period of domain registration, the problems associated with a deterministic domain deletion cycle have gone unaddressed.

One of these problems is rapid polling of registry systems by those seeking to instantaneously register deleted domain names. The intent may be to innocently acquire deleted names for a legitimate new use. Or the intent may be to acquire recently deleted names in order to usurp the prior registrantʹs identity. (Naive prior registrants may not realize that after abandoning a name that a successor may use that domain name to maliciously masquerade as that prior registrant or to monetize residual network traffic coming into that name.)

Quiet periods of this type are a standard practice for many internet service provider account identities and email addresses; an extended and non-deterministic period of non-availability for domain names responds to registry stability and registrant security issues which have not been addressed in the existing generic top-level domains to date.

The significant events of a standard domain lifecycle are explained in the following sections, and graphically depicted in the two flow diagrams as follows:

See EXHIBIT ʺ27-Figure-Domain-Lifecycle-1.pngʺ referenced as 27-1 below; and

See EXHIBIT ʺ27-Figure-Domain-Lifecycle-2.pngʺ referenced as 27-2 below.

27.1.1. Note on the Status Codes

Object status codes used in this answer have been based on the status codes explained in the following references

* RFC 3915 -- Domain Registry Grace Period Mapping for the Extensible Provisioning Protocol (EPP)
* RFC 5730 -- Extensible Provisioning Protocol (EPP)

27.1.2. Initial Registration ⁄ Add-Grace

Referring to step 1 of Exhibit 27-1, a second level domain name is accepted for registration if (a) it is not already registered or reserved, (b) it satisfies the string requirements (e.g. 63 allowable characters, no trailing dashes, etc.), and (c) administrative requirements of the Registrar Accreditation Agreement are satisfied, such as prohibition against securing registrations for which a registrar has not obtained assurance of payment.

During the first five days of registration, at step 2, the domain name is subject to an initial Add-Grace period (AGP). The purpose of the AGP is to provide an opportunity for a registrar to discontinue a registration made in error, such as by a malfunction of registrar software resulting in unintended registrations. As shown in steps 3-5, if a delete command is received during the AGP, the registrar is refunded the registration fee, and the registration proceeds to immediate deletion at step 39 (label D, Exhibit 27-2). During the AGP, the ICANN Add Grace Period Limits Policy (http:⁄⁄www.icann.org⁄en⁄tlds⁄agp-policy-17dec08-en.htm) shall be applied to deter “domain tasting”.

Significant provisions of the ICANN AGP include:

A. During any given month, the registry shall not offer any refund to a registrar for any domain names deleted during the AGP that exceed (i) 10% of that registrarʹs net new registrations in that month (calculated as the total number of net adds of one-year through ten-year registrations), or (ii) fifty (50) domain names, whichever is greater, unless an exemption has been granted for extraordinary circumstances.

B. A registrar may seek a specific one month retroactive exemption from application the AGP restrictions upon the documented showing of extraordinary circumstances. For any registrar requesting such an exemption, the registrar must confirm in writing to the registry how, at the time the names were deleted, these extraordinary circumstances were not known, reasonably could not have been known, and⁄or were outside the Registrarʹs control. Acceptance of any exemption will be at the sole and reasonable discretion of the registry in consultation with ICANN. ʺExtraordinary circumstancesʺ which reoccur regularly for the same Registrar will not be deemed extraordinary. Invocation of such circumstances for any two one-month periods in a single year will result in application of the second-tier penalties described in the response to Question 29, and successive tiered penalties for each month thereafter, leading to de-accreditation.

C. The registry shall report each instance of application of an exemption to ICANN, along with a brief descriptive identification of the type of extraordinary circumstance and the action, approval or denial that was taken by the registry.

If the registration is not deleted during the AGP, it proceeds to the registration term (step 6).

27.1.3. Registration Changes Affecting The Registration Lifecycle

Registrations during the contracted term will be subject to actions which do not affect the lifecycle, such as WHOIS updates and nameserver changes. Also, during the registration term Uniregistry may re-assign nameservers to prevent resolution of a domain name due to action taken under the Uniregistry Abuse Policy (see Question 29), or in response to a decision under the Uniform Rapid Suspension Policy (URS) requiring that the domain name resolve to a designated web page indicating that the domain name has been disabled. Uniregistry will also implement such changes as may be ordered by a court of competent jurisdiction or necessitated by registrar de-accreditation. Absent such unusual circumstances, any of the following actions prior to expiration of the registration term, will result in extension or shortening of the term:

Extension of Term (EPP command ʺrenewʺ), step 8: A registration can be extended prior to expiration of the registration term in one year increments up to a total of ten years maximum. The account of the sponsoring registrar at the time of the additional extension will be charged for the number of years the registration is extended. As indicated in steps 12-14, if a delete command is received within a period of five days, the registrar will be credited for the previously charged extension, and the registration will proceed to the Delete Cycle (label A, Exhibit 27-2).

Express Deletion (EPP command “delete”), step 9: An express deletion issued by the sponsoring registrar during the registration term will initiate the Delete Cycle (label A, Exhibit 27-2).

Registrar Transfer (EPP command “transfer”), step 10: If a gaining registrar issues a transfer command, the registry will re-assign the authoritative registrar for a domain name upon receipt of a valid transfer request and authorization code. Transfers shall be implemented in accordance with the current version of the ICANN Inter-Registrar Transfer Policy (http:⁄⁄www.icann.org⁄en⁄transfers⁄). If the losing registrar expressly authorizes the transfer, the transfer shall proceed immediately. Otherwise, the transfer will proceed within five days. When the registration is assigned to the gaining registrar, the expiration date of the domain is extended by at least one year, and limited by the maximum registration term of ten years, and the gaining registrar is charged accordingly. As indicated in steps 21-23, if an express deletion is issued by the gaining registrar within five days, the registrar is credited for the renewal fee mandated by the transfer, and the registration proceeds to the Delete Cycle (label A, Exhibit 27-2). Otherwise, the registration continues in accordance with the new registration term (step 6).

27.1.4. Expiration of Registration Term

Registrars will be required to implement the relevant provisions of the ICANN Expired Domain Deletion Policy (EDDP) (http:⁄⁄www.icann.org⁄en⁄registrars⁄eddp.htm) for names subject to deletion as a consequence of non-renewal, and to accept renewal payments for names subject to dispute in accordance with the provisions of the EDDP relating to domain dispute procedures.

At, step 7, upon the completion of the contracted registration term, the registration proceeds to an Auto-Renew Grace Period (ARGP) of forty five days in step 24. The sponsoring registrar is required to notify the registrant of impending expiration at least twice prior to expiration - once at least 30 days prior to expiration and once within 30 days of expiration. By default under the ARGP, expired domain names will be automatically renewed by the registry for a single year.

In steps 25 and 26, if a domain is deleted within the ARGP, the sponsoring registrar at the time of the deletion receives a credit of the renewal fee (step 14), and the registration proceeds to the Delete Cycle (label A, Exhibit 27-2). If no delete command is issued during the ARGP, then the renewal is confirmed, and the registration proceeds in accordance with the renewed term (step 6). A registration can also be expressly renewed and its term extended beyond a single year during the Auto-Renew Grace Period, subject to a limit of ten years total. The account of the sponsoring Registrar at the time of the additional extension will be charged for the additional number of years the registration is extended.

In step 27 of Exhibit 27-1, if a domain is transferred within the Auto-Renew Grace Period, the losing Registrar is credited with the Auto-Renew charge (step 28), the year added by the Auto-Renew operation is canceled, and the registration proceeds to the transfer process described above (label E, Exhibit 27-1). In the event of a bulk transfer with ICANN approval during the Auto-Renew Grace Period (such as may occur upon de-accreditation of the sponsoring registrar), the expiration dates of transferred registrations are not affected and the losing registrarʹs account is charged for the Auto-Renew.

27.1.5. Delete Cycle and Redemption Grace Period

A Redemption Grace Period (RGP) is applied at the initial step 30 of the Delete Cycle. The RGP is a period of six months, during which the subject registration is placed on REGISTRY-HOLD, and nameserver records for the registration are removed from the zone file, such that the domain name will not resolve. This six month period is significantly longer than the present industry standard, which has been subject to community criticism for not providing sufficient time for registrants with extenuating circumstances. Rendering the registration non-functional in this manner is effectively the final notice to the registrant that the name is subject to deletion at the end of the RGP, even if inaccurate contact data or other technical issue resulted in failure of the registrant to receive renewal reminders or expiration notices.

During the RGP, as indicated in steps 31-35, the registration may only be restored to the original registrant, subject to issuance of a “restore” command (step 32), followed by receipt of a redemption report from the sponsoring registrar (step 35) within a Restore Lock Period of five calendar days (step 34). During the RLP, the nameservers are restored, and the domain status is:

PENDING RESTORE + UPDATE PROHIBITED + DELETE PROHIBITED + RENEW PROHIBITED + TRANSFER PROHIBITED

If a Restore Report is not received from the registrar within the RLP, the nameservers are removed, and the domain is returned to step 30 until expiration of the RGP with status of:

PENDING DELETE RESTORABLE + HOLD

In order to restore the registration, a redemption report submitted in step 35 must indicate that the registrar has (a) verified identity of the party seeking redemption of the registration, (b) paid a renewal fee, and (c) paid an RGP service fee for reviewing the redemption report circumstances of requested redemptions. If so, the registration returns to step 6 of Exhibit 27-1 for the renewed term of registration.

Extension of the RGP to six months, as proposed herein, addresses a frequently-criticized aspect of current registration practices, under which a successive registrant of a previously registered domain name may utilize it to engage in identity fraud or reputational damage to the previous registrant. The six month period proposed here, reduces the efficacy of this abusive practice.

27.1.6. Deletion

If the registration is not redeemed during the RGP, it proceeds to Pending Delete status in step 36. Here, the lifecycle varies significantly from the standard gTLD registration lifecycle. Instead of a deterministic interval between the end of RGP and the start of deletion, a random, non-published time interval of 1 to 30 days is set for final deletion of the registration. When the random deletion period has elapsed (step 38), the registration proceeds to final deletion from the registry (step 39).

Registrars found to be engaging in unreasonably repetitive registration attempts of registrations during the Quiet Period (such as attributable to automated processes being conducted by or through the registrar, and not as a consequence of manual availability queries by end users) will be suspended from registry access until the cause of such repetitive attempts are eliminated. Repeated suspensions for this reason shall lead to the graded penalties described in the response to Question 28 of loss of incentives, financial penalties, and ultimate de-accreditation.
27.2. RESOURCING PLANS

Costs and procurement of the resources described here are detailed in response to Question 47.

27.2.1. Human Resources

See EXHIBIT: ʺ27-Chart-Resourcing.pngʺ.

27.3. ABOUT THIS RESPONSE

We believe that this answer meets the requirements and addresses all the points of this question:

* We have provided a complete and detailed statement of the registration lifecycle to be used for .INC.
* This lifecycle is substantially the same as the well-understood life cycle in the existing generic top-level domains.
* We have modified the lifecycle to redress problems, such as identity theft, that can occur when names are deleted.
* This lifecycle is coupled to and consistent with our abuse mitigation policies.
* We have adequate technical, operational, legal, and financial resources to handle this lifecycle.
gTLDFull Legal NameE-mail suffixDetail
.dealUniregistry, Corp.internet.proView
TABLE OF CONTENTS

27.1 DOMAIN REGISTRATION LIFECYCLE
27.1.1 Note on the Status Codes
27.1.2 Initial Registration ⁄ Add-Grace
27.1.3 Registration Changes Affecting The Registration Lifecycle
27.1.4 Expiration of Registration Term
27.1.5 Delete Cycle and Redemption Grace Period
27.1.6 Deletion
27.2 RESOURCING PLANS
27.2.1 Human Resources
27.3 ABOUT THIS RESPONSE

- - - - -

27.1. DOMAIN REGISTRATION LIFECYCLE

The domain registration cycle for second-level domain name registrations in .DEAL is substantially the same as the well-understood life cycle in the existing generic top-level domains.

Second-level domain names are registered for a term which is an integer number of years, up to a maximum registration term of ten years.

An initial Add Grace Period (AGP) of five days is provided during which domain names registered as a consequence of error or registrar malfunction can be canceled. To deter the abusive practice of “domain tasting” or “domain kiting” registrars must provide a report of circumstances under which the Add Grace Period is invoked, and are limited to a fixed proportion of such instances.

During the registration period, second-level domain names may be transferred from one registrant to another, and from one registrar to another. Such names are subject to transfers, cancellations, and de-activation in accordance with intellectual property protection and abuse policies described under the relevant responses of this Application.

A substantial improvement to security and stability is provided through the addition of a “quiet period” that occurs after expiration of a domain name and prior to deletion of that domain name from the registry. While ICANN has addressed the practice of Add Grace abuse at the initial period of domain registration, the problems associated with a deterministic domain deletion cycle have gone unaddressed.

One of these problems is rapid polling of registry systems by those seeking to instantaneously register deleted domain names. The intent may be to innocently acquire deleted names for a legitimate new use. Or the intent may be to acquire recently deleted names in order to usurp the prior registrantʹs identity. (Naive prior registrants may not realize that after abandoning a name that a successor may use that domain name to maliciously masquerade as that prior registrant or to monetize residual network traffic coming into that name.)

Quiet periods of this type are a standard practice for many internet service provider account identities and email addresses; an extended and non-deterministic period of non-availability for domain names responds to registry stability and registrant security issues which have not been addressed in the existing generic top-level domains to date.

The significant events of a standard domain lifecycle are explained in the following sections, and graphically depicted in the two flow diagrams as follows:

See EXHIBIT ʺ27-Figure-Domain-Lifecycle-1.pngʺ referenced as 27-1 below; and

See EXHIBIT ʺ27-Figure-Domain-Lifecycle-2.pngʺ referenced as 27-2 below.

27.1.1. Note on the Status Codes

Object status codes used in this answer have been based on the status codes explained in the following references

* RFC 3915 -- Domain Registry Grace Period Mapping for the Extensible Provisioning Protocol (EPP)
* RFC 5730 -- Extensible Provisioning Protocol (EPP)

27.1.2. Initial Registration ⁄ Add-Grace

Referring to step 1 of Exhibit 27-1, a second level domain name is accepted for registration if (a) it is not already registered or reserved, (b) it satisfies the string requirements (e.g. 63 allowable characters, no trailing dashes, etc.), and (c) administrative requirements of the Registrar Accreditation Agreement are satisfied, such as prohibition against securing registrations for which a registrar has not obtained assurance of payment.

During the first five days of registration, at step 2, the domain name is subject to an initial Add-Grace period (AGP). The purpose of the AGP is to provide an opportunity for a registrar to discontinue a registration made in error, such as by a malfunction of registrar software resulting in unintended registrations. As shown in steps 3-5, if a delete command is received during the AGP, the registrar is refunded the registration fee, and the registration proceeds to immediate deletion at step 39 (label D, Exhibit 27-2). During the AGP, the ICANN Add Grace Period Limits Policy (http:⁄⁄www.icann.org⁄en⁄tlds⁄agp-policy-17dec08-en.htm) shall be applied to deter “domain tasting”.

Significant provisions of the ICANN AGP include:

A. During any given month, the registry shall not offer any refund to a registrar for any domain names deleted during the AGP that exceed (i) 10% of that registrarʹs net new registrations in that month (calculated as the total number of net adds of one-year through ten-year registrations), or (ii) fifty (50) domain names, whichever is greater, unless an exemption has been granted for extraordinary circumstances.

B. A registrar may seek a specific one month retroactive exemption from application the AGP restrictions upon the documented showing of extraordinary circumstances. For any registrar requesting such an exemption, the registrar must confirm in writing to the registry how, at the time the names were deleted, these extraordinary circumstances were not known, reasonably could not have been known, and⁄or were outside the Registrarʹs control. Acceptance of any exemption will be at the sole and reasonable discretion of the registry in consultation with ICANN. ʺExtraordinary circumstancesʺ which reoccur regularly for the same Registrar will not be deemed extraordinary. Invocation of such circumstances for any two one-month periods in a single year will result in application of the second-tier penalties described in the response to Question 29, and successive tiered penalties for each month thereafter, leading to de-accreditation.

C. The registry shall report each instance of application of an exemption to ICANN, along with a brief descriptive identification of the type of extraordinary circumstance and the action, approval or denial that was taken by the registry.

If the registration is not deleted during the AGP, it proceeds to the registration term (step 6).

27.1.3. Registration Changes Affecting The Registration Lifecycle

Registrations during the contracted term will be subject to actions which do not affect the lifecycle, such as WHOIS updates and nameserver changes. Also, during the registration term Uniregistry may re-assign nameservers to prevent resolution of a domain name due to action taken under the Uniregistry Abuse Policy (see Question 29), or in response to a decision under the Uniform Rapid Suspension Policy (URS) requiring that the domain name resolve to a designated web page indicating that the domain name has been disabled. Uniregistry will also implement such changes as may be ordered by a court of competent jurisdiction or necessitated by registrar de-accreditation. Absent such unusual circumstances, any of the following actions prior to expiration of the registration term, will result in extension or shortening of the term:

Extension of Term (EPP command ʺrenewʺ), step 8: A registration can be extended prior to expiration of the registration term in one year increments up to a total of ten years maximum. The account of the sponsoring registrar at the time of the additional extension will be charged for the number of years the registration is extended. As indicated in steps 12-14, if a delete command is received within a period of five days, the registrar will be credited for the previously charged extension, and the registration will proceed to the Delete Cycle (label A, Exhibit 27-2).

Express Deletion (EPP command “delete”), step 9: An express deletion issued by the sponsoring registrar during the registration term will initiate the Delete Cycle (label A, Exhibit 27-2).

Registrar Transfer (EPP command “transfer”), step 10: If a gaining registrar issues a transfer command, the registry will re-assign the authoritative registrar for a domain name upon receipt of a valid transfer request and authorization code. Transfers shall be implemented in accordance with the current version of the ICANN Inter-Registrar Transfer Policy (http:⁄⁄www.icann.org⁄en⁄transfers⁄). If the losing registrar expressly authorizes the transfer, the transfer shall proceed immediately. Otherwise, the transfer will proceed within five days. When the registration is assigned to the gaining registrar, the expiration date of the domain is extended by at least one year, and limited by the maximum registration term of ten years, and the gaining registrar is charged accordingly. As indicated in steps 21-23, if an express deletion is issued by the gaining registrar within five days, the registrar is credited for the renewal fee mandated by the transfer, and the registration proceeds to the Delete Cycle (label A, Exhibit 27-2). Otherwise, the registration continues in accordance with the new registration term (step 6).

27.1.4. Expiration of Registration Term

Registrars will be required to implement the relevant provisions of the ICANN Expired Domain Deletion Policy (EDDP) (http:⁄⁄www.icann.org⁄en⁄registrars⁄eddp.htm) for names subject to deletion as a consequence of non-renewal, and to accept renewal payments for names subject to dispute in accordance with the provisions of the EDDP relating to domain dispute procedures.

At, step 7, upon the completion of the contracted registration term, the registration proceeds to an Auto-Renew Grace Period (ARGP) of forty five days in step 24. The sponsoring registrar is required to notify the registrant of impending expiration at least twice prior to expiration - once at least 30 days prior to expiration and once within 30 days of expiration. By default under the ARGP, expired domain names will be automatically renewed by the registry for a single year.

In steps 25 and 26, if a domain is deleted within the ARGP, the sponsoring registrar at the time of the deletion receives a credit of the renewal fee (step 14), and the registration proceeds to the Delete Cycle (label A, Exhibit 27-2). If no delete command is issued during the ARGP, then the renewal is confirmed, and the registration proceeds in accordance with the renewed term (step 6). A registration can also be expressly renewed and its term extended beyond a single year during the Auto-Renew Grace Period, subject to a limit of ten years total. The account of the sponsoring Registrar at the time of the additional extension will be charged for the additional number of years the registration is extended.

In step 27 of Exhibit 27-1, if a domain is transferred within the Auto-Renew Grace Period, the losing Registrar is credited with the Auto-Renew charge (step 28), the year added by the Auto-Renew operation is canceled, and the registration proceeds to the transfer process described above (label E, Exhibit 27-1). In the event of a bulk transfer with ICANN approval during the Auto-Renew Grace Period (such as may occur upon de-accreditation of the sponsoring registrar), the expiration dates of transferred registrations are not affected and the losing registrarʹs account is charged for the Auto-Renew.

27.1.5. Delete Cycle and Redemption Grace Period

A Redemption Grace Period (RGP) is applied at the initial step 30 of the Delete Cycle. The RGP is a period of six months, during which the subject registration is placed on REGISTRY-HOLD, and nameserver records for the registration are removed from the zone file, such that the domain name will not resolve. This six month period is significantly longer than the present industry standard, which has been subject to community criticism for not providing sufficient time for registrants with extenuating circumstances. Rendering the registration non-functional in this manner is effectively the final notice to the registrant that the name is subject to deletion at the end of the RGP, even if inaccurate contact data or other technical issue resulted in failure of the registrant to receive renewal reminders or expiration notices.

During the RGP, as indicated in steps 31-35, the registration may only be restored to the original registrant, subject to issuance of a “restore” command (step 32), followed by receipt of a redemption report from the sponsoring registrar (step 35) within a Restore Lock Period of five calendar days (step 34). During the RLP, the nameservers are restored, and the domain status is:

PENDING RESTORE + UPDATE PROHIBITED + DELETE PROHIBITED + RENEW PROHIBITED + TRANSFER PROHIBITED

If a Restore Report is not received from the registrar within the RLP, the nameservers are removed, and the domain is returned to step 30 until expiration of the RGP with status of:

PENDING DELETE RESTORABLE + HOLD

In order to restore the registration, a redemption report submitted in step 35 must indicate that the registrar has (a) verified identity of the party seeking redemption of the registration, (b) paid a renewal fee, and (c) paid an RGP service fee for reviewing the redemption report circumstances of requested redemptions. If so, the registration returns to step 6 of Exhibit 27-1 for the renewed term of registration.

Extension of the RGP to six months, as proposed herein, addresses a frequently-criticized aspect of current registration practices, under which a successive registrant of a previously registered domain name may utilize it to engage in identity fraud or reputational damage to the previous registrant. The six month period proposed here, reduces the efficacy of this abusive practice.

27.1.6. Deletion

If the registration is not redeemed during the RGP, it proceeds to Pending Delete status in step 36. Here, the lifecycle varies significantly from the standard gTLD registration lifecycle. Instead of a deterministic interval between the end of RGP and the start of deletion, a random, non-published time interval of 1 to 30 days is set for final deletion of the registration. When the random deletion period has elapsed (step 38), the registration proceeds to final deletion from the registry (step 39).

Registrars found to be engaging in unreasonably repetitive registration attempts of registrations during the Quiet Period (such as attributable to automated processes being conducted by or through the registrar, and not as a consequence of manual availability queries by end users) will be suspended from registry access until the cause of such repetitive attempts are eliminated. Repeated suspensions for this reason shall lead to the graded penalties described in the response to Question 28 of loss of incentives, financial penalties, and ultimate de-accreditation.
27.2. RESOURCING PLANS

Costs and procurement of the resources described here are detailed in response to Question 47.

27.2.1. Human Resources

See EXHIBIT: ʺ27-Chart-Resourcing.pngʺ.

27.3. ABOUT THIS RESPONSE

We believe that this answer meets the requirements and addresses all the points of this question:

* We have provided a complete and detailed statement of the registration lifecycle to be used for .DEAL.
* This lifecycle is substantially the same as the well-understood life cycle in the existing generic top-level domains.
* We have modified the lifecycle to redress problems, such as identity theft, that can occur when names are deleted.
* This lifecycle is coupled to and consistent with our abuse mitigation policies.
* We have adequate technical, operational, legal, and financial resources to handle this lifecycle.