28 Abuse Prevention and Mitigation
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1. COMPREHENSIVE ABUSE POLICIES, WHICH INCLUDE CLEAR DEFINITIONS OF WHAT CONSTITUTES ABUSE IN THE TLD, AND PROCEDURES THAT WILL EFFECTIVELY MINIMIZE POTENTIAL FOR ABUSE IN THE TLD
The .HOME gTLD will have a comprehensive abuse policy, which includes a clear definition of what constitutes abuse in .HOME, and procedures in place to effectively minimize potential for abuse in .HOME. It is a core goal of .HOME to provide a namespace that minimizes harm to Internet users (such as identity theft, harm to children and a general erosion of trust), while not negatively impacting Internet stability or security. Dot Home LLC (DH) takes abuse prevention and mitigation seriously, and the following core elements of the plan (what constitutes abuse, what we will do if we find abuse, how we can be made aware of abuse, and the processes and procedures we will invoke) shows DH’s commitment to abuse prevention and mitigation in .HOME.
1.1 .HOME Abuse Prevention and Mitigation Implementation Plan
DH takes abuse prevention and mitigation seriously. The attached .HOME Abuse Prevention and Mitigation plan (the “Plan”) will be published on .HOME’s registry website and details many of .HOME’s policies and procedures regarding abuse prevention and mitigation. The goal of the Plan is to address significant potential harm to Internet users, including identity theft, harm to children and erosion of trust by Internet users, and to address those who abuse the DNS and otherwise engage in illegal or fraudulent activity via the .HOME gTLD.
The Plan includes a single abuse point of contact responsible for addressing matters requiring expedited attention and providing a timely response to abuse complaints concerning all .HOME names registered through all registrars of record, including those involving a reseller. The Plan identifies an Abuse Prevention Manager who will be tasked with being the primary point of contact for receiving all abuse complaints.
The Plan also includes a clear definition of what constitutes “abuse.” Particularly, “abuse” or “abusive use” of a .HOME domain name is the wrongful or excessive use of power, position or ability with regard to a .HOME domain, and includes, without limitation, the following:
* Illegal or fraudulent actions;
* Spam: The use of electronic messaging systems to send unsolicited bulk messages. The term applies to e-mail spam and similar abuses such as instant messaging spam, mobile messaging spam, and the spamming of Web sites and Internet forums. An example, for purposes of illustration, would be the use of email in denial-of-service attacks;
* Phishing: The use of counterfeit Web pages that are designed to trick recipients into divulging sensitive data such as usernames, passwords, or financial data;
* Pharming: The redirecting of unknowing users to fraudulent sites or services, typically through DNS hijacking or poisoning;
* Willful distribution of malware: The dissemination of software designed to infiltrate or damage a computer system without the ownerʹs informed consent.
Examples include, without limitation, computer viruses, worms, keyloggers, and trojan horses;
* Botnet command and control: Services run on a domain name that are used to control a collection of compromised computers or ʺzombies,ʺ or to direct denial-of-service attacks (DDoS attacks);
* Distribution of child pornography; and
* Illegal Access to Other Computers or Networks: Illegally accessing computers, accounts, or networks belonging to another party, or attempting to penetrate security measures of another individualʹs system (often known as ʺhackingʺ). Also, any activity that might be used as a precursor to an attempted system penetration (e.g., port scan, stealth scan, or other information gathering activity).
“Abuse” or “abusive use” of a .HOME domain name also includes violation or breach of any policies or rules regarding registration and⁄or use of the .HOME gTLD as set forth by the National Association of Realtors® (NAR). This allows NAR, as steward of the .HOME gTLD, to adopt, address, evolve and enforce current and additional policies in place to prevent or mitigate any abusive use of the .HOME gTLD.
The Plan also includes reservation of the right on DH’s part to deny, cancel or transfer any registration or transaction, or place any domain name(s) on registry lock, hold or similar status, that DH deems necessary: (1) to protect the integrity and stability of .HOME; (2) to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on DH’s and NAR’s part, as well as affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement or (5) to correct mistakes made by DH, NAR or any registrar in connection with a domain name registration. DH also reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a complaint.
DH acknowledges that it is not capable of making final determinations of matters which are appropriately determined in other fora, such as determination of guilt on a criminal matter, determination of child pornography, or determination of other illegality. As such, with regard to any abuse claim made under color or rule of law, statute or code of any jurisdiction, DH will most likely defer final determination on any such claim to an appropriate tribunal in an appropriate jurisdiction. However, as set forth above, DH also reserves the right to lock, suspend, place on hold (or similar status) any domain which is the subject of an abuse claim while the substance of the claim is pending adjudication or otherwise final determination by the appropriate tribunal in the appropriate jurisdiction.
The Plan also includes procedures that will effectively minimize potential for abuse in the .HOME gTLD, as set forth more completely in Section 1.2 below.
The Plan is aimed at illegal and abusive use of domains, and is not intended as a substitute, replacement, circumvention or alternative venue for complaints, matters and issues more appropriately addressed by trademark rights protection mechanisms set forth in response to Question 29, such as, for example, the UDRP, URS, Sunrise Period and the Trademark Clearinghouse, or the PDDRP as set forth in Question 29.
1.2 Policies for Handling Complaints Regarding Abuse
Abuse complaints may be submitted to the Abuse Prevention Manager by email (likely to be “abuse” (at) RegistryOperatorWebsite.HOME or similar) or by written mail to: Attention: Abuse Prevention Manager ⁄ 3029 Prospect Avenue ⁄ Cleveland ⁄ OH ⁄ 44115 ⁄ United States, or other address as identified on .HOME’s registry website. This will allow the complaint to be formally recognized and processed.
A complaint should include: the .HOME domain name at issue; the nature of the alleged abuse; the date(s) the abuse allegedly occurred; any materials the claimant may have illustrating the abuse (for example, spam email, screen shots, etc.); any authority the complainant may have with regard to the claim (for example, if the complainant is with law enforcement); and the claimant’s contact information, including a preferred method of contact (such as email).
Complaints must be submitted in English. In the event a complainant is not capable of submitting a complaint in English, or is otherwise incapable of communicating in English, DH will take commercially reasonable efforts to accommodate the complainant and determine an effective means of communication, but makes no guarantee that any complaint will be processed in any language outside of English.
Commercially reasonable attempts will be made to respond to the complainant via the method of communication identified in the complaint (e.g., by email or written mail; by phone if requested and reasonable). If the complaint contains no contact information, or incomplete contact information that does not allow a response, the complaint will be dismissed.
Once received, a complaint will be assigned a unique identifier, which will be maintained during the life cycle of the complaint and communicated to the complainant upon DH’s first response to the complainant.
Every complaint will be initially screened to determine if it is to be substantively processed or otherwise identified as incomplete, frivolous, incomprehensible, stating a claim for which no relief can be granted, non-topical or otherwise not subject to substantive processing. DH will endeavor to make this threshold determination within ten business days of receiving a complaint, or three business days if the complainant is a member of law enforcement.
If the complaint is deemed to be incomplete or incomprehensible, DH will respond to the complainant asking for a complete and comprehensible complaint, and will cease processing the complaint until a complete and comprehensible complaint is received. If the complaint is deemed frivolous, DH will reply that the complaint is frivolous and invite the complainant to justify why the complaint is not frivolous; if the complainant cannot overcome this burden, the complaint will be dismissed. If the complaint is non-topical or makes claim for which no relief can be granted under .HOME’s Abuse Prevention and Mitigation Plan, DH will respond accordingly and invite the claimant to respond or direct the claimant to a more appropriate forum or mechanism for addressing the claimant’s complaint, such as the UDRP, other rights protection mechanisms as set forth in the answer to Question 29, civil litigation in an appropriate forum, or referral to law enforcement. In either event, DH will cease processing such a complaint until a response is received from the complainant. If a review of the complaint determines that the complaint cannot be substantively processed for any other reason, DH will respond to the complainant accordingly and processing of the complaint will cease until a response is received from complainant.
In the event DH’s initial screening determines that the complaint is complete, non-frivolous, comprehensible, states a claim for which relief can be granted, topical and otherwise capable of substantive processing by DH, DH will substantively process the complaint. DH will establish and follow a variety of methods for tracking claimed abuse and for addressing the nature of the alleged abuse. These methods may include, but not be limited to, coordination with NAR, law enforcement, engaging security vendors, internal investigations, engaging our back-end provider (Verisign) and employing Verisign’s resources regarding abuse detection⁄prevention, engaging the registrar of record, and any other industry-standard mechanisms for addressing domain abuse. Complaint processing, analysis and resource allocation will be on a case-by-case basis as needed for each complaint.
In the event DH initiates substantive processing of a complaint, DH will inform NAR, the registrant of record, the registrar of record and the complainant of such initiation, and will submit requests for information, comment or feedback as required on a case-by-case basis for each complaint. The registrant of record will be contacted via the WHOIS information associated with the registration. DH will work with NAR and the registrar of record to determine the nature of the alleged abuse, and the necessary and appropriate steps to address same. DH will contact the registrar of record by phone, email or other method as identified in the agreement between DH and the registrar.
At any time during processing of a complaint, NAR may contact DH and direct DH to take any of the actions set forth herein (such as, for example, suspending the domain pending further investigation). NAR is committed to working with DH in the fair and reasonable implementation of the Plan as set forth herein, and in the fair and reasonable processing of each complaint.
DH acknowledges that the registrar of record may initiate its own abuse investigation, at which point DH will process the complaint in parallel with the registrar. Again, DH will work with the registrar of record with regard to contacting the registrant (if the registrar wishes to be the point of contact with the registrant) and processing the complaint.
During DH’s processing of a complaint, DH may elect to suspend, lock, or otherwise place the domain at issue on hold pending resolution of the complaint. The registrant of record will be sent notice via contact information in the WHOIS that the domain will be suspended, locked or otherwise placed on hold pending resolution of the complaint. If the registrant of record chooses to respond, DH will consider their response and may release the suspension, lock or hold if appropriate. DH is committed to a fair and impartial process for addressing abuse complaints, and will endeavor to ensure that mistakes in processing or suspending⁄locking⁄holding do not occur, but DH recognizes that rarely false-positive suspension may occur. In this event, DH notes that the domain at issue will not be deleted (until potentially completion of complaint processing), which will allow for quick correction of the suspension⁄lock⁄hold in the rare case of a false-positive. In any event, DH will comply with any appropriate court or tribunal order directed to DH to release a suspended⁄locked⁄on-hold domain if complainant provides such to DH.
After processing of a complaint, DH may approve or deny the claim, make comments on the claim, conditionally approve the claim, suspend the claim pending further action, and may take any action set forth herein (such as, for example, cancelling or transferring the domain at issue). In matters in which the ultimate determination as to whether the substance of a claim is illegal or otherwise more appropriately determined by a court or tribunal in other fora, DH may delay final processing of a claim, pending resolution and⁄or direction in the matter from such court or tribunal. In matters in which the ultimate determination as to whether an abuse has occurred is more appropriately determined by NAR in its position as steward of the .HOME gTLD, DH may delay final processing of a claim pending NAR’s determination of appropriate action.
DH will notify the claimant, NAR, the registrant of record and the registrar of record of DH’s final determination regarding the complaint and any actions DH may take⁄have taken in regard to the matter. The registrant (or entity claimed to have abusively acted) or the claimant may, within ten business days of DH sending out such notice, inform DH that such entity wishes DH to reconsider its decision. Such reconsideration request should be submitted to the Abuse Prevention Manager in the same manner as the complaint was submitted, or otherwise as provided in the notice of DH’s decision. Any reconsideration request must address why reconsideration should be considered, and should identify any new information which was not considered by DH in DH’s final decision, and which would be considered material enough to justify a reversal of DH’s determination. If the reconsideration request contains such material new information, DH may decide to reopen processing of the complaint, and would then notify NAR, the complainant, the registrant, the registrar and any other interested parties of such reopening. If the reconsideration request fails to contain any material new information, or if DH that the material new information provided is not sufficient for DH to change its position, DH will deny the reconsideration request. At that point DH will cease processing the claim, but will still respond to appropriate court or tribunal orders directed to DH regarding the matter.
In the event a complainant identifies themselves as a member of law enforcement investigating a potential illegal activity, DH will endeavor to initially respond to such a complaint within twenty-four hours, but in no event less than seventy-two hours, and may respond sooner if the complaint requests a quicker turnaround and provides an adequate reason for needing a quicker turnaround. DH is committed to working with law enforcement relating to abusive actions in the .HOME gTLD, and will put forth commercially reasonable efforts to communicate with law enforcement, accommodate law enforcement requests and generally work with law enforcement towards expedited processing of a complaint.
DH is a Delaware limited liability company with a principal place of business at 3029 Prospect Avenue, Cleveland Ohio 44115, and is subject to Ohio and Delaware law. In the event DH receives a court or tribunal order for any reason, DH will review the order to determine its reasonableness and the extent to which the issuing court or tribunal has authority over DH, NAR or any party implicated in a complaint. DH may consult with outside legal counsel in such a review. If DH elects to respond or take action pursuant to the order, DH will endeavor to do so within any time frame set forth in the order, so long as practicable.
For complaints arising from matters relating to abuse or misuse of NAR’s policies governing use of the .HOME gTLD (“NAR Policies”), DH will work with NAR to determine the processing of such a complaint. In complaints relating to NAR Policies, NAR may choose to invoke any of its own policies or procedures which will be developed and adapted to address abuses or violations of NAR Policies. DH will work with NAR, at NAR’s direction, to assist in processing any claim. DH will also comply with any direction to action given by NAR related to suspension, lock, hold, transfer or cancellation of any domain in a complaint primarily regarding NAR Policies. As previously stated, NAR is committed to the fair and impartial implementation of the Plan.
DH is committed to preventing and mitigating abuse in the .HOME gTLD, and will comply with all terms regarding such in the final version of the Registry Agreement and all consensus policies relating to such. Working with NAR and registrars, DH will remain flexible on the Plan and its implementation policies⁄procedures to address future and unconventional abuses which are not currently known, and looks forward to working with other gTLD registry operators and ICANN in determining industry standard abuse prevention and mitigation plans, policies and procedures.
1.3 Proposed Measures for Removal of Orphan Glue Records
Although orphan glue records often support correct and ordinary operation of the Domain Name System (DNS), registry operators will be required to remove orphan glue records (as defined at http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf) when provided with evidence in written form that such records are present in connection with malicious conduct. DH’s selected backend registry services provider’s (Verisign’s) registration system is specifically designed to not allow orphan glue records. Registrars are required to delete⁄move all dependent DNS records before they are allowed to delete the parent domain.
To prevent orphan glue records, Verisign performs the following checks before removing a domain or name server:
Checks during domain delete:
* Parent domain delete is not allowed if any other domain in the zone refers to the child name server.
* If the parent domain is the only domain using the child name server, then both the domain and the glue record are removed from the zone.
Check during explicit name server delete:
* Verisign confirms that the current name server is not referenced by any domain name (in-zone) before deleting the name server.
* If the parent domain references the child name server AND if other domains in the zone also reference it AND if the parent domain name is assigned a serverHold status, then the parent domain goes out of the zone but the name server glue record does not.
* If no domains reference a name server, then the zone file removes the glue record.
1.4 Resourcing Plans
Details related to resourcing plans for the initial implementation and ongoing maintenance of DH’s abuse plan are provided in Section 2 of this response.
1.5 Measures to Promote Whois Accuracy
1.5.1 Authentication of Registrant Information
As set forth in the answer to Question 18, only NAR, REALTORS®, NAR members, NAR affiliates (including societies and counsels), NAR licensees and parties otherwise in a contractual relationship with NAR will be permitted registration in .HOME. Each of these individuals or entities may be identified by a unique identifier, as is the case with all REALTORS®. This unique identifier is created and supplied by NAR, maintained in NAR databases, and updated accordingly (such as, for example, when a REALTOR®’s membership ceases, the identifier is updated accordingly).
During the domain application process, the applicant will input their unique identifier (supplied by NAR), and the inputted identifier will be checked against NAR’s database to ensure that the applicant is in good status. In this regard the registrant information of all applications are pre-authenticated by NAR, as NAR will only issue an identifier, and maintain that identifier’s status, if the individual⁄entity to which the identifier is assigned is in good standing with NAR (such as, for example, retains their position as a REALTOR®).
NAR will work with accredited registrars to ensure that required back-end functionality for pinging NAR’s database to check identifiers is readily available.
1.5.2 Regular Monitoring of Registration Data for Accuracy and Completeness
NAR regularly monitors its member database to ensure that accurate membership status is maintained. For example, a real estate professional may become a REALTOR® if the professional otherwise qualifies under NAR’s standards and maintains payment of dues. In the event the REALTOR® fails to maintain payment of their dues, the database reflects that the individual is no longer a REALTOR® in good standing.
In this regard the NAR database maintains an accurate database of registration information relating to REALTOR® and NAR members which is updated in real time with membership status and contact information supplied by REALTORS® and members. NAR will inform DH in the event that a REALTOR® or a member ceases to be a REALTOR® or a member, and DH will modify any implicated domains accordingly.
DH recognizes that monitoring of registration data for accuracy and completeness is an important matter to ICANN and many ICANN stakeholders. DH will comply with all monitoring provisions in the final version of the Registry Agreement and all consensus policies relating to monitoring. DH will work with all accredited registrars towards this goal. DH will also work with NAR to establish procedures for cross-checking WHOIS data with NAR’s REALTOR® and membership databases.
Verisign, DH’s selected backend registry services provider, has established policies and procedures to encourage registrar compliance with ICANN’s Whois accuracy requirements. Verisign provides the following services to DH for incorporation into its full-service registry operations.
Registrar self certification.
The self-certification program consists, in part, of evaluations applied equally to all operational ICANN accredited registrars and conducted from time-to-time throughout the year. Process steps are as follows:
* Verisign sends an email notification to the ICANN primary registrar contact, requesting that the contact go to a designated URL, log in with his⁄her Web ID and password, and complete and submit the online form. The contact must submit the form within 15 business days of receipt of the notification.
* When the form is submitted, Verisign sends the registrar an automated email confirming that the form was successfully submitted.
* Verisign reviews the submitted form to ensure the certifications are compliant.
* Verisign sends the registrar an email notification if the registrar is found to be compliant in all areas.
* If a review of the response indicates that the registrar is out of compliance or if Verisign has follow-up questions, the registrar has 10 days to respond to the inquiry.
* If the registrar does not respond within 15 business days of receiving the original notification, or if it does not respond to the request for additional information, Verisign sends the registrar a Breach Notice and gives the registrar 30 days to cure the breach.
* If the registrar does not cure the breach, Verisign terminates the Registry-Registrar Agreement (RRA).
Whois data reminder process. Verisign regularly reminds registrars of their obligation to comply with ICANN’s Whois Data Reminder Policy, which was adopted by ICANN as a consensus policy on 27 March 2003 (http:⁄⁄www.icann.org⁄en⁄registrars⁄wdrp.htm). Verisign sends a notice to all registrars once a year reminding them of their obligation to be diligent in validating the Whois information provided during the registration process, to investigate claims of fraudulent Whois information, and to cancel domain name registrations for which Whois information is determined to be invalid.
1.5.3 Use of Registrars
As of the submission date of this application, ICANN has not provided final guidance as to the nature and the details of the procedures which will be implemented by registrars to ensure accuracy and completeness of WHOIS data. DH has followed and will continue to follow closely the progress of the negotiations between ICANN and the Registrar Negotiations Team (NT) regarding the revised Registrar Accreditation Agreement (RAA). DH acknowledges the interests of law enforcement agencies (LEA), who generally are seeking greater openness, accuracy and accountability in WHOIS data. DH also acknowledges the countervailing position of those who wish to maintain WHOIS privacy, and those (such as registrars) who wish to keep WHOIS costs down.
In the 1 March 2012 Progress Report on Negotiations on the Registrar Accreditation Agreement, ICANN notes that ICANN and the NT are currently undertaking a “comprehensive review” of the RAA and addressing twelve enumerated requests from LEA relating to WHOIS accuracy, accountability and completeness. ICANN and the NT appear to have an agreement in principle on eleven of the twelve principals, agreeing in principle on (1) guidelines for Privacy⁄Proxy Accreditation Services; (2) a gross negligence standard for knowledge in permitting criminal activity regarding WHOIS information; (3) registrar contact information; (4) public display of registrar officer information; (5) registrar ownership; (6) notice of change to registrar; (7) registrar certification; (8) registrar accountability and disclosure obligations; (10) validation of WHOIS data; (11) abuse point of contact; and (12) SLA for port 43 servers – while not having an agreement in principle on (9) registrar collection and maintenance of data on the persons initiating requests for registrations, as well as source IP addresses and financial transaction information. ICANN and the NT are also addressing approximately twenty-two other issues relating to the RAA, of which approximately half have an agreement in principle.
DH is committed to support WHOIS accuracy and completeness procedures and policies which support the WHOIS policies and procedures which result from eventual agreement between ICANN and the NT regarding matters of WHOIS accuracy, accountability and openness as set forth in the final version of the RAA.
1.6 Controls to Ensure Proper Access to Domain Functions
To ensure proper access to domain functions, DH incorporates Verisign’s Registry-Registrar Two-Factor Authentication Service into its full-service registry operations. The service is designed to improve domain name security and assist registrars in protecting the accounts they manage by providing another level of assurance that only authorized personnel can communicate with the registry. As part of the service, dynamic one-time passwords (OTPs) augment the user names and passwords currently used to process update, transfer, and⁄or deletion requests. These one-time passwords enable transaction processing to be based on requests that are validated both by “what users know” (i.e., their user name and password) and “what users have” (i.e., a two-factor authentication credential with a one-time-password).
Registrars can use the one-time-password when communicating directly with Verisign’s Customer Service department as well as when using the registrar portal to make manual updates, transfers, and⁄or deletion transactions. The Two-Factor Authentication Service is an optional service offered to registrars that execute the Registry-Registrar Two-Factor Authentication Service Agreement. As shown in Figure 28-1, the registrars’ authorized contacts use the OTP to enable strong authentication when they contact the registry. There is no charge for the Registry-Registrar Two-Factor Authentication Service. It is enabled only for registrars that wish to take advantage of the added security provided by the service.
Figure 28-1: See DotHome LLC_Q28_Figures
2. TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION
DH’s management team is an experienced team which has managed a gTLD (.JOBS) for over six years and is well-acquainted with domain abuse prevention and mitigation.
During initial operation of .HOME, the Abuse Prevention Manager will be the General Counsel of DH. In processing a complaint, the Abuse Prevention Manager may seek the assistance of any of the Executive Management Personnel, including the Vice President of Registry Operations for .HOME policy-related issues. The Abuse Prevention Manager may also seek the assistance of either or both Customer Support personnel and Technical Labor personnel, depending upon the nature of the complaint and the volume of complaints. The Abuse Prevention Manager may also engage the services of outside legal counsel for advice or representation if the nature of a complaint or processing the complaint requires.
Operations of the Abuse Prevention Manager will scale as needed to accommodate the volume and nature of complaints received, including shifting allocations of time from Customer Support personnel and Technical Labor personnel. In the event registration volume and related income allow, and complaint volume dictates, additional personnel may be added to accommodate the complaints, up to and including addition of a dedicated Abuse Prevention Manager with a staff commensurate to need.
Costs for DH’s operations as detailed above are addressed in the response to Question 47. Specifically, $20,000 has been attributed to legal as part of general administrative expenses per year (see table 3 provided in response to Question 47). In addition, per the Financial Projections Template submitted in response to Question 46, $50,000 per year is budgeted under Other Operating Costs in case of unexpected contingencies, such as outside legal counsel.
The National Association of Realtors is the largest trade association in North America. NAR has an experienced management team, compliance team and legal team for overseeing use of their REALTOR mark. With regard to abuse complaints that relate to NAR Policies, NAR will deploy their brand management resources to establish, implement and maintain internal procedures for addressing such claims. Such procedures may involve input from management, compliance and legal, and legal may consult with outside legal counsel. NAR has sufficient resources and personnel to provide the compliance services attributed to NAR herein.
NAR’s internal costs for abuse complaint procedures will be borne by NAR, and are thus not included in the response to Question 47.
Resource Planning Specific to Backend Registry Activities
Verisign, DH’s selected backend registry services provider, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to DH fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.
Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force. (Current statistics are publicly available in Verisign’s quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100 percent of the time for more than 13 years for .com, proving Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s TLD service offerings.
Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support abuse prevention and mitigation:
* Application Engineers: 19
* Business Continuity Personnel: 3
* Customer Affairs Organization: 9
* Customer Support Personnel: 36
* Information Security Engineers: 11
* Network Administrators: 11
* Network Architects: 4
* Network Operations Center (NOC) Engineers: 33
* Project Managers: 25
* Quality Assurance Engineers: 11
* Systems Architects: 9
To implement and manage the .HOME gTLD as described in this application, Verisign, DH’s selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area.
When usage projections indicate a need for additional staff, Verisign’s internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed gTLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internet’s largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.
3. POLICIES AND PROCEDURES IDENTIFY AND ADDRESS THE ABUSIVE USE OF REGISTERED NAMES AT STARTUP AND ON AN ONGOING BASIS
The anti-abuse policies and procedures set forth in the answers to this Question 28 address, and are applicable, to abusive use of registered names in .HOME at both startup and on an ongoing basis.
3.1 Start-Up Anti-Abuse Policies and Procedures
DH’s anti-abuse policies and procedures set forth above will be available as of start-up of .HOME. Further, the requirement set forth in section 1.5 above regarding submission of a unique identifier for applicants for domains will be in place for start-up.
Verisign, DH’s selected backend registry services provider, provides the following domain name abuse prevention services, which DH incorporates into its full-service registry operations. These services are available at the time of domain name registration.
Registry Lock. The Registry Lock Service allows registrars to offer server-level protection for their registrants’ domain names. A registry lock can be applied during the initial standup of the domain name or at any time that the registry is operational.
Specific Extensible Provisioning Protocol (EPP) status codes are set on the domain name to prevent malicious or inadvertent modifications, deletions, and transfers. Typically, these ‘server’ level status codes can only be updated by the registry. The registrar only has ‘client’ level codes and cannot alter ‘server’ level status codes. The registrant must provide a pass phrase to the registry before any updates are made to the domain name. However, with Registry Lock, provided via Verisign, DH’s subcontractor, registrars can also take advantage of server status codes.
The following EPP server status codes are applicable for domain names: (i) serverUpdateProhibited, (ii) serverDeleteProhibited, and (iii) serverTransferProhibited. These statuses may be applied individually or in combination.
The EPP also enables setting host (i.e., name server) status codes to prevent deleting or renaming a host or modifying its IP addresses. Setting host status codes at the registry reduces the risk of inadvertent disruption of DNS resolution for domain names.
The Registry Lock Service is used in conjunction with a registrar’s proprietary security measures to bring a greater level of security to registrants’ domain names and help mitigate potential for unintended deletions, transfers, and⁄or updates.
Two components comprise the Registry Lock Service:
* DH and⁄or its registrars provides Verisign, DH’s selected provider of backend registry services, with a list of the domain names to be placed on the server status codes. During the term of the service agreement, the registrar can add domain names to be placed on the server status codes and⁄or remove domain names currently placed on the server status codes. Verisign then manually authenticates that the registrar submitting the list of domain names is the registrar-of-record for such domain names.
* If DH and⁄or its registrars requires changes (including updates, deletes, and transfers) to a domain name placed on a server status code, Verisign follows a secure, authenticated process to perform the change. This process includes a request from a DH-authorized representative for Verisign to remove the specific registry status code, validation of the authorized individual by Verisign, removal of the specified server status code, registrar completion of the desired change, and a request from the DH-authorized individual to reinstate the server status code on the domain name. This process is designed to complement automated transaction processing through the Shared Registration System (SRS) by using independent authentication by trusted registry experts.
DH intends to charge registrars based on the market value of the Registry Lock Service. A tiered pricing model is expected, with each tier having an annual fee based on per domain name⁄host and the number of domain names and hosts to be placed on Registry Lock server status code(s).
3.2 Ongoing Anti-Abuse Policies and Procedures
DH’s anti-abuse policies and procedures set forth in the answers to this Question 28 will be available on an on-going basis for .HOME. Further, the requirement set forth in section 1.5 above regarding submission of a unique identifier also will apply on an ongoing basis.
3.2.1 Policies and Procedures That Identify Malicious or Abusive Behavior
Verisign, DH’s selected backend registry services provider, provides the following service to DH for incorporation into its full-service registry operations.
Malware scanning service. Registrants are often unknowing victims of malware exploits. Verisign has developed proprietary code to help identify malware in the zones it manages, which in turn helps registrars by identifying malicious code hidden in their domain names.
Verisign’s malware scanning service helps prevent websites from infecting other websites by scanning web pages for embedded malicious content that will infect visitors’ websites. Verisign’s malware scanning technology uses a combination of in-depth malware behavioral analysis, anti-virus results, detailed malware patterns, and network analysis to discover known exploits for the particular scanned zone. If malware is detected, the service sends the registrar a report that contains the number of malicious domains found and details about malicious content within its TLD zones. Reports with remediation instructions are provided to help registrars and registrants eliminate the identified malware from the registrant’s website.
3.2.2 Policies and Procedures That Address the Abusive Use of Registered Names
Suspension processes conducted by backend registry services provider. In the case of domain name abuse, DH will determine whether to take down the subject domain name as set forth in Section 1 of the answer to this Question 28. Verisign, DH’s selected backend registry services provider, will follow the following auditable processes to comply with the suspension request.
Figure 28-2: See DotHome LLC_Q28_Figures
Verisign Suspension Notification. DH submits the suspension request to Verisign for processing, documented by:
* Threat domain name
* Registry incident number
* Incident narrative, threat analytics, screen shots to depict abuse, and⁄or other evidence
* Threat classification
* Threat urgency description
* Recommended timeframe for suspension⁄takedown
* Technical details (e.g., Whois records, IP addresses, hash values, anti-virus detection results⁄nomenclature, name servers, domain name statuses that are relevant to the suspension)
* Incident response, including surge capacity
Verisign Notification Verification. When Verisign receives a suspension request from DH, it performs the following verification procedures:
* Validate that all the required data appears in the notification.
* Validate that the request for suspension is for a registered domain name.
* Return a case number for tracking purposes.
Suspension Rejection. If required data is missing from the suspension request, or the domain name is not registered, the request will be rejected and returned to DH with the following information:
* Threat domain name
* Registry incident number
* Verisign case number
* Error reason
Registrar Notification. Once Verisign has performed the domain name suspension, and upon DH request, Verisign notifies the registrar of the suspension. If DH does not request that Verisign notify the registrar, DH will notify the registrar. Registrar notification includes the following information:
* Threat domain name
* Registry incident number
* Verisign case number
* Classification of type of domain name abuse
* Evidence of abuse
* Anti-abuse contact name and number
* Suspension status
* Date⁄time of domain name suspension
Registrant Notification. Once Verisign has performed the domain name suspension, and upon DH request, Verisign notifies the registrant of the suspension. If DH does not request that Verisign notify the registrant, DH will notify the registrant. Registrant notification includes the following information:
* Threat domain name
* Registry incident number
* Verisign case number
* Classification of type of domain name abuse
* Evidence of abuse
* Registrar anti-abuse contact name and number
Domain Suspension. Verisign places the domain to be suspended on the following statuses:
Suspension Acknowledgement. Verisign notifies DH that the suspension has been completed. Acknowledgement of the suspension includes the following information:
* Threat domain name
* Registry incident number
* Verisign case number
* Case number
* Domain name
* DH abuse contact name and number, or registrar abuse contact name and number
* Suspension status
4. WHEN EXECUTED IN ACCORDANCE WITH THE REGISTRY AGREEMENT, PLANS WILL RESULT IN COMPLIANCE WITH CONTRACTUAL REQUIREMENTS
It is DH’s good faith belief that the plans and procedures set forth herein, when executed, will place .HOME in compliance with the contractual requirements set forth in the Registry Agreement. As a final version of the Registry Agreement has not been provided, DH is committed to being in compliance with all abuse-prevention terms and obligations set forth in the final version of the Registry Agreement, and will amend and augment any and all anti-abuse plans and procedures set forth herein to be in compliance with the terms and obligations regarding anti-abuse plans and procedures set forth in the final version of the Registry Agreement and any Consensus Policies relating to abuse prevention and mitigation.
5. TECHNICAL PLAN SCOPE⁄SCALE THAT IS CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY
DH’s anti-abuse plans and procedures set forth herein are consistent with the technical, operational and financial approach and details set forth in other parts of this application, and other answers to the Questions therein. As detailed in answers to Question 47, DH has allocated more than adequate levels of resources on hand and committed to enable full functionality of the plan and procedures, and DH’s experienced management team and new hires, along with the resources of NAR and Verisign, are more than capable of successfully carrying out the functions set forth herein.
Scope⁄Scale Consistency Specific to Backend Registry Activities
Verisign, DH’s selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies.
Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the .HOME gTLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to DH fully accounts for cost related to this infrastructure, which is provided as “Other Operating Cost” (Template 1, Line I.L) within the Question 46 financial projections response.
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