gTLD	Full Legal Name	E-mail suffix	Detail
.tatar	Limited Liability Company ʺCoordination Center of Regional Domain of Tatarstan Republicʺ	cctld.ru	View

1. INTRODUCTION

Domain name registration policies in the prospective community-based gTLD .TATAR suggest that the domain name may be registered only upon presenting recommendations from two effective registrants in .TATAR. The Applicant believes that such requirement will form an additional regulating factor to lower the number of abuses and malpractices in .TATAR. That said, guided by the ICANN’s policies and recommendations, and the industry best practices the Applicant envisages implementation of sufficient and efficient anti-abuse measures in the TLD nonetheless.

The Applicant believes that abusive registrations or use of domain names in the applied-for gTLD .TATAR should not be tolerated.
Prior to the launch of the TLD, the Applicant will develop and publish on his website the respective Anti-Abuse Policies in the applied-for TLD based on materials set forth in the present section, the Application Guidebook requirements, ICANN standards and policies on abuse prevention and mitigation, as well as industry best practices.

Abuse minimization within this section suggests certain measures in the TLD that the prospective Registry Operator or Registrars (in accordance with requirements of Registry-Registrar Agreement (RRA)) can undertake in order to prevent or terminate abuse in case of its identification, as well as to mitigate consequences of such actions.

As it is impossible to foresee all possible kinds of abuse that may emerge in the future, the Applicant reserves the right to modify earlier established policies and procedures and introduce additional ones aimed at minimizing abuse in the TLD. In addition, the Applicant plans to apply and factor into all the abuse specifications, requirements and policies for gTLDs approved by ICANN as well as take into consideration the corresponding recommendations of ICANN and best practices in other TLDs.

The Applicant plans to interact with organizations that specialize in exposure, analysis and termination of various illegal usages of Internet resources and are competent in the field of abusive use of domain names. The Applicant sees the purpose of such an interaction in joint development and implementing procedures of abuse identification, prompt examination and expert evaluation by third parties. Besides, information on abusive actions in Internet, including those related to using domain names, can be later used to prepare regular reports and informing all the Internet community representatives concerned about examples of malicious behavior, particularly so for the sake of preparing the industry’s black lists.

Organizations exemplifying Russian NGOs and corporations which are recognized by the Internet community and the national law-enforcement bodies as experts in this area, are the Friendly Runet Foundation (an NGO specializing in fighting child pornography) and Group-IB Ltd (renders complex services in the field of investigation into information security incidents). The Applicant plans to establish contractual relations with these organizations and engage them as experts in post-moderation procedures and evaluation of abuses in the TLD.

2. ABUSE CLASSIFICATION

The Applicant considers as abuse in the applied-for gTLD .TATAR to be any illegal and excessive use of authority, position or ability that generates security and stability challenges to the Registry Operator, Registrars and registrants as well as for Internet users in general.

The Applicant foresees, without limitation, the following categories of abuses:
(i) Abusive registration of domain names;
(ii) Abusive use of registered domain names;
(iii) Abusive activities of registrars jeopardizing the registry’s stability and security.

It is suggested to employ specific measures for minimizing the listed abuses with regard to every category. Prevention and actions in case of detection of the said abuses are used in accordance with the policies and procedures given in this section of the application for the applied-for gTLD.

Hereinafter the term ʺRegistrarʺ means ʺthe ICANN accredited registrar which entered into the Registry-Registrar Agreement (RRA) with the TLD Registry Operator.ʺ

2.1. Abusive registration of domain names

2.1.1. Abusive registration of domain names implies (including but not limited to) registration of domain names with violation of standards, restrictions, requirements and policies of ICANN (established in the Registry Agreement and the Registrar Accreditation Agreement (RAA)) and the TLD Registry Operator (established by RRA and policies for the TLD ); abuse of stability and security of the TLD registry; as well as infringement or violation of rights of a certain or indefinite group of persons, the international or national law. Such registration issues are usually related to the core domain name-related activities performed by registrars and registries.

2.1.2. The applied-for TLD will provide for the following set of measures to prevent abusive registrations of domain names:

(i) Protection to trademark holders:

- The pre-launch Sunrise service in the TLD foresees employment of a specially developed procedure of priority registration of the second-level domain names for trademark and brand owners, intending to use these domains in conformity to the mission and purposes of the gTLD .TATAR and confirming these by respective commitment and warranty. It is also envisaged to implement the Trademark Claims service in accordance with requirements set by ICANN for gTLD registries. During the Sunrise period, corporations and individuals concerned will have a possibility to challenge registration of any second-level domain name in accordance with the respective policy for Sunrise dispute resolution. More detailed information on the TLD launch is given in the answer to Evaluation Question #29.
- To prevent potential abuse during the open registration in the TLD the registrant, in accordance with the TLD policies, will be recommended, before filing an application, to make sure there is no similarity between the domain name and trademarks, names of non-profits and state agencies and other types of intellectual property.
- In the event of any disputes regarding eligibility of registration of domain names associated with illegal use of trademarks, the claimant has the right to consider such a dispute in accordance with both the procedure under the Uniform Domain Name Dispute Resolution Policy (UDRP) and the applicable law.

(ii) Protection of geographic names

In accordance with Specification 5 to the Registry Agreement the TLD provides for the list of reserved domain names which includes geographic and geopolitical names. These domain names are not available for registration. However, the reserved names are not intended to be prohibited names and may be released to corresponding and appropriate entities basing on respective policies in the TLD. The list of reserved names may also be updated from time to time. More details on protection of geographic names can be found in the answer to Evaluation Question #22.

2.1.3. Identification of abusive registrations is exercised pursuant to petitions or complaints by the parties concerned.

Petitions⁄complaints of the parties concerned are processed in accordance with the procedure described in sub-section 3.2.

2.1.4. Possible actions in the event of abuse identification.

Where abusive registrations of domain names were identified, a decision to cancel the domain name registration can be made.

2.2. Abusive use of registered domain names

2.2.1. The abusive use of domain names in the TLD is understood as follows:

- Malicious use of domain names;

- Use of domain name for posting thereon and distributing materials, data, information inconsistent with the mission and purposes of gTLD .TATAR, as well as conflicting with the Russian law and commonly recognized international legal standards;

- Use of domain name for purposes that do not correspond to the warranty and commitment given by its registrant during the registration process.

Such domain name use issues concern the registrant’s actual operation does with the domain name after the domain is created, that is, the purpose the registrant puts the domain to, and⁄or the services that the registrant operates on it. These use issues are often independent of or do not involve any registration issues.

2.2.1.1. Malicious use

Malicious use includes (but is not limited to) the following kinds of activities:

(i) Spamming
Spam is defined as bulk unsolicited e-mail (or SMS, MMS) or posting of undesired content on the websites.

(ii) Phishing
Phishing is defined as use of websites fraudulently presenting themselves as trusted sites in order to deceive Internet users and receive their key information including, but not limited to, e-mails, passwords and banking credentials.

(iii) Malware distribution
Malware is defined as installation by a registrant or a person authorized by him⁄her of software designated for penetration in, or inflicting damage to, third parties without their knowledge.

(iv) Botnet control
Botnet control is defined as an exercise from a certain domain name of control over malicious software implanted on infected computers and intended for fulfillment of a concerted impact.

(v) Any other type of domain name use for abusive activities aimed at infringement of the Internet network elements (hardware or software) that do not belong to its registrant.

2.2.1.2. Use of domain names for posting and distribution of materials, data, information inconsistent with the mission and purposes of the applied-for TLD as well as conflicting with the Russian law and commonly recognized international legal standards. This kind of abuses includes the use of domain name for placement, distribution, reproduction, transmission, etc. by any means, as well as in any form (including but not limited to) of:

(i) materials⁄data⁄information promotion of which is either prohibited or restricted by law of the Russian Federation (such as, for instance, narcotics or psychotropic substances, liqueurs, tobacco products, etc.);

(ii) software and⁄or other materials that are, in part or in full, protected by copyright, author’s right and allied rights without consent of the rights holder, as well as content which concerns any patent, trade mark, commercial secret, copyright or other proprietary rights and⁄or author’s right and associated with it the third party’s rights;

(iii) hyperlinks to Internet resources whose contents contravene the Russian Federation law and commonly recognized international standards;

(iv) materials⁄data⁄information, contradicting to public and moral order, bona fide, infringing the rights of the third persons (for instance, those with obscene content, antihuman calls insulting human dignity, religious sentiments, etc.);

(v) materials⁄data⁄information of erotic and pornographic nature, which directly or indirectly promote unhealthy lifestyle, sects, extremism, threats to physical or mental health;

(vi) any other materials⁄data⁄information conflicting with Russian and⁄or international law;

(vii) any other materials⁄data⁄information inconsistent with the mission and purposes of the TLD.

2.2.1.3. Use of domain name for purposes that do not correspond to the warranty and commitment given by its registrant during the registration process. This abusive use may occur when the registrant use the domain name, for instance, to post and distribute materials⁄data⁄information which are legal by their own but contradict the purpose of the domain name use as stated by the registrant.

2.2.2. In order to prevent abusive use of domain names, the Applicant establishes a number of requirements to registrants therein that will be stipulated in the TLD registration policy and which the Registrar, in accordance with RRA, is bound to include in the registrants’ obligations under registration agreement.

(i) The registrant is bound to use the domain name in accordance with the mission and purposes of .TATAR domain.

(ii) While registering the domain name, the registrant is bound to provide commitment and warranty (by filling out the “descriptionʺ field during registration of domain, supported by the EPP extension schema as described in the answer to Evaluation Question #25), that purpose of the use of the domain name does not contradict the mission and purposes of the TLD. Where it has been found out that the domain name was used against these commitment and warranty, the registrant may become subject to sanctions to the extent of cancellation of the domain name registration.

(iii) Registrant is bound to present recommendations from two effective registrants in the TLD .TATAR in case the domain name is registered during the landrush and live period.

2.2.3. Identification of abusive use takes place basing on submission of petition or complaint by a party concerned.

(i) Petitions⁄complaints by parties concerned are processed in accordance with the procedure described in sub-section 3.2.

(ii) Where any disputes arise with respect to legality of usage of domain names related to abusive use of trademarks, decisions are made in accordance with the Uniform Dispute Resolution Policy, the Uniform Rapid Suspension System or other dispute resolution policies developed and approved by ICANN, as well as by the effective law of the Russian Federation.

2.2.4. Where an abusive use of a domain name has been identified, one of the following measures may become applicable:

(i) Suspension of the domain name delegation.
In case of application of this measure, the domain may not be delegated until the moment the detected violations are remedied (domain gets status EPP «inactive» and EPP «serverHold»).

(ii) Restrictions on the use of the domain name.
In case of application of this measure, the domain name may not be transferred to another Registrar, updated, renewed, or deleted (domain gets a combination of EPP statuses – «serverTransferProhibited», «serverRenewProhibited», «serverUpdateProhibited», «serverDeleteProhibited»). The measure can be applied together with the one referred to in p.(i).

(iii) Cancellation of the domain registration.
Where measures described in pp. (i)-(ii) are taken, the registrant is granted a certain period of time to eliminate the identified abuse. In case the registrant has failed to remedy the abuse within a given time period, the domain name is deleted. For a greater detail, see sub-section 3.2.

2.3. Abusive Registrar activities

2.3.1. Abusive Registrar’s activities constitute any acts by which Registrars breach restrictions, requirements and policies of the RRA agreement in the TLD and endangering the normal operation of the registry, the Registry Operator and registrants, DNS and the Internet on the whole.

The Applicant will also closely monitor Registrars’ activities related to noncompliance with ICANN standards, limitations and policies. To prevent and mitigate such activities, the Applicant plans to include into RRA respective obligations of, and the right to impose sanctions on Registrars, which would range from a temporary suspension of RRA to its termination. These sanctions, for instance, may be imposed in the case of non-compliance with the UDRP, the URS, or once it has been found out that the Registrar does not take necessary measures to react to reports about WHOIS data inaccuracy received from the WHOIS Data Problem Report System, despite of obligations under RAA.

2.3.2. In order to prevent Registrars’ abusive activities, the Applicant implements Operational Test and Evaluation (OT&E) certification. The purpose of OT&E certification is to verify accurate operation of Registrarʹs client system. For the sake of urgent consultations and support of Registrars Customer and Technical support services shall be deployed. More details are given in the answer to Evaluation Question #23.

2.3.3. Identification of Registrars’ abusive activities takes place pursuant to petitions⁄complaints by parties concerned in accordance with the complaints processing procedures described in sub-section 2.2, as well as on the basis of the registry database operational monitoring by the Registry Operator, described in the answer to Evaluation Question #42.

2.3.4. To identify Registrars’ abusive activities, the following measures can be applied:

(i) Suspend of RRA and delivery of a warning notification to the Registrar requiring to terminate the identified abuse and mitigate its consequences.

(ii) Termination of RRA.
The Registry Operator will send a prompt electronic and written notice to the Registrar, with respective copies sent in the same manner to ICANN, describing restrictions and policies the Registrar has violated. The ensuing procedure concerning the Registrarʹs eligibility to continue to sponsor registered domain names in the TLD is governed by the Registry-Registrar Agreement and the Registrar Accreditation Agreement.

3. GENERAL ORGANIZATIONAL MEASURES FOR ABUSE MINIMIZATION

This sub-section enumerates general organizational measures designed for minimization of abuses in the TLD.

3.1. Abuse point of contact

The proposed Registry Operator will establish and publish on its website a single abuse point of contact responsible for addressing matters requiring prompt attention and providing a timely response to abuse complaints with respect to all the domain names registered in the TLD through all the operating Registrars, including resellers.

The Registry Operator is bound to keep this contact data up-to-date at all times.

Processing of complaints received by the single abuse point of contact will be performed by the Duty Shift of the Anti-Abuse Team 24х7х365 with account taken of categories of complaints, as described in sub-section 3.2.

3.2. Abuse complaints processing procedure

This sub-section describes in a general form the procedure of processing complaints about abusive activities related to registration or use of domain names in the TLD.

The detailed procedure will be developed by Registry Operator and posted on its website.

A complaint regarding any problem related to operation of a domain name in the TLD can be filed by any party (a corporation, an individual, or a law enforcement agency) concerned.

The following categories of complaints with the corresponding response time are foreseen:

- Category 1: complaints with regard to abuse activities requiring an immediate action to minimize its potential effect (i.e. phishing, malware distribution, etc.): the response time to the complaint shall be no more than 3 hours;
- Category 2: other types of complaints: the response time shall be no more than 3 calendar days.

“Response time” means the time period within which the Duty Shift of the Anti-Abuse Team shall complete the initial processing of the complaint, including urgent steps to minimize the abuse impact.

The total time for processing of complaints by the Anti-Abuse Team may not exceed 60 calendar days from the moment of receipt of the abuse complaint and through the moment of closing the respective case in Trouble Ticket Management System (TTMS).

The procedure is designed to process complaints on a minimum required level, and to reduce abuse remedy time.

(i) Receipt of complaint

Any complaint received by the single abuse point of contact is registered in the TTMS. The registration is processed automatically if the complaint is submitted via e-mail or a special Web-interface on the Registry Operator’s website. If the complaint is submitted through other channels (e.g., by phone) the Anti-Abuse Team staff processes it manually. The complainant is given the Trouble Ticket Reference Number in TTMS. The case remains active in TTMS until the complaint processing is complete.

Information about incoming complaints as well as results of their processing by the Anti-Abuse Team is to be stored in the TTMS for 3 (three) years in case of law-enforcement agencies’ inquiry regarding any case.

(ii) Initial complaint processing

At this stage, the Duty Shift of the Anti-Abuse Team evaluates adequacy of the incoming complaint, and defines its category.

Where the incoming complaint is recognized inadequate, the complaint processing is terminated and the case in TTMS is closed. The corresponding notification is sent only to the complainant.

Where the incoming complaint is recognized adequate, the Duty Shift exercises activities in accordance with the category of the complaint:

- Category 1 complaint: the suspicious domain is blocked (the delegation is suspended and the ban on its transfer, renewal, update or deletion is established). The registrant and sponsoring Registrar receive due notification with the incoming complaint data and reasons for the domain name blocking;

- Category 2 complaint: the suspicious domain is NOT blocked. Due notification is sent to the registrant and sponsoring Registrar on a copy. The notification should include the incoming complaint data and suggestion to the registrant to produce clarifications regarding the complaint within the specified time period.

(iii) Main body complaint processing

Category 1 complaint:

Within 30 calendar days the registrant can request clarifications from the Anti-Abuse Team and confirm discontinuation of the identified abuse.
- If within 30 days the registrant has failed to refer to the Anti-Abuse Team, the domain name registration is cancelled. The complaint processing is complete.
- If the registrant has referred to the Anti-Abuse Team with clarifications, by results of the respective analysis and evaluation the domain name can be reactivated. The complaint processing is complete.

Category 2 complaint:

- The Anti-Abuse Team escalates the complaint to panel of experts for evaluating the suspicious domain. Experts operate on the basis of internal regulations consistent with the policies and procedures the Registry Operator established in the TLD.
- Where the registrant’s explication has been received within the noted time period, the Anti-Abuse Team submits it to experts for comprehensive evaluation of the situation. If the explication was received after the noted time period, experts do not consider it when processing the complaint.
- Upon receipt of the informed judgment, the Anti-Abuse Team: 1) dispatches notification of the evaluation findings to the registrant and sponsoring Registrar. Complaint processing is completed; or 2) blocks domain (suspends delegation, establishes prohibition to transfer, renew, update and delete the domain). The corresponding notification is sent to the registrant and sponsoring Registrar.
- Within 30 calendar days after the domain name blocking, the registrant may contact the Anti-Abuse Team for clarifications and confirmation of discontinuation of the abuse.
- If within 30 calendar days the registrant failed to refer to the Anti-Abuse Team, the domain registration is cancelled. The complaint processing is complete.
- If the registrant has referred to the Anti-Abuse Team with clarifications, they are subject to evaluation by results of which the domain may be reactivated. The complaint processing is complete.

(iv) Completion of complaint processing

When complaint processing is complete, notification of its results is dispatched to the complainant, registrant and sponsoring Registrar. The respective case is closed in TTMS.

(v) Remedy of abuse by the registrant

Where the registrant received notification of a complaint and of measures taken in response thereto and the registrant is able to remedy the abuse, he⁄she may undertake the necessary steps to remedy the abuse and report results to the Anti-Abuse Team. Where re-examination proves that the abuse has been remedied, sanctions against the domain name may be stopped and the domain may be re-activated.

3.3. Responding to law-enforcement requests concerning abuses

The Registry Operator provides for a special service level for law-enforcement requests.

Law-enforcement requests concerning any kinds of abuses classified in the TLD are processed in accordance with the complaint processing procedure (sub-section 3.2).

Where a law-enforcement agency’s request concerns any abuse that is not explicitly specified by the Registry Operator , the Anti-Abuse Team’s response time shall not exceed 1 (one) workday.

The Registry Operator may enter into an interaction agreement with a specific law-enforcement agency. Where such an agreement has been entered into, any requests from that law -enforcement agency are dispatched to the Anti-Abuse Team via a trusted channel (for instance, requests are sent from the authorized e- mail address or verified with electronic digital signature). For processing of such requests they are granted a priority status, which implies their processing in TTMS in a separate queue with mandatory granting the request the category 1 complaint status.

3.4. Processing of orphan glue records

When provided with evidence in writing that the glue is present in connection with malicious conduct (according to Specification 6 to the Registry Agreement), the orphan glue records are deleted.

In this case, the Registry Operator will exercise the following procedure:
- Identification of the registered domain names associated with the aforementioned orphan glue records;
- Examination of the list of nameservers necessary for the domain names delegation;
- In case of failure to meet the requirement to provide two appropriate nameservers, suspension of delegation of the domain;
- Sending notification to the domain name sponsoring registrar and its registrant on steps taken and the need to update information about nameservers for re-delegation of the domain.

4. RESOURCING PLANS. PERSONNEL.

To ensure operation of the single abuse point of contact and processing of abuse complaints, the Applicant concludes an agreement with a third-party contractor. The third-party contractor selected is JSC ʺTechnical Center of Internetʺ which has necessary personnel with required skill levels and extensive record of processing abuse complaints. The agreement sets strict service level requirements that must be followed by the contractorʹs personnel, in particular, the Duty shift’s response time with respect to category-1 complaints (no more than 3 hours) and category-2 ones (no more than 3 calendar days), complaints processing timelines, and other parameters.

Functions of the Anti-Abuse Team are performed by Duty Operators working in the 24х7х365 mode.

Based on available to the Applicant statistics of complaints with regard to abuse-related issues in the existing TLDs, it is possible to project a number of complaints to the Anti-Abuse Team. For 65,220 domain names registered by the end of the third year, the provisional monthly number of complaints should not exceed 14 per month. With an average claim processing time of 60 minutes in man-hour equivalent by one Anti-Abuse Team Operator, this accounts for 12-14 man-hours a month, excluding the time of expert organizations evaluations. Thus, the number of Operators assigned to the Duty Shift of the Anti-Abuse Team is considered to be sufficient.

The functional duties of the personnel assigned to the Anti-Abuse Team include:
- Observance of complaints processing procedures;
- Evaluation of the incoming abuse claims within the limits of their competence, including classification of complaints by the type of abuse in accordance with the service instructions;
- Interaction with expert organizations on conditions set forth by agreements the said expert organizations enter into with the Registry Operator;
- Interaction with the complainant, registrant and sponsoring registrar in the course of processing abuse;
- Observance of escalation procedures of queries to the Registry Operator or the Registry Service Provider’s corresponding services, if necessary.

Operations of the Duty Operators of Anti-Abuse Team are regulated by service instructions. These service instructions constitute an internal document for use only by the corresponding personnel and include description of required actions of the Duty Operators of the Anti-Abuse Team while processing complaints.

The JSC ʺTechnical Center of Internet” confirms the delivery of the Anti-Abuse Team Service as acknowledged by the Letter of Intent (See the attachment to Evaluation Question #46 - Q46_LOITCI).

5. WHOIS ACCURACY ENHANCEMENT MEASURES

This sub-section enumerates measures aimed at increasing the accuracy of WHOIS data.

The mission and purposes of the TLD require elimination of registration of domain names with anonymous or false WHOIS data. As information on registrants is collected by Registrars, certain requirements are laid toward Registrars within RAA and RRA.

5.1. Collection of registration data

In accordance with RAA and RRA provisions, Registrars in the TLD shall collect registration information from the registrant and check it to ensure validity of the domain-name registration. The Registrar must submit through the Shared Registration System (SRS) complete, accurate, and valid registration data, and must update that data when changes occur.

Where domains are registered by legal entities, the Registrar collects information that can be used for unambiguous identification of the corporate registrant (name, taxpayer identification number (TIN), principal place of business, postal address, phone number, e-mail). Data allowing automatic verification (e.g. TIN) shall be subject to such verification.

Where domains are registered by individuals, the Registrar collects information that can be used for their unambiguous identification (name in full, postal address, phone numbers, e-mails).

Besides, the Registrar collects recommendations from two effective registrants in the TLD .TATAR as well as commitment and warranty provided by the registrant during the domain name registration process and confirming consistency with the mission and purposes of the gTLD .TATAR.

5.2. Verification of registrant information

In accordance with RAA, after the domain name registration the Registrar is required to send the registrant a notification of the domain name renewal procedure, the policy of the domain deletion in case of his⁄her failure to renew it, as well as on the need to update the registrant data in case of its alteration and to update it at least annually. This notification should also include possible consequences of failure to respond to Registrars’ requests to confirm the earlier given WHOIS data to the extent of cancelling the domain registration.

In accordance with the RRA provisions, the Registrar will be obligated to make sure that the registrant provided genuine data and can be reached on⁄at the a contact he⁄she specified for each type of contacts (registrant, administrative contact, technical contact). In order to verify the registrant data the Registrars are bound to conduct specialized checkups, namely:

(i) Examination of the presence of two recommendations from effective registrants in TLD .TATAR as of the moment of registration of the domain name and presence of warrantees and commitment is consistent with the mission and purposes of the gTLD .TATAR.

(ii) Phone number verification
For instance, Registrar can use SMS-authorization, where an SMS is sent to the registrant’s contact phone number with a request for the registrant response actions to complete authorization or it can be a call placed by the Registrar’s staff to the phone number provided by the registrant given.

(iii) E-mail verification
For instance, back-verification is used, where the registrant must send a reply with certain content or receives an e-mail request sent by Registrar or where the registrant must use the given hyperlink to complete verification.

Besides, the Registry Operator will prepare recommendations for Registrars to conduct, at their discretion, checkups of documentary confirmations of registrant information.

In accordance with ICANN WHOIS Data Reminder Policy, at least annually, a registrar must present to the registrant current WHOIS data, and remind the registrant that provision of false WHOIS data can form grounds for cancellation of his⁄her domain name registration. Registrants must review their WHOIS data, and make respective modifications therein.

ICANN Restored Names Accuracy Policy states that when a registrar restores the name (from the redemption grace period) that had been deleted on the basis of submission of false contact data or because of failure to respond to Registrar’s inquiries, the name must be placed on the Registrar Hold status until the registrant has provided updated and accurate WHOIS data.

5.3. Encouragement of Registrars

The proposed Registry Operator plans to periodically conduct spot checks of registrant data collected by Registrars.

To conduct the check the Registry Operator may contact registrants by sending registered postal letters to his⁄her postal addresses (with delivery confirmation), e-mail queries at contact e-mail addresses or by placing calls to his⁄her contact phone numbers and those of administrative and technical contacts in order to confirm the relevance of the earlier provided WHOIS data.

Reports containing the spot check findings will be forwarded to all the gTLD Registrars. Based on the reports, those Registrars which have demonstrated a high level of authenticity and accuracy of registrant information will be awarded a possibility to take part in joint marketing campaigns with the Registry Operator.

Where the Registrar regularly exhibits a low level of accuracy of WHOIS data, the Registry Operator has the right to run a detailed examination of registration information with regard to domain names sponsored by that Registrar. By results of such an examination the Registry Operator is given time to remedy exposed abuses. Where the Registrar has failed to remedy the abuses within the prescribed time periods or where the Registrar has permanently abused the rules and policies, the decision may be made to suspend the effect of RRA as per terms and conditions set forth in RRA.

5.4. Other measures

In order to protect registrants and as well as to abide by Russian Federal Act FZ-152 ʺOn personal dataʺ, the Registry Operator does not disclose registrants personal data (including those of the administrative and technical contact) as well as e-mails and phone numbers in the publicly available WHOIS.

The Registry Operator obligates Registrars to ensure the possibility to contact the registrant without publication of his⁄her contact data in WHOIS (e-mail, phone number). This can be implemented, for instance, by means of publishing a web-form that allows sending messages to the registrant. The Registry publishes in its WHOIS the hyperlink to the web-form on the Registrar website.

6. PREVENTION OF UNAUTHORIZED ACCESS TO DOMAIN FUNCTIONS

Prevention of unauthorized access to domain functions must be implemented only within the frame of relations between the Registrar sponsoring the domain and its registrant. The Registry Operator establishes certain obligations under RRA for their mandatory observance by Registrars as well as recommendations for Registrars which can be translated into the registration agreement.

In accordance with the RRA provisions, the Registrars are obligated to check for complexity the passwords registrants use to carry out critical operations with their domain names.

Besides, the Registry Operator obligates the Registrars to implement the following measures:
- The Registrar is bound to grant registrant the possibility to control the domain name via Web-interfaces using HTTPS protocol.
- The Registrar is bound to send notifications to registrant, administrative and technical contacts upon completion of any critical operation with the domain (update, renewal, transfer, deletion) as well as to include in those notifications information of where one should refer to in the event the operation was not authorized by the registrant.
- The Registrar is bound to establish mechanisms to check for resiliency and security passwords the registrant uses to access to domain critical functions and to warn the registrant and his⁄her contacts of responsibility to ensure secure storage of passwords.

The Registrar is recommended to have registrants use machine-generated passwords to ensure proper access to domain functions.

Where domains are transferred, the parties engaged therein are bound to comply with the ICANN requirements to Holder-Authorized Transfers as set forth in the Inter-Registrar Transfer Policy (http:⁄⁄www.icann.org⁄en⁄transfers⁄policy-en.htm).

7. CONCLUSION

The answer fully covers all issues of Evaluation Question #28. The Applicant describes the proposed policies and procedures to minimize abusive registrations and use of domain names as well as other activities that might have a negative impact on Internet users. The Applicant will implement and publish on its website a single abuse point of contact and establish the respective Abuse Complaint Processing Procedure. Measures for removal of orphan glue records are proposed. To promote accuracy of WHOIS, the Applicant will implement relevant measures including authentication of registrant information to be complete and accurate at the moment of registration, regular monitoring of registration data, employing most advanced authentication methods and establishing policies and procedures to address domain names with inaccurate or incomplete WHOIS data. The Applicant will ensure Registrars’ compliance with contractual requirements regarding WHOIS accuracy, including spot checks and financial encouragement of Registrars. Malicious or abusive behavior, including unambiguous definitions of the phenomena of abuse in the TLD and procedures that will allow an efficient mitigation of potential for abuse in the TLD are defined. The Applicant will establish special Service Level Requirements for abuse resolution, including service levels for responding to law enforcement agencies’ inquiries and requests. The Applicant will exercise adequate controls to ensure a proper access to domain critical functions.

gTLD	Full Legal Name	E-mail suffix	Detail
.skolkovo	Fund for Development of the Center for Elaboration and Commercialization of New Technologies	cctld.ru	View

1. INTRODUCTION

The mission and purposes of .SKOLKOVO suggest that the applied-for gTLD will have a limited circle of registrants. Nevertheless, the Applicant plans to implement sufficient and effective measures to prevent and mitigate consequences of potential abuses in the gTLD.
The Applicant believes that abusive registrations or use of domain names in the applied-for gTLD .SKOLKOVO should not be tolerated.

The Applicant will develop and publish on his website the respective Anti-Abuse Policies in the gTLD .SKOLKOVO based on materials set forth in the present section, the Application Guidebook requirements, ICANN standards and policies on abuse prevention and mitigation, as well as industry best practices.

Abuse minimization suggests certain measures that the Registry Operator or⁄and Registrars (in accordance with requirements of Registry-Registrar Agreement (RRA)) should undertake in order to prevent abuse or terminate abuse in case of its identification, as well as to mitigate consequences of such actions.

Since it is impossible to foresee all possible kinds of abuse that may emerge in the future, the Applicant reserves the right to modify earlier established policies and procedures and introduce additional ones aimed at minimizing abuse. In addition, the Applicant plans to apply and factor into all the abuse specifications, requirements and policies for gTLDs approved by ICANN as well as take into consideration the corresponding recommendations of ICANN and best practices in other TLDs.

The Applicant will consider interaction with organizations that specialize in exposure, analysis and termination of various illegal usages of Internet resources and are competent in the field of abusive use of domain names. The purpose of this collaboration is to examine and implement in the applied-for TLD the Internet industry’s best practices, as well as to engage experts from those organizations in evaluation of incoming abuse requests concerning domain name registrations and use in the TLD. Besides, information on abusive actions in Internet, including those related to using domain names, can be later used to prepare regular reports and informing all the Internet community representatives concerned about examples of malicious behavior, particularly so for the sake of preparing industry’s black lists.

2. ABUSE CLASSIFICATION

The Applicant considers as abuse in the applied-for TLD to be any illegal and excessive use of authority, position or ability that generates security and stability challenges to the Registry Operator, Registrars and registrants as well as for Internet users in general.

The Applicant foresees, without limitation, the following categories of abuses:
(i) Abusive registration of domain names
(ii) Abusive use of registered domain names
(iii) Abusive activities of Registrars jeopardizing the registry’s stability and security.

It is suggested to employ specific measures for minimizing the listed abuses with regard to every category. Prevention and actions in case of detection of the said abuses are used in accordance with the policies and procedures given in this section of the application for the applied-for gTLD.

Hereinafter the term ʺRegistrarʺ means ʺthe ICANN accredited registrar which entered into the Registry-Registrar Agreement (RRA) with the TLD Registry Operator.ʺ

2.1. Abusive registration of domain names

2.1.1. Abusive registration of domain names implies (including but not limited to) registration of domain names with violation of standards, restrictions, requirements and policies of ICANN (established in the Registry Agreement and the Registrar Accreditation Agreement (RAA)) and the TLD Registry Operator (established by RRA and policies for the TLD); abuse of stability and security of the TLD registry; as well as infringement or violation of rights of a certain or indefinite group of persons, the international or national law. Such registration issues are usually related to the core domain name-related activities performed by registrars and registries.

2.1.2. The applied-for TLD will provide for the following set of measures to prevent abusive registrations of domain names:

(i) Protection to trademark holders:

- The pre-launch Sunrise service in the TLD foresees employment of a specially developed procedure of priority registration of the second-level domain names for trademark and brand owners (among participants in the innovation center “Skolkovo”’s project and legal entities or individuals who have received invitations from the Registry Operator). It is also envisaged to implement the Trademark Claims service in accordance with requirements set by ICANN for gTLD registries. During the Sunrise period, corporations and individuals concerned will have a possibility to challenge registration of any second-level domain name in accordance with the respective policy for Sunrise dispute resolution. More detailed information on the TLD launch is given in the answer to Evaluation Question #29.
- To prevent potential abuse during the open registration in the TLD the registrant, in accordance with the TLD policies, will be recommended, before filing an application, to make sure there is no similarity between the domain name and trademarks, names of non-profits and state agencies and other types of intellectual property.
- In the event of any disputes regarding eligibility of registration of domain names associated with illegal use of trademarks, the claimant has the right to consider such a dispute in accordance with both the procedure under the Uniform Domain Name Dispute Resolution Policy (UDRP) and the applicable law.

(ii) Protection of geographic names

In accordance with Specification 5 to the Registry Agreement the TLD provides for the list of reserved domain names which includes geographic and geopolitical names. These domain names are not available for registration. However, the reserved names are not intended to be prohibited names and may be released to corresponding and appropriate entities basing on respective policies in the TLD. The list of reserved names may also be updated from time to time. More details on protection of geographic names can be found in the answer to Evaluation Question #22.

2.1.3. Identification of abusive registrations is exercised pursuant to petitions or complaints by the parties concerned.

Petitions⁄complaints of the parties concerned are processed in accordance with the procedure described in sub-section 3.2.

2.1.4. Possible actions in the event of abuse identification.

Where abusive registrations of domain names were identified, a decision to cancel the domain name registration can be made.

2.2. Abusive use of registered domain names

2.2.1. The abusive use of domain names in the applied-for gTLD is understood as follows:

- Malicious use of domain names;
- Use of domain name for posting thereon and distributing materials, data, information inconsistent with the mission and purposes of .SKOLKOVO, as well as conflicting with the Russian law and commonly recognized international legal standards;

Such domain name use issues concern the registrant’s actual operation does with the domain name after the domain is created, that is, the purpose the registrant puts the domain to, and⁄or the services that the registrant operates on it. These use issues are often independent of or do not involve any registration issues.

2.2.1.1. Malicious use

Malicious use includes (but are not limited to) the following kinds of activities:

(i) Spamming
Spam is defined as bulk unsolicited e-mail (or SMS, MMS) or posting of undesired content on the websites.

(ii) Phishing
Phishing is defined as use of websites fraudulently presenting themselves as trusted sites in order to deceive Internet users and receive their key information including, but not limited to, e-mails, passwords and banking credentials.

(iii) Malware distribution
Malware is defined as installation by a registrant or a person authorized by him⁄her of software designated for penetration in, or inflicting damage to, third parties without their knowledge.

(iv) Botnet control
Botnet control is defined as an exercise from a certain domain name of control over malicious software implanted on infected computers and intended for fulfillment of a concerted impact.

(v) Any other type of domain name use for abusive activities aimed at infringement of the Internet network elements (hardware or software), that do not belong to its registrant.

2.2.1.2. Use of domain names for posting and distribution of materials, data, information inconsistent with the mission and purposes of the applied-for gTLD as well as conflicting with the Russian law and commonly recognized international legal standards. This kind of abuses includes the use of domain name for placement, distribution, reproduction, transmission, etc. by any means, as well as in any form (including but not limited to) of:

(i) materials⁄data⁄information promotion of which is either prohibited or restricted by law of the Russian Federation (such as, for instance, narcotics or psychotropic substances, liqueurs, tobacco products, etc.);

(ii) software and⁄or other materials that are, in part or in full, protected by copyright, author’s right and allied rights without consent of the rights holder, as well as content which concerns any patent, trademark, commercial secret, copyright or other proprietary rights and⁄or author’s right and associated with it the third party’s rights;

(iii) hyperlinks to Internet resources whose contents contravene the Russian Federation law and commonly recognized international standards;

(iv) materials⁄data⁄information, contradicting to public and moral order, bona fide, infringing the rights of the third persons (for instance, those with obscene content, antihuman calls insulting human dignity, religious sentiments, etc.);

(v) materials⁄data⁄information of erotic and pornographic nature, which directly or indirectly promote unhealthy lifestyle, sects, extremism, threats to physical or mental health;

(vi) any other materials⁄data⁄information conflicting with Russian and⁄or international law;

(vii) any other materials⁄data⁄information inconsistent with the mission and purposes of the TLD.

2.2.2. In order to prevent abusive use of domain names, the Applicant establishes a number of requirements to registrants therein that will be stipulated in the applied-for TLD registration policy and which the Registrar, in accordance with RRA, is bound to include in the registrants’ obligations.

(i) The registrant is fully responsible for content of materials posted in the Internet with the use of his⁄her registered domain, understands and accepts possible consequences of his illegal actions.

(ii) The registrant is bound to use the domain name in accordance with the mission and purposes of .SKOLKOVO domain.

(iii) The registrant is obligated to submit documents and⁄or information confirming the fact that he⁄she has a status of the participant in the innovation center “Skolkovo”’s project or that he⁄she possess an invitation to register domain names in the TLD issued by the Registry Operator. These documents⁄information should be checked according to the procedures established by the Registry Operator. The Registry Operator plans to provide the Registrars with access to the database containing data on all actual participants of the Skolkovo project and invited persons or entities.

2.2.3. Identification of abusive use takes place upon submission of petition or complaint by a party concerned.

(i) Petition or complaint by party concerned is processed in accordance with the procedure described in sub-section 3.2.

(ii) Where any disputes arise with respect to legality of usage of domain names related to abusive use of trademarks, decisions are made in accordance with the Uniform Dispute Resolution Policy, the Uniform Rapid Suspension System or other dispute resolution policies developed and approved by ICANN, as well as by the effective law of the Russian Federation.

2.2.4. Where an abusive use of a domain name has been identified, one of the following measures may become applicable:

(i) Suspension of the domain name delegation.
In case of application of this measure, the domain may not be delegated until the moment the detected violations are remedied (domain gets status EPP «inactive» and EPP «serverHold»).

(ii) Restrictions on the use of the domain name.
In case of application of this measure, the domain name may not be transferred to another Registrar, updated, renewed, or deleted. (domain gets a combination of EPP statuses – «serverTransferProhibited», «serverRenewProhibited», «serverUpdateProhibited», «serverDeleteProhibited»). The measure can be applied together with the one referred to in p.(i).

(iii) Cancellation of the domain registration.
Where measures described in pp. (i)-(ii) are taken, the registrant is granted a certain period of time to eliminate the identified abuse. In case the registrant has failed to remedy the abuse within a given time period, the domain name is deleted. For a greater detail, see sub-section 3.2.

2.3. Abusive Registrar activities

2.3.1. Abusive Registrar’s activities constitute any acts by which Registrars breach restrictions, requirements and policies of the RRA agreement in the TLD and endangering the normal operation of the registry, the Registry Operator and registrants, DNS and the Internet in general.

The Applicant will also closely monitor Registrars’ activities related to noncompliance with ICANN standards, limitations and policies. To prevent and mitigate such activities, the Applicant plans to include into RRA respective obligations and responsibilities which for imposition of sanctions on the Registrars which would range from a temporary suspension of RRA and termination of RRA. These sanctions, for instance, may be imposed in the case of non-compliance with the UDRP, the URS, or once it has been found out that the Registrar does not take necessary measures to react to reports about WHOIS data inaccuracy received from the WHOIS Data Problem Report System, despite of obligations under RAA.

2.3.2. In order to prevent Registrars’ abusive activities, the Applicant implements Operational Test and Evaluation (OT&E) certification. The purpose of OT&E certification is to verify accurate operation of Registrarʹs client system. For the sake of urgent consultations and support of Registrars Customer and Technical support services shall be deployed. More details are given in the answer to Evaluation Question #23.

2.3.3. Identification of Registrars’ abusive activities takes place pursuant to petitions⁄complaints by parties concerned in accordance with the complaints processing procedures described in sub-section 2.2, as well as on the basis of the registry database operational monitoring by the Registry Operator, described in the answer to Evaluation Question #42.

2.3.4. To identify Registrars’ abusive activities, the following measures can be applied:

(i) Suspend of RRA and delivery of a warning notification to the Registrar requiring to terminate the identified abuse and mitigate its consequences.

(ii) Termination of RRA.
The Registry Operator will send a prompt electronic and written notice to the Registrar, with respective copies sent in the same manner to ICANN personnel, describing restrictions and policies the Registrar has violated. The ensuing procedure concerning the Registrarʹs eligibility to continue to sponsor registered domain names in the TLD is governed by the Registry-Registrar Agreement and the Registrar Accreditation Agreement.

3. GENERAL ORGANIZATIONAL MEASURES FOR ABUSE MINIMIZATION

This sub-section enumerates general organizational measures designed for minimization of abuses in the TLD.

3.1. Abuse point of contact

The proposed Registry Operator will establish and publish on its website a single abuse point of contact responsible for addressing matters requiring prompt attention and providing a timely response to abuse complaints with respect to all the domain names registered in the TLD through all the operating Registrars, including resellers.

The Registry Operator is bound to keep this contact data up-to-date at all times.

Processing of complaints received by the single abuse point of contact will be performed by the Duty Operators of the Anti-Abuse Team 24х7х365 with account taken of categories of complaints, as described in sub-section 3.2.

3.2. Abuse complaints processing procedure

This sub-section describes in a general form the procedure of processing complaints about abusive activities related to registration or use of domain names in the TLD.

The detailed procedure will be developed by Registry Operator and posted on its website.

A complaint regarding any problem related to operation of a domain name in the TLD can be filed by any party (a corporation, an individual, or a law enforcement agency) concerned.

The following categories of complaints with the corresponding response time are foreseen:

- Category 1: complaints with regard to abuse activities requiring an immediate action to minimize its potential effect (i.e. phishing, malware distribution, etc.): the response time to the complaint shall be no more than 3 hours;

- Category 2: other types of complaints: the response time shall be no more than 3 calendar days.

Response time means the time period within which the Anti-Abuse Team shall complete the initial processing of the complaint, including urgent steps to minimize the abuse impact.

The total time for processing of complaints by the Anti-Abuse Team may not exceed 60 calendar days from the moment of receipt of the abuse complaint and through the moment of closing the respective case in Trouble Ticket Management System (TTMS).

The procedure is designed to process complaints on a minimum required level, and to reduce abuse remedy time.

(i) Receipt of complaint

Any complaint received by the single abuse point of contact is registered in the TTMS. The registration is processed automatically if the complaint is submitted via e-mail or a special Web-interface on the Registry Operator’s website. If the complaint is submitted through other channels (e.g., by phone) the Anti-Abuse Team staff processes it manually. The complainant is given the Trouble Ticket reference number in TTMS. The case remains active in TTMS until the complaint processing is complete.

Information about incoming complaints as well as results of their processing by the Anti-Abuse Team is to be stored in the TTMS for 3 (three) years in case of law-enforcement agencies’ inquiry regarding any case.

(ii) Initial complaint processing

At this stage, the Duty Operator of the Anti-Abuse Team evaluates adequacy of the incoming complaint, and defines its category.

Where the incoming complaint is recognized inadequate, the complaint processing is terminated and the case in TTMS is closed. The corresponding notification is sent only to the complainant.

Where the incoming complaint is recognized adequate, the Duty Operator exercises activities in accordance with the category of the complaint:

- Category 1 complaint: the suspicious domain is blocked (the delegation is suspended and the ban on its transfer, renewal, update or deletion is established). The registrant and sponsoring Registrar receive due notification with the incoming complaint data and reasons for the domain name blocking;

- Category 2 complaint: the suspicious domain is NOT blocked. Due notification is sent to the registrant and sponsoring Registrar on a copy. The notification should include the incoming complaint data and suggestion to the registrant to produce clarifications regarding the complaint within the given time period.

(iii) Main body complaint processing

Category 1 complaint:

- Within 30 calendar days the registrant can request clarifications from the Anti-Abuse Team and confirm discontinuation of the identified abuse.
- If within 30 days the registrant has failed to refer to the Anti-Abuse Team, the domain name registration is cancelled. The complaint processing is complete.
- If the registrant has referred to the Anti-Abuse Team with clarifications, by results of the respective analysis and evaluation the domain name can be reactivated. The complaint processing is complete.

Category 2 complaint:

- The Anti-Abuse Team escalates the complaint to panel of experts for evaluating the suspicious domain. Experts operate on the basis of internal regulations consistent with the policies and procedures the Registry Operator established in the TLD.
- Where the registrant’s explication has been received within the noted time period, the Anti-Abuse Team submits it to experts for comprehensive evaluation of the situation. If the explication was received after the noted time period, experts do not consider it when processing the complaint.
- Upon receipt of the informed judgment, the Anti-Abuse Team: 1) dispatches notification of the evaluation findings to the registrant and sponsoring Registrar. Complaint processing is completed; or 2) blocks domain (suspends delegation, establishes prohibition to transfer, renew, update and delete the domain). The corresponding notification is sent to the registrant and sponsoring Registrar.
- Within 30 calendar days after the domain name blocking, the registrant may contact the Anti-Abuse Team for clarifications and confirmation of discontinuation of the abuse.
- If within 30 calendar days the registrant failed to refer to the Anti-Abuse Team, the domain registration is cancelled. The complaint processing is complete.
- If the registrant has referred to the Anti-Abuse Team with clarifications, they are subject to evaluation by results of which the domain may be reactivated. The complaint processing is complete.

(iv) Completion of complaint processing

When complaint processing is complete, notification of its results is dispatched to the complainant, registrant and sponsoring Registrar. The respective case is closed in TTMS.

(v) Remedy of abuse by the registrant

Where the registrant received notification of a complaint and of measures taken in response thereto and the registrant is able to remedy the abuse, he⁄she may undertake the necessary steps to remedy the abuse and report results to the Anti-Abuse Team. Where re-examination proves that the abuse has been remedied, sanctions against the domain name may be stopped and the domain may be re-activated.

3.3. Responding to law-enforcement requests concerning abuses

The Registry Operator provides for a special service level for law-enforcement requests.

Law-enforcement requests concerning any kinds of abuses classified in the TLD are processed in accordance with the complaint processing procedure (sub-section 3.2).

Where a law-enforcement agency’s request concerns any abuse that is not explicitly specified by the Registry Operator , the Anti-Abuse Team’s response time shall not exceed 1 (one) workday.

The Registry Operator may enter into an interaction agreement with a specific law-enforcement agency. Where such an agreement has been entered into, any requests from that law -enforcement agency are dispatched to the Anti-Abuse Team via a trusted channel (for instance, requests are sent from the authorized e- mail address or verified with electronic digital signature). For processing of such requests they are granted a priority status, which implies their processing in TTMS in a separate queue with mandatory granting the request the category 1 complaint status.

3.4. Processing of orphan glue records

When provided with evidence in writing that the glue is present in connection with malicious conduct (according to Specification 6 to the Registry Agreement), the orphan glue records are deleted.

In this case, the Registry Operator will exercise the following procedure:
- Identification of the registered domain names associated with the aforementioned orphan glue records;
- Examination of the list of nameservers necessary for the domain names delegation;
- In case of failure to meet the requirement to provide two appropriate nameservers, suspension of delegation of the domain;
- Sending notification to the domain name sponsoring Registrar and its registrant on steps taken and the need to update information about nameservers for re-delegation of the domain.

4. RESOURCING PLANS. PERSONNEL

To ensure operation of the single abuse point of contact and processing of abuse complaints, the Applicant concludes an agreement with a third-party contractor. The third-party contractor selected is JSC ʺTechnical Center of Internetʺ which has necessary personnel with required skill level and extensive record of processing abuse complaints. The agreement sets strict service level requirements that must be followed by the contractorʹs personnel, in particular, the response time with respect to category-1 complaints (no more than 3 hours) and category-2 ones (no more than 3 calendar days), complaints processing time period, and other parameters.

Functions of the Anti-Abuse Team are performed by the Duty Operators working in the 24х7х365 mode with one dedicated operator handle claims related to the applied-for TLD.

Based on available to the Applicant statistics of complaints with regard to abuse-related issues in the existing TLDs, it is possible to project a number of complaints to the Anti-Abuse Team. For 18,000 domain names registered by the end of the third year, the provisional monthly number of complaints should not exceed 4 per month. With an average claim processing time of 60 minutes in man-hour equivalent by one Anti-Abuse Team operator, this accounts for 3,5-4,0 man-hours a month, excluding the time of expert organizations evaluations. Thus, one operator assigned to the Duty shift of the Anti-Abuse Team is considered to be sufficient.

The functional duties of the operator assigned to the Anti-Abuse Team include:
- Observance of complaints processing procedures;
- Evaluation of the incoming abuse claims within the limits of their competence, including classification of complaints by the type of abuse in accordance with the service instructions;
- Interaction with expert organizations on conditions set forth by agreements the said expert organizations enter into with the Registry Operator;
- Interaction with the complainant, registrant and sponsoring Registrar in the course of processing abuse;
- Observance of escalation procedures of queries to the Registry Operator or the Registry Service Provider’s corresponding services, if necessary.

Operations of the Anti-Abuse Team personnel are regulated by service instructions. These service instructions constitute an internal document for use only by the corresponding staff and include description of required actions of the Duty shift of the Anti-Abuse Team while processing complaints.

The JSC ʺTechnical Center of Internet” confirms the delivery of the Anti-Abuse Team service as described above. This is confirmed by the Letter of Intent including Anti-Abuse Service (See attachment to Evaluation Question#46 - Q46_LOITCI).

5. WHOIS ACCURACY ENHANCEMENT MEASURES

This sub-section enumerates measures aimed at increasing the accuracy of WHOIS data.

The mission and purposes of the TLD require elimination of registration of domain names with anonymous or false WHOIS data. As information on registrants is collected by Registrars, certain requirements are laid toward Registrars within RAA and RRA.

5.1. Collection of registration data

In accordance with the RAA and RRA provisions, Registrars in the TLD shall collect registration information from the registrant and check it to ensure validity of the domain-name registration. The Registrar must submit through the Shared Registration System (SRS) complete, accurate, and valid registration data, and must update that data when changes occur.

Where domains are registered by legal entities, the Registrar collects information that can be used for unambiguous identification of the corporate registrant (name, taxpayer identification number (TIN), principal place of business, postal address, phone number, e-mail). Data allowing automatic verification (e.g. TIN) shall be subject to such verification.

Where domains are registered by individuals, the Registrar collects information that can be used for their unambiguous identification (name in full, postal address, phone numbers, e-mails).

The Registrar collects information and⁄or documents confirming that a legal entity or an individual has a status of actual participant in the innovation center “Skolkovo”’s project or has a valid invitation from the Registry Operator, and meets the requirements to a registrant established in the TLD’s policies. In compliance with the RRA an obligation will be imposed on the Registrar to verify the said information⁄documents. The Applicant plans to provide the Registrars with access to the database containing data on actual participants of the Skolkovo project and special invitations issued by the Registry Operator.

5.2. Verification of registrant information

In accordance with RAA, after the domain name registration the Registrar is required to send the registrant a notification of the domain name renewal procedure, the policy of the domain deletion in case of his⁄her failure to renew it, as well as on the need to update the registrant data in case of its alteration and to update it at least annually. This notification should also include possible consequences of failure to respond to Registrars’ requests to confirm the earlier given WHOIS data to the extent of cancelling the domain registration.

In accordance with the RRA provisions, the Registrar will be obligated to make sure that the registrant provided genuine data and can be reached on⁄at the a contact he⁄she specified for each type of contacts (registrant, administrative contact, technical contact). In order to verify the registrant data the Registrars are bound to conduct specialized checkups, namely:

(i) verification of information⁄documents confirming that a registrant has a status of actual participant in the innovation center “Skolkovo”’s project (eg. a valid certificate of participant) or has obtained an invitation to register domain names in the TLD from the Registry Operator.
To perform the verification, the Registrar can use the database which is supported by the Registry Operator and contains data of all participants in the Skolkovo project and their certificates as well as invitations specially issued by the Registry Operator.

(ii) Phone number verification
For instance, Registrar can use SMS-authorization, where an SMS is sent to the registrant’s contact phone number with a request for the registrant response actions to complete authorization or it can be a call placed by the Registrar’s staff to the phone number provided by the registrant given.

(iii) E-mail verification
For instance, back-verification can be used, where the registrant must send a reply with certain content or receives an e-mail request sent by Registrar or where the registrant must use the given hyperlink to complete verification.

In accordance with ICANN WHOIS Data Reminder Policy, at least annually, a registrar must present to the registrant current WHOIS data, and remind the registrant that provision of false WHOIS data can form grounds for cancellation of his⁄her domain name registration. Registrants must review their WHOIS data, and make respective modifications therein.

ICANN Restored Names Accuracy Policy states that when a Registrar restores the name (from the redemption grace period) that had been deleted on the basis of submission of false contact data or because of failure to respond to Registrar’s inquiries, the name must be placed on the Registrar Hold status until the registrant has provided updated and accurate WHOIS data.

5.3. Encouragement of Registrars

The proposed Registry Operator plans to periodically conduct spot checks of registrant data collected by Registrars.

The Registry Operator may check the authenticity of registrants’ certificate or invitation and its expiry date, may contact registrants by sending registered postal letters to his⁄her postal addresses (with delivery confirmation), e-mail queries at contact e-mail addresses or by placing calls to his⁄her contact phone numbers and those of administrative and technical contacts in order to confirm the relevance of the earlier provided WHOIS data.

Reports containing the spot check findings will be forwarded to all the TLD Registrars. Based on the reports, those Registrars which have demonstrated a high level of authenticity and accuracy of registrant information will be awarded a possibility to take part in joint marketing campaigns with the Registry Operator.

Where the Registrar regularly exhibits a low level of accuracy of WHOIS data, the Registry Operator has the right to run a detailed examination of registration information with regard to domain names sponsored by that Registrar. By results of such an examination the Registry Operator is given time to remedy exposed abuses. Where the Registrar has failed to remedy the abuses within the specified time periods or where the Registrar has permanently abused the rules and policies, the decision may be made to suspend the effect of RRA as per terms and conditions set forth in RRA.

5.4. Other measures

In order to protect registrants and as well as to abide by Russian Federal Act FZ-152 ʺOn personal dataʺ, the Registry Operator does not disclose registrants personal data (including those of the administrative and technical contact) as well as e-mails and phone numbers in the publicly available WHOIS.

The Registry Operator obligates Registrars to ensure the possibility to contact the registrant without publication of his⁄her contact data in WHOIS (e-mail, phone number). This can be implemented, for instance, by means of publishing web-form that allows sending messages to the registrant. The Registry publishes in its WHOIS the hyperlink to the web-form on the Registrar website.

6. PREVENTION OF UNAUTHORIZED ACCESS TO DOMAIN FUNCTIONS

Prevention of unauthorized access to domain functions must be implemented only within the frame of relations between the Registrar sponsoring the domain and its registrant. The Registry Operator establishes certain obligations under RRA for their mandatory observance by Registrars as well as recommendations for Registrars which can be translated into the registration agreement.

In accordance with the RRA provisions, the Registrars are obligated to check for complexity the passwords registrants use to carry out critical operations with their domain names.

Besides, the Registry Operator obligates the Registrars to implement the following measures:
- The Registrar is bound to grant registrant the possibility to control the domain name via Web-interfaces using HTTPS protocol.
- The Registrar is bound to send notifications to registrant, administrative and technical contacts upon completion of any critical operation with the domain (update, renewal, transfer, deletion) as well as to include in those notifications information of where one should refer to in the event the operation was not authorized by the registrant.
- The Registrar is bound to establish mechanisms to check for resiliency and security passwords the registrant uses to access to domain critical functions and to warn the registrant and his⁄her contacts of responsibility to ensure secure storage of passwords.

The Registrar is recommended to have registrants use machine-generated passwords to ensure proper access to domain functions.

Where domains are transferred, the parties engaged therein are bound to comply with the ICANN requirements to Holder-Authorized Transfers as set forth in the Inter-Registrar Transfer Policy (http:⁄⁄www.icann.org⁄en⁄transfers⁄policy-en.htm).

7. CONCLUSION

The answer fully covers all issues of Evaluation Question #28. The Applicant describes the proposed policies and procedures to minimize abusive registrations and use of domain names as well as other activities that might have a negative impact on Internet users. The Applicant will implement and publish on its website a single abuse point of contact and establish the respective Abuse Complaint Processing Procedure. Measures for removal of orphan glue records are proposed. To promote accuracy of WHOIS, the Applicant will implement relevant measures including authentication of registrant information to be complete and accurate at the moment of registration, regular monitoring of registration data, employing most advanced authentication methods and establishing policies and procedures to address domain names with inaccurate or incomplete WHOIS data. The Applicant will ensure Registrars’ compliance with contractual requirements regarding WHOIS accuracy, including spot checks and financial encouragement of Registrars. Malicious or abusive behavior, including unambiguous definitions of the phenomena of abuse in the TLD and procedures that will allow an efficient mitigation of potential for abuse in the TLD are defined. The Applicant will establish special Service Level Requirements for abuse resolution, including service levels for responding to law enforcement agencies’ inquiries and requests. The Applicant will exercise adequate controls to ensure a proper access to domain critical functions.