29 Rights Protection Mechanisms

Prototypical answer:

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.INCCNI Registry, LLCfairwindspartners.comView

VeriSign, Inc. Response to Question 28 Abuse Prevention and Mitigation

28.1 Abuse Prevention and Mitigation Implementation Plan

CNI Registry’s primary safeguard against mitigating abusive and⁄or non-compliant registrations within the .INC name space is the deployment of the following tapestry of policies which increase the safety within the .INC namespace. The first is a Registrant Eligibility Policy that will ensure that only those companies organized as incorporated companies or those with a bona fide intent to organize, are be able to register domains in the .INC gTLD. Second is the Name Selection Criteria Policy which will require that entities only register domain names that correspond with their business names. The third is an Acceptable Use Policies that will be implemented to ensure that registrants use domains registered in .INC namespace are for bona fide business purposes. In addition to these policies, CNI Registry will hardcode into the registry architecture enhanced EPP Data Fields that will require registrants to provide additional information during the registration process (jurisdiction⁄Business ID). These additional EPP data fields will empower third parties to report non-compliant registrations to the registry.

28.1.2 Policies for Handling Complaints Regarding Abuse

As required by the ICANN template Registry Agreement, CNI Registry will establish, publish, and maintain on its website a single point of contact for handling abuse complaints. This contact will be a role account, e.g., abuse@registry.INC. All email inquiries submitted to this email account will be responded to in a reasonably timely manner. CNI Registry will employ an escalated complaint procedure. This procedure will place priority on complaints received from a trusted⁄verified source (e.g. law enforcement). If the complaint falls within the scope of CNI Registry’s Abuse Policy Listed below, CNI Registry reserves the right to suspend or cancel the non-compliant domain.

The role email account identified above will have multiple CNI Registry staff recipients to allow for monitoring on a 24X7 basis. In addition the phone number provided for on the Registry website will be answered by CNI Registry staff during normal working hours.

28.1.3 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. CNI Registry’s selected back-end 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.

Zone-file impact:
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.

28.1.4 Resourcing Plans

Details related to resourcing plans for the initial implementation and ongoing maintenance of CNI Registry’s abuse plan are provided in Section 2 of this response.

28.1.5 Measures to Promote WHOIS Accuracy

Ensuring the accuracy of WHOIS information is of paramount importance to CNI Registry in the operation of the ..INC gTLD. CNI Registry will employ the following mechanism to promote WHOIS accuracy.

-APPLICANT is evaluating a prohibition against the use of proxy registration services;
-CNI Registry will maintain a web-based form for third parties to submit claims regarding false and or inaccurate WHOIS data.
- An added level of security will be provided through the public availability of the additional EPP data fields (jurisdiction⁄Business ID) collected from registrants and available via public WHOIS. The availability of these additional fields will empower third parties to investigate and report to the registry for investigation potential non-compliant domain name registration. Authentication of Registrant Information

The .INC registry will utilize an enhanced EPP data set to collect information from prospective registrant including the jurisdiction of organization and business identification number. This practice of using additional EPP data fields by previous gTLD registries have proven to be an excellent resource in assisting registry operators in verifying the credentials of registrants either pre or post registration. Regular Monitoring of Registration Data for Accuracy and Completeness

Verisign, CNI Registry’s selected back-end registry services provider, has established policies and procedures to encourage registrar compliance with ICANN’s WHOIS accuracy requirements. Verisign provides the following service to CNI Registry for incorporation into its full-service registry operations.

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. Use of Registrars

CNI Registry has not yet made any final determinations regarding the criteria they will use in approving ICANN accredited registrars to provide domain name registration services in the gTLD. While CNI Registry would ideally like to establish relationships with the corporate centric registrars, CNI Registry believes that its primary focus needs to be on those retail or niche registrars providing domain name registration services as part of a bundle of services to newly created legal entities. This smaller universe and higher quality of business centric registrars will likely lead to a reduction of abusive and⁄or malicious activity.

28.1.6 Malicious or Abusive Behavior Definitions, Metrics, and Service Level Requirements for Resolution

CNI Registry will have an Authorized Usage Policy that will govern how a registrant may use its registered domain name(s). A draft framework of this policy is as follows:

By registering a name in this gTLD, the registrant agrees to be bound by the terms of this Acceptable Use Policy (AUP). Registrant may not:
1. Use domain names for any purposes that are prohibited by the laws of the jurisdiction(s) in which registrant does business, or any other applicable law.
2. Use domain names for any purposes or in any manner that violates a statute, rule, or law governing use of the Internet and⁄or electronic commerce (specifically including “phishing,” ʺpharming,ʺ distributing Internet viruses and other destructive activities).
3. Use domain names for the following types of activity:
i. Violation of the privacy or publicity rights of any third party,
ii. Promotion of or engagement in hate speech; hate crime; terrorism; violence against people, animals, or property; or intolerance of or against any protected class;
iii. Promotion of or engagement in defamatory, harassing, abusive or otherwise objectionable behavior;
iv. Promotion of or engagement in child pornography or the exploitation of children;
v. Promotion of or engagement in any spam or other unsolicited bulk email, or computer or network hacking or cracking;
vi. Infringement on the intellectual property rights of another member of the .INC gTLD community, or any other person or entity;
vii. Engagement in activities designed to impersonate any third party or create a likelihood of confusion in sponsorship;
viii.Interference with the operation of the .INC gTLD or services offered by CNI Registry;
ix. Installation of any viruses, worms, bugs, Trojan horses, or other code, files, or programs designed to, or capable of, disrupting, damaging, or limiting the functionality of any software or hardware; or distributing false or deceptive language, or unsubstantiated or comparative claims, regarding CNI Registry;
x. Registration of .INC domain names for the purpose of reselling or transferring those domain names.

28.1.7 Controls to Ensure Proper Access to Domain Functions

CNI Registry will rely upon the safeguards incorporated at the registrar level to ensure proper access to domain names. Because CNI Registry envisions working with a limited number of corporate registrars, this will provide an important gate keeping functions. Requiring Multiple, Unique Points of Contact and Means of Notification

CNI Registry will likely assigned multiple unique points of contact. In connection with compliance, abuse, or malicious activity, an individual within CNI Registry’s legal department will be identified. In connection with technical, security, and⁄or stability issues, an individual in CNI Registry’s IT department will be identified. These unique POCs will have a corresponding unique email address that will auto-forward emails to these addresses to multiple individuals in each of the appropriate departments to ensure that there is no single point of failure in the communication chain.

28.2 Technical plan that is adequately resourced in the planned costs detailed in the financial section

28.2.1 Resource Planning

CNI Registry has projected that a staff level 1.5 FTE for legal compliance and oversight for the gTLD. In addition, CNI Registry can rely upon existing in-house legal and other support staff should the need arise. CNI Registry has strategically chosen Verisign as its registry services provider because of their excellent track record in operating some of the worldʹs most complex and critical top level domains. Verisignʹs support for the .INC gTLD will help ensure its success.

28.2.2 Resource Planning Specific to Back-end Registry Activities

Verisign, CNI Registry’s selected back-end registry services provider, is an experienced back-end registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a gTLD. 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 back-end registry services it provides to CNI Registry 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 .INC gTLD as described in this application, Verisign, CNI Registry’s selected back-end 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.

28.3.2 Ongoing Anti-Abuse Policies and Procedures Policies and Procedures that Identify Malicious or Abusive Behavior

Verisign, CNI Registry’s selected back-end registry services provider, provides the following service to CNI Registry 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. Policies and Procedures that Address the Abusive Use of Registered Names

Suspension processes: Any registrant that fails to comply with any of the registries stated policies (Registrant Eligibility, Name Selection, Acceptable Use) will immediately have their domain name suspended and⁄or cancelled. In addition, any registrant that fails to timely respond to a WHOIS accuracy complaint is subject to having their domain name suspended and⁄or cancelled. Prior to taking any affirmation action in connection with an WHOIS accuracy compliant, CNI Registry will attempt to contact registrant through various electronic means (email, telephone and fax).
Suspension processes conducted by back-end registry services provider: In the case of domain name abuse, CNI Registry will determine whether to take down the subject domain name. Verisign, CNI Registry’s selected back-end registry services provider, will follow the following auditable processes to comply with the suspension request.

Verisign Suspension Notification: CNI Registry 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 CNI Registry, 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 CNI Registry with the following information:
Threat domain name
Registry incident number
Verisign case number
Error reason

Upon CNI Registry request, Verisign can provide a process for registrants to protest the suspension.

Domain Suspension: Verisign places the domain to be suspended on the following statuses:

Suspension Acknowledgement: Verisign notifies CNI Registry 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
CNI Registry abuse contact name and number, or registrar abuse contact name and number
Suspension status

28.4 When executed in accordance with the Registry Agreement, plans will result in compliance with contractual requirements

As noted in the Question 18 business plan, the purpose of this gTLD registry is to provide businesses and consumers with a trusted and secure namespace to both display and access online content related to LLCs worldwide. Given the fact that CNI Registry authored the contractual requirements, which have been incorporated into the Registrant Agreement, CNI Registry intends to fully comply with these contractual requirements. Moreover, CNI Registry has a vested interest to ensure that all registrants adhere to these legal requirements.
As noted, in the above referenced compliance section, failure for registrants to timely remedy any non-compliant activity will result in the suspension and⁄or deletion of the domain in question.

28.5 Technical plan scope⁄scale that is consistent with the overall business approach and planned size of the registry

28.5.1 Scope⁄Scale Consistency

As a restricted-registrant gTLD Registry, the allocated registry staff will ensure that all registrations are in compliance with the requirements set forth in the Registrant Agreement. The .INC gTLD will likely be serviced by a limited universe of corporate-centric registrars and registrars providing services to new businesses. Unlike other registries that must oversee numerous registrars and untold number of registrants, the .INC gTLD will be a limited-universe of known entities with a pre-existing legal or membership relationship with the APPLICANT that will likely be registered through one registrar.

28.5.2 Scope⁄Scale Consistency Specific to Back-End Registry Activities

Verisign, CNI Registry’s selected back-end registry services provider, is an experienced back-end 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 .INC 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 back-end registry services it provides to CNI Registry 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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