29 Rights Protection Mechanisms
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Q28 Abuse Prevention and Mitigation
Abbott Laboratories (“Abbott”), working with Afilias, will take the requisite operational and technical steps to promote WHOIS data accuracy, limit domain abuse, remove outdated and inaccurate data, and other security measures to ensure the integrity of the .ABBVIE gTLD. The specific measures include, but are not limited to:
- Posting a gTLD Anti-Abuse Policy that clearly defines abuse, and provides point-of-contact information for reporting suspected abuse;
- Committing to rapid identification and resolution of abuse, including suspensions;
- Ensuring completeness of WHOIS information at the time of registration;
- Publishing and maintaining procedures for removing orphan glue records for names removed from the zone; and
- Establishing measures to deter WHOIS abuse, including rate-limiting, determining data syntax validity, and implementing and enforcing requirements from the Registry-Registrar Agreement.
The Anti-Abuse Policy stated below will be enacted under the contractual authority of Abbott through the Registry-Registrar Agreement, and the obligations will be passed on to and made binding upon registrants. This policy will be posted on the .ABBVIE gTLD website along with contact information for registrants or users to report suspected abuse.
The policy is designed to address the malicious use of domain names. Abbott and its registrars will make reasonable attempts to limit significant harm to Internet users. This policy is not intended to take the place of the Uniform Domain Name Dispute Resolution Policy (UDRP) or the Uniform Rapid Suspension System (URS), and it is not to be used as an alternate form of dispute resolution or as a brand protection mechanism. Its intent is not to burden law-abiding or innocent registrants and domain users; rather, the intent is to deter those who use domain names maliciously by engaging in illegal or fraudulent activity.
Repeat violations of the abuse policy will result in a case-by-case review of the abuser(s), and the Abbott reserves the right to escalate the issue, with the intent of levying sanctions that are allowed under the gTLD anti-abuse policy.
The below policy is a recent version of the policy that has been used by the .INFO registry since 2008, and the .ORG registry since 2009. It has proven to be an effective and flexible tool.
.ABBVIE Anti-Abuse Policy
The following Anti-Abuse Policy is effective upon launch of the .ABBVIE gTLD. Malicious use of domain names will not be tolerated. The nature of such abuses creates security and stability issues for the registry, registrars, and registrants, as well as for users of the Internet in general. Abbott’s definition of abusive use of a domain 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 email spam and similar abuses such as instant messaging spam, mobile messaging spam, and the spamming of web sites and Internet forums;
- Phishing: The use of counterfeit web pages that are designed to trick recipients into divulging sensitive data such as personally identifying information, usernames, passwords, or financial data;
- Pharming: The redirecting of unknowing users to fraudulent sites or services, typically through, but not limited to, 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;
- Malicious fast-flux hosting: Use of fast-flux techniques with a botnet to disguise the location of web sites or other Internet services, or to avoid detection and mitigation efforts, or to host illegal activities;
- 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 distributed denial-of-service attacks (DDoS attacks); 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).
Pursuant to the Registry-Registrar Agreement, Abbott reserves the right at its sole discretion to deny, cancel, or transfer any registration or transaction, or place any domain name(s) on registry lock, hold, or similar status, that it deems necessary: (1) to protect the integrity and stability of the registry; (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 the part of Abbott, as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement and this Anti-Abuse Policy; or (5) to correct mistakes made by Abbott or any registrar in connection with a domain name registration. Abbott also reserves the right to place upon registry lock, hold, or similar status a domain name during resolution of a dispute.
The policy stated above will be accompanied by notes about how to submit a report to Abbott’s abuse point of contact, and how to report an orphan glue record suspected of being used in connection with malicious conduct (see below).
Abuse Point of Contact and Procedures for Handling Abuse Complaints
Abbott will establish an abuse point of contact. This contact will be a role-based e-mail address of the form “abuse@registry..ABBVIE.” This e-mail address will allow multiple staff members to monitor abuse reports on a 24⁄7 basis, and then work toward closure of cases as each situation calls for. For tracking purposes, Abbott will have a ticketing system with which all complaints will be tracked internally. The reporter will be provided with the ticket reference identifier for potential follow-up. Afilias will integrate its existing ticketing system with Abbott’s to ensure uniform tracking and handling of the complaint. This role-based approach has been used successfully by ISPs, e-mail service providers, and registrars for many years, and is considered a global best practice.
Abbott’s designated abuse handlers will then evaluate complaints received via the abuse system address. They will decide whether a particular issue is of concern, and decide what action, if any, is appropriate.
In general, Abbott will find itself receiving abuse reports from a wide variety of parties, including security researchers and Internet security companies, financial institutions such as banks, Internet users, and law enforcement agencies among others. Some of these parties may provide good forensic data or supporting evidence of the malicious behavior. In other cases, the party reporting an issue may not be familiar with how to provide such data or proof of malicious behavior. It is expected that a percentage of abuse reports to Abbott will not be actionable, because there will not be enough evidence to support the complaint (even after investigation), and because some reports or reporters will simply not be credible.
The security function includes a communication and outreach function, with information sharing with industry partners regarding malicious or abusive behavior, in order to ensure coordinated abuse mitigation across multiple TLDs.
Assessing abuse reports requires great care, and Abbott will rely upon professional, trained investigators who are versed in such matters. The goals are accuracy, good record-keeping, and a zero false-positive rate so as not to harm innocent registrants.
Different types of malicious activities require different methods of investigation and documentation. Further, Abbott expects to face unexpected or complex situations that call for professional advice, and will rely upon professional, trained investigators as needed.
In general, there are two types of domain abuse that must be addressed:
a) Compromised domains. These domains have been hacked or otherwise compromised by criminals, and the registrant is not responsible for the malicious activity taking place on the domain. For example, the majority of domain names that host phishing sites are compromised. The goal in such cases is to get word to the registrant (usually via the registrar) that there is a problem that needs attention with the expectation that the registrant will address the problem in a timely manner. Ideally such domains do not get suspended, since suspension would disrupt legitimate activity on the domain.
b) Malicious registrations. These domains are registered by malefactors for the purpose of abuse. Such domains are generally targets for suspension, since they have no legitimate use.
The standard procedure is that Abbott will forward a credible alleged case of malicious domain name use to the domain’s sponsoring registrar with a request that the registrar investigate the case and act appropriately. The registrar will be provided evidence collected as a result of the investigation conducted by the trained abuse handlers. As part of the investigation, if inaccurate or false WHOIS registrant information is detected, the registrar is notified about this. The registrar is the party with a direct relationship with—and a direct contract with—the registrant. The registrar will also have vital information that Abbott will not, such as:
- Details about the domain purchase, such as the payment method used (credit card, PayPal, etc.);
- The identity of a proxy-protected registrant;
- The purchaser’s IP address;
- Whether there is a reseller involved; and
- The registrant’s past sales history and purchases in other TLDs (insofar as the registrar can determine this).
Registrars do not share the above information with registry operators due to privacy and liability concerns, among others. Because they have more information with which to continue the investigation, and because they have a direct relationship with the registrant, the registrar is in the best position to evaluate alleged abuse. The registrar can determine if the use violates the registrar’s legal terms of service or the registry Anti-Abuse Policy, and can decide whether or not to take any action. While the language and terms vary, registrars will be expected to include language in their registrar-registrant contracts that indemnifies the registrar if it takes action, and allows the registrar to suspend or cancel a domain name; this will be in addition to the registry Anti-Abuse Policy. Generally, registrars can act if the registrant violates the registrar’s terms of service, or violates ICANN policy, or if illegal activity is involved, or if the use violates the registry’s Anti-Abuse Policy.
If a registrar does not take action within a time period indicated by Abbott (usually 24 hours), Abbott might then decide to take action itself. At all times, Abbott reserves the right to act directly and immediately if the potential harm to Internet users seems significant or imminent, with or without notice to the sponsoring registrar.
Abbott will be prepared to call upon relevant law enforcement bodies as needed. There are certain cases, for example, Illegal pharmacy domains, where Abbott will contact the Law Enforcement Agencies to share information about these domains, provide all the evidence collected and work closely with them before any action will be taken for suspension. The specific action is often dependent upon the jurisdiction in which Abbott operates, although the operator in all cases will adhere to applicable laws and regulations.
When valid court orders or seizure warrants are received from courts or law enforcement agencies of relevant jurisdiction, Abbott will order execution in an expedited fashion. Compliance with these will be a top priority and will be completed as soon as possible and within the defined timelines of the order. There are certain cases where Law Enforcement Agencies request information about a domain including but not limited to:
- Registration information;
- History of a domain, including recent updates made;
- Other domains associated with a registrant’s account; and
- Patterns of registrant portfolio.
Requests for such information is handled on a priority basis and sent back to the requestor as soon as possible. Afilias sets a goal to respond to such requests within 24 hours.
Abbott may also engage in proactive screening of its zone for malicious use of the domains in the .ABBVIE gTLD, and report problems to the sponsoring registrars. Abbott could take advantage of a combination of the following resources, among others:
- Blocklists of domain names and nameservers published by organizations such as SURBL and Spamhaus;
- Anti-phishing feeds, which will provide URLs of compromised and maliciously registered domains being used for phishing; and
- Analysis of registration or DNS query data [DNS query data received by the gTLD nameservers.]
Abbott will keep records and track metrics regarding abuse and abuse reports. These will include:
- Number of abuse reports received by the registry’s abuse point of contact described above;
- Number of cases and domains referred to registrars for resolution;
- Number of cases and domains where the registry took direct action;
- Resolution times;
- Number of domains in the .ABBVIE gTLD that have been blacklisted by major anti-spam blocklist providers; and
- Phishing site uptimes in the .ABBVIE gTLD.
Removal of Orphan Glue Records
By definition, orphan glue records used to be glue records. Glue records are related to delegations and are necessary to guide iterative resolvers to delegated nameservers. A glue record becomes an orphan when its parent nameserver record is removed without also removing the corresponding glue record. (Please reference the ICANN SSAC paper SAC048 at: http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf.) Orphan glue records may be created when a domain (example.tld) is placed on EPP ServerHold or ClientHold status. When placed on Hold, the domain is removed from the zone and will stop resolving. However, any child nameservers (now orphan glue) of that domain (e.g., ns1.example.tld) are left in the zone. It is important to keep these orphan glue records in the zone so that any innocent sites using that nameserver will continue to resolve. This use of Hold status is an essential tool for suspending malicious domains.
Afilias observes the following procedures, which are being followed by other registries and are generally accepted as DNS best practices. These procedures are also in keeping with ICANN SSAC recommendations.
When a request to delete a domain is received from a registrar, the registry first checks for the existence of glue records. If glue records exist, the registry will check to see if other domains in the registry are using the glue records. If other domains in the registry are using the glue records then the request to delete the domain will fail until no other domains are using the glue records. If no other domains in the registry are using the glue records then the glue records will be removed before the request to delete the domain is satisfied. If no glue records exist, then the request to delete the domain will be satisfied.
If a registrar cannot delete a domain because of the existence of glue records that are being used by other domains, then the registrar may refer to the zone file or the “weekly domain hosted by nameserver report” to find out which domains are using the nameserver in question and attempt to contact the corresponding registrar to request that they stop using the nameserver in the glue record. Abbott does not plan on performing mass updates of the associated DNS records.
Abbott will accept, evaluate, and respond appropriately to complaints that orphan glue is being used maliciously. Such reports should be made in writing to Abbott, and may be submitted to the registry’s abuse point-of-contact. If it is confirmed that an orphan glue record is being used in connection with malicious conduct, Abbott will have the orphan glue record removed from the zone file. Afilias has the technical ability to execute such requests as needed.
Methods to Promote WHOIS Accuracy
The creation and maintenance of accurate WHOIS records is an important part of registry management. As described in our response to Question 26, WHOIS, Abbott will manage a secure, robust and searchable WHOIS service for the .ABBVIE gTLD.
WHOIS Data Accuracy
Abbott will offer a “thick” registry system. In this model, all key contact details for each domain name will be stored in a central location by the registry. This allows better access to domain data, and provides uniformity in storing the information. Abbott will ensure that the required fields for WHOIS data (as per the defined policies for the .ABBVIE gTLD) are enforced at the registry level. This ensures that the registrars are providing required domain registration data. Fields defined by the registry policy to be mandatory are documented as such and must be submitted by registrars. The Afilias registry system verifies formats for relevant individual data fields (e.g. e-mail and phone⁄fax numbers). Only valid country codes are allowed as defined by the ISO 3166 code list. The Afilias WHOIS system is extensible, and is capable of using the VAULT system, described further below.
Similar to the centralized abuse point of contact described above, Abbott can institute a contact email address which could be utilized by third parties to submit complaints for inaccurate or false WHOIS data detected. This information will be processed by Afilias’ support department and forwarded to the registrars. The registrars can work with the registrants of those domains to address these complaints. Afilias will audit registrars on a yearly basis to verify whether the complaints being forwarded are being addressed or not. This functionality, available to all registry operators, is activated based on Abbott’s business policy.
Afilias also incorporates a spot-check verification system where a randomly selected set of domain names are checked periodically for accuracy of WHOIS data. Afilias’ .PRO registry system incorporates such a verification system whereby 1 percent of total registrations or 100 domains, whichever number is larger, are spot-checked every month to verify the domain name registrant’s critical information provided with the domain registration data. With both a highly qualified corps of engineers and a 24⁄7 staffed support function, Afilias has the capacity to integrate such spot-check functionality into the .ABBVIE gTLD, based on Abbott’s business policy. Note: This functionality will not work for proxy protected WHOIS information, where registrars or their resellers have the actual registrant data. The solution to that problem lies with either registry or registrar policy, or a change in the general marketplace practices with respect to proxy registrations.
Finally, Afilias’ registry systems have a sophisticated set of billing and pricing functionality which aids registry operators who decide to provide a set of financial incentives to registrars for maintaining or improving WHOIS accuracy. For instance, it is conceivable that Abbott may decide to provide a discount for the domain registration or renewal fees for validated registrants, or levy a larger cost for the domain registration or renewal of proxy domain names. The Afilias system has the capability to support such incentives on a configurable basis, towards the goal of promoting better WHOIS accuracy.
Role of Registrars
As part of the RRA (Registry-Registrar Agreement), Abbott will require the registrar to be responsible for ensuring the input of accurate WHOIS data by its registrants. The Registrar⁄Registered Name Holder Agreement will include a specific clause to ensure accuracy of WHOIS data, and to give the registrar rights to cancel or suspend registrations if the Registered Name Holder fails to respond to the registrar’s query regarding accuracy of data. ICANN’s WHOIS Data Problem Reporting System (WDPRS) will be available to those who wish to file WHOIS inaccuracy reports, as per ICANN policy (http:⁄⁄wdprs.internic.net⁄).
The proposed use of .ABBVIE as a .BRAND gTLD in which all of the domain names will initially be registered by Abbott and its qualified subsidiaries and affiliates essentially eliminates the potential of false or inaccurate WHOIS data. Further ensuring that all domain names contain uniform, accurate, and up-to-date WHOIS information is the fact that these domain names will be registered through Abbott’s existing registrar(s), or a similarly situated registrar, which handle Abbott’s existing domain name portfolio.
Should Abbott expand the universe of potential registrants in the .ABBVIE namespace, to include third parties such as licensees or strategic partners, Abbott intends to offer the following enhanced mechanism to ensure the accuracy of WHOIS data; specifically, there will be a process put in place in which third parties will be able to submit complaints to Abbott regarding non-compliant WHOIS data. The complaint will be sent to the registrar of record. This registrar shall be contractually required to investigate and remediate said complaint. Thirty days following the forwarding of the complaint to the registrar of record, Abbott will analyze the current WHOIS data for each name alleged to be inaccurate in order to determine in the complaint has been properly addressed. If no action has been taken by the registrar, or if it is apparent that the registrant of record failed to correct the non-compliant WHOIS data, Abbott reserves the right to suspend the applicable domain name(s) until the registrant has properly updated the WHOIS record(s).
Controls to Ensure Proper Access to Domain Functions
Several measures are in place in the Afilias registry system to ensure proper access to domain functions, including authentication provisions in the RRA relative to notification and contact updates via use of AUTH-INFO codes.
IP address access control lists, TLS⁄SSL certificates and proper authentication are used to control access to the registry system. Registrars are only given access to perform operations on the objects they sponsor.
Every domain will have a unique AUTH-INFO code. The AUTH-INFO code is a six- to 16-character code assigned by the registrar at the time the name is created. Its purpose is to aid identification of the domain owner so proper authority can be established. It is the ʺpasswordʺ to the domain name. Registrars must use the domain’s password in order to initiate a registrar-to-registrar transfer. It is used to ensure that domain updates (update contact information, transfer, or deletion) are undertaken by the proper registrant, and that this registrant is adequately notified of domain update activity. Only the sponsoring registrar of a domain has access to the domain’s AUTH-INFO code stored in the registry, and this is accessible only via encrypted, password-protected channels.
Information about other registry security measures such as encryption and security of registrar channels are confidential to ensure the security of the registry system. The details can be found in the response to Question 30B.
Validation and Abuse Mitigation Mechanisms
Afilias has developed advanced validation and abuse mitigation mechanisms. These capabilities and mechanisms are described below. These services and capabilities are discretionary and may be utilized by Abbott based on its policy and business needs.
Afilias has the ability to analyze the registration data for known patterns at the time of registration. A database of these known patterns is developed from domains and other associated objects (e.g., contact information) which have been previously detected and suspended after being flagged as abusive. Any domains matching the defined criteria can be flagged for investigation. Once analyzed and confirmed by the domain anti-abuse team members, these domains may be suspended. This provides proactive detection of abusive domains.
Provisions are available to enable Abbott to only allow registrations by pre-authorized and verified contacts. These verified contacts are given a unique code that can be used for registration of new domains.
Registrant Pre-Verification and Authentication
One of the systems that could be used for validity and identity authentication is VAULT (Validation and Authentication Universal Lookup). It utilizes information obtained from a series of trusted data sources with access to billions of records containing data about individuals for the purpose of providing independent age and id verification as well as the ability to incorporate additional public or private data sources as required. At present it has the following: U.S. Residential Coverage – 90 percent of Adult Population, and also International Coverage – Varies from country to country with a minimum of 80 percent coverage (24 countries, mostly European).
Various verification elements can be used. Examples might include applicant data such as name, address, phone, etc. Multiple methods could be used for verification include integrated solutions utilizing API (XML Application Programming Interface) or sending batches of requests.
- Verification and Authentication requirements would be based on gTLD operator requirements or specific criteria.
- Based on required WHOIS Data, registrant contact details (name, address, phone).
- If address⁄ZIP can be validated by VAULT, the validation process can continue (North America +25 International countries).
- If in-line processing and registration and EPP⁄API call would go to the verification clearinghouse and return up to four challenge questions.
- If two-step registration is required, then registrants would get a link to complete the verification at a separate time. The link could be specific to a domain registration and pre-populated with data about the registrant.
- If WHOIS data is validated a token would be generated and could be given back to the registrar which registered the domain.
- WHOIS data would reflect the Validated Data or some subset, i.e., fields displayed could be first initial and last name, country of registrant, and date validated. Other fields could be generic validation fields much like a “privacy service.”
- A “Validation Icon” customized script would be sent to the registrants email address. This could be displayed on the website and would be dynamically generated to avoid unauthorized use of the Icon. When clicked on the Icon would should limited WHOIS details, e.g., Registrant: jdoe, Country: USA, Date Validated: March 29, 2011, as well as legal disclaimers.
- Validation would be annually renewed, and validation date displayed in the WHOIS.
Abuse Prevention Resourcing Plans
Since its founding, Afilias has been focused on delivering secure, stable, and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and on-going maintenance of the .ABBVIE gTLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the Afilias project management methodology allows efficient and effective use of our staff in a focused way. Abuse prevention and detection is a function that is staffed across the various groups inside Afilias, and requires a team effort when abuse is either well hidden or widespread, or both. While all of Afilias’ 200+ employees are charged with responsibility to report any detected abuse, the engineering and analysis teams, numbering over 30, provide specific support based on the type of abuse and volume and frequency of analysis required. The Afilias security and support teams have the authority to initiate mitigation.
Afilias has developed advanced validation and abuse mitigation mechanisms. These capabilities and mechanisms are described below. These services and capabilities are discretionary and may be utilized by Abbott based on its policy and business needs.
The .ABBVIE’s anticipated volume of registrations in the first three years of operation is listed in the response to Question 46. Afilias and Abbott’s anti-abuse function anticipates the expected volume and type of registrations, and together will adequately cover the staffing needs for the .ABBVIE gTLD. Abbott will maintain an abuse response team, which may be a combination of internal staff and outside specialty contractors, adjusting to the needs of the size and type of the gTLD. The team structure planned for the .ABBVIE gTLD is based on several years of experience responding to, mitigating, and managing abuse for TLDs of various sizes. The team will generally consist of abuse handlers (probably internal), a junior analyst, (either internal or external), and a senior security consultant (likely an external resource providing Abbott with extra expertise as needed). These responders will be specially trained in the investigation of abuse complaints, and will have the latitude to act expeditiously to suspend domain names (or apply other remedies) when called for.
The exact resources required to maintain an abuse response team must change with the size and registration procedures of the .ABBVIE gTLD. An initial abuse handler is necessary as a point of contact for reports, even if a part-time responsibility. The abuse handlers monitor the abuse email address for complaints and evaluate incoming reports from a variety of sources. A large percentage of abuse reports to Abbott may be unsolicited commercial email. The designated abuse handlers can identify legitimate reports and then decide what action is appropriate, either to act upon them, escalate to a security analyst for closer investigation, or refer them to registrars as per the above-described procedures. A gTLD with rare cases of abuse would conform to this structure.
If multiple cases of abuse within the same week occur regularly, Abbott will consider staffing internally a security analyst to investigate the complaints as they become more frequent. Training an abuse analyst requires three to six months and likely requires the active guidance of an experienced senior security analyst for guidance and verification of assessments and recommendations being made.
If the .ABBVIE gTLD were to regularly experience multiple cases of abuse within the same day, a full-time senior security analyst would likely be necessary. A senior security analyst capable of fulfilling this role should have several years of experience and able to manage and train the internal abuse response team.
The abuse response team will also maintain subscriptions for several security information services, including the blocklists from organizations like SURBL and Spamhaus, and anti-phishing and other domain related abuse (malware, fast-flux, etc.) feeds. The pricing structure of these services may depend on the size of the domain and some services will include a number of rapid suspension requests for use as needed.
For a large gTLD, regular audits of the registry data are required to maintain control over abusive registrations. When a registrar with a significant number of registrations has been compromised or acted maliciously, Abbott may need to analyze a set of registration or DNS query data. A scan of all the domains of a registrar is conducted only as needed. Scanning and analysis for a large registrar may require as much as a week of full-time effort for a dedicated machine and team.
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