ICANN New gTLD Application

The Hindi IDN gTLD will benefit registrants, Internet users, and others as described below in response sections 18b(i-v).

18b(i) The Hindi IDN gTLD’s area of specialty is in providing registrants a local language domain name for greater inclusiveness of Internet users. A goal of the Hindi IDN gTLD is to carry forward the reputation of .ORG as being trustworthy, well-intentioned, valuable information, and reliable. These are the top five brand attributes of .ORG, as indicated in PIR’s annual brand research conducted in 2008-2011. PIR will operate the IDN gTLD registry in the same exemplary manner as it does for .ORG in order to carry forward the environment conducive to such positive brand recognition.

18b(ii) The Hindi IDN gTLD will advance the goals of competition, differentiation and innovation in a number a ways. Creating a language-unique IDN gTLD for organizations will advance competition among TLDs that currently offer domain service to community organizations.

Community organizations use .ORG today, as well as a wide selection of TLDs, ccTLDs, sTLDs. A uniquely identifiable IDN gTLD for organizations will provide the same differentiation that organizations can achieve today with .ORG, but within their own language. This distinction also benefits Internet users who are searching for language specific organizations on the Internet.

18b(iii) With each IDN gTLD that is launched, the Internet takes a big step forward in becoming truly global. English might be a popular language in the world, but there are many people who donʹt use it, or who use other languages together with it. With IDNs, the Internet will reach many more people, who previously were either completely offline, or who used the Internet only in a limited way. The Hindi IDN gTLD will make the Internet more user-friendly for this language community. Internet users will now be able to write a domain name or an URL exactly the way it is supposed to be written - i.e. without substituting the special symbols in Latin-based languages, or without transcribing non-Latin languages into English.

PIR’s Abuse Prevention and Mitigation policies (summarized in response to Evaluation Question #18b(iv) and detailed in response to Evaluation Question #28) will strive to make this Hindi IDN gTLD a safer and more trustworthy environment for Internet users. The policies combat fraudulent activity and abusive practices prevalent in other top-level domains.

18b(iv) To achieve the above goals and assure that the Hindi IDN gTLD domain names are allocated in an appropriate manner, PIR has developed a set of IDN Registration Policies and corresponding compliance and enforcement mechanisms.
The policies are built to match the need of the IDN registrants, based on experience from the .ORG gTLD management since 2003; and to ensure a higher security level for domain names than what currently is considered standard global requirements for gTLDs today.
IDN Registration Policies
The registration policies in support of the goals are described in the following summary and are detailed later in this section.
• Registrant Eligibility Requirements – there are no eligibility restrictions for the IDN domain names, in order to serve a variety of community organizations and remain consistent with the unrestricted use of .ORG.
• Content and Use Restriction Policy – ensures that IDN domain names are not used for illegal or fraudulent purposes or activities.
• Compliance Functions – ensures ongoing compliance of the Abuse Prevention and Mitigation and the Content and Use Restriction Policy.
• Name Selection Policy – ensures that initially only Hindi IDN scripts for domain names are registered.
• Reserved Name Policy – names⁄types of domain names will initially be reserved from registration under the Hindi IDN.
• Registry Name Policy – names⁄types of domain names will be held from general availability, these will be used in support of the registry.

The following policies support the IDN goals and are detailed in subsequent Evaluation Questions of the application dedicated to such policies, as noted below.

• Abuse Prevention and Mitigation – includes the Anti-Abuse Policy which addresses the identification and prompt action taken on malicious use of domain names. Detailed descriptions of the policies can be found in response to Evaluation Question #28.
• Rights Protection Mechanisms – to protect intellectual property holders under the Trademark Clearinghouse, Uniform Dispute Resolution Policy (UDRP), Uniform Rapid Suspension (URS), Post-Delegation Dispute Resolution Policy (PDDRP), in addition to the Sunrise services and policies that can be found in response to Evaluation Question #29.

PIR will review all policies and processes on an annual basis with involvement from the PIR’s .ORG Advisory Council.

Specific Policy Details

Content and Use Restriction Policy: Abusive use of the IDN domain names will not be tolerated by PIR. The following use and content limitations apply:
• Any illegal or fraudulent usage of the IDN domain name is not allowed, including but not limited to phishing and pharming attacks, distribution of malware, and distribution of adult content.
• Registration and use of a domain name in violation of Rights Protection Mechanisms is not allowed.

Violations of any of the IDN Registration Policies may be grounds for loss of registration, pursuant to the enforcement mechanism discussed below.

Compliance Functions: While disputes will be managed directly by the dispute resolution providers, PIR will to conduct random compliance efforts across all the IDN Registration Policies. Periodically PIR will conduct through compliance staff a sample of IDN registrations to verify compliance with the name and use policy.

If a registrant is found to not be in compliance the registrant will be notified that the domain will be placed on registry lock and that if the issue is not cured the domain will be terminated.

As part of the compliance function PIR will also incorporate its existing expertise, obtained through its management of .ORG, to monitor and take action on any abusive behavior occurring on IDN domain names.

Name Selection Policy: At the time of launch, domain names (to the left of the dot) will be restricted to the same Devanagari script used to the right of the dot only. As market demands, additional scripts to the left of the dot will be considered for domain name registration.

Reserved Names Policy: The IDN domain name that a registrant wishes to register must fulfill certain name policy criteria. The following names⁄types of domain names will initially be reserved from registration under the Hindi IDN:
• All single- and two-character second-level domain names;
• Domains of an inappropriate nature, pursuant to a list defined by PIR and its .ORG Advisory Council;
• Names provided by ICANN as required reserved names;
• A list of generic names defined by PIR and its .ORG Advisory Council. Such names will be released in a specific RFP process.

Registry Name Policy: The following names⁄types of domain names will be held from general availability, these will be used in support of the registry.
• Names to support registry operations, e.g., registry.IDN

Compliance and Enforcement Mechanisms
PIR will take measures to enforce the policies of the IDN gTLD. These measures are addressed via our audit process (described below) and through our defined dispute resolution processes.

A violation of the IDN Registration Policies will be enforced on a case-by-case, fact specific basis, under the process set forth below:
1. Any alleged violation of the Rights Protection Mechanisms shall be enforced under the provisions contained in each of them.

Disputes resulting out of violations of the IDN Registration Policies will be resolved through the Compliance Functions and the Rights Protection Mechanisms. The Rights Protection Mechanisms (Trademark Clearinghouse, UDRP, PDDRP, and the Sunrise services and policies) will be made applicable by the ICANN-Accredited Registrarsʹ registration agreements with registrants. Proceedings under the Rights Protection Mechanisms will be conducted in accordance with the policies and procedures that will be included in an appendix to the Registry Agreement. As set forth in the Compliance Functions, registry operator will review on a random basis, monitor, and verify that any particular domain name is being used in compliance with the Rights Protection Mechanisms processes.

18b(v) PIR will manage the Hindi IDN gTLD in accordance with best practices and specific policies around privacy and data protection, as it does for nearly 10 million .ORG registrations today. Specific protections of the WHOIS administered by the registry backend service provider can be found in Evaluation Question #26, and details on our privacy policies in Evaluation Question #28.

Pursuant to its mission, PIR has been conducting outreach since its management of the .ORG domain began in 2003. Ongoing outreach and communications ensures that we meet the projected benefits as described and established in response to #18b(i-v). The Hindi IDN language community is large and global in reach. As such, coordinated efforts and international outreach and communication are necessary to drive awareness of the benefits of the IDN for language-unique identification, differentiation, and innovation.

Based on PIR’s long-term successful management of .ORG and its outreach, it will ensure the secure and stable operation as well as market adoption of the IDN gTLD.

Public Interest Registry (PIR) has been successfully managing .ORG, one of the internet’s original gTLDs, for over nine years. PIR uses Afilias Limited as the registry backend service provider who will also support this gTLD. Afilias has experience managing registrations for over a decade and supports comprehensive registration lifecycle services including the registration states, any modifications required with the introduction of any new ICANN policies, and addressing any potential security or stability concerns.

The below response includes a description of the registry services to be provided for this gTLD, additional services provided to support registry operations, and an overview of the approach.

1. Operations of the Registry
To support this gTLD, PIR and Afilias will offer the following registry services, all in accordance with relevant technical standards and policies:

a. Receipt of data from registrars concerning registration for domain names and nameservers, and provision to registrars of status information relating to the EPP-based domain services for registration, queries, updates, transfers, renewals, and other domain management functions. Please see our responses to Evaluation Questions #24, #25, and #27 for full details.

b. Operation of the registry DNS servers: The DNS system, run and managed by Afilias, is a massively provisioned infrastructure that utilizes among the most sophisticated DNS architecture, hardware, software and redundant design created. Afilias’ industry-leading system works in a seamless way to incorporate nameservers from any number of other secondary DNS service vendors. Please see our response to Evaluation Question #35 for full details.

c. Dissemination of TLD zone files: Afilias’ distinctive architecture allows for real-time updates and maximum stability for zone file generation, publication and dissemination. Please see our response to Evaluation Question #34 for full details.

d. Dissemination of contact or other information concerning domain registrations: A port 43 WHOIS service with basic and expanded search capabilities with requisite measures to prevent abuse. Please see our response to Evaluation Question #26 for full details.

e. Internationalized Domain Names (IDNs): Ability to support all protocol valid Unicode characters at every level of the gTLD, including alphabetic, ideographic and right-to-left scripts in conformance with the ICANN IDN Guidelines. Please see our response to Evaluation Question #44 for full details.

f. DNS Security Extensions (DNSSEC): A fully DNSSEC-enabled registry, with a stable and efficient means of signing and managing zones. This includes the ability to safeguard keys and manage keys completely. Please see our response to Evaluation Question #43 for full details.

Each service will meet or exceed the contract service level agreement. All registry services for this gTLD will be provided in a standards-compliant manner.

2. Support
Numerous supporting services and functions facilitate effective management of this gTLD. These support services include:

a. Customer support: 24x7 live phone and email support for customers to address any access, update or other issues they may encounter. This includes assisting the customer identification of the problem as well as solving it. Customers include registrars and the registry operator, but not registrants except in unusual circumstances. Customers have access to a web-based portal for a rapid and transparent view of the status of pending issues.

b. Financial services: billing and account reconciliation for all registry services according to pricing established in respective agreements.

c. Support necessary to address the consensus policies as adopted by ICANN including:

• Uniform Domain Name Dispute Resolution
• WHOIS Data Reminder
• Inter-Registrar Transfer Policy
• WHOIS Marketing Restriction Policy
• Restored Names Accuracy Policy
• Expired Domain Deletion Policy
• Registry Services Evaluation Policy
• AGP Limits Policy

3. Other Services
Reporting is an important component of supporting registry operations. Afilias will provide reporting to the registry operator and registrars, as well as financial reporting. Afilias provides an extensive suite of reports to the registry operator, including daily, weekly and monthly reports with data at the transaction level that enables PIR to track and reconcile at whatever level of detail preferred. Afilias provides the exact data required by ICANN in the required format to enable PIR to meet its technical reporting requirements to ICANN.

In addition, Afilias offers access to a data warehouse capability that will enable near-real-time data to be available 24x7. This can be arranged by informing the Afilias Account Manager regarding who should have access. Afilias’ data warehouse capability enables drill-down analytics all the way to the transaction level.

Reporting Available to Registrars
Afilias provides an extensive suite of reporting to registrars and has been doing so in an exemplary manner for more than ten years. Specifically, Afilias provides daily, weekly and monthly reports with detail at the transaction level to enable registrars to track and reconcile at whatever level of detail they prefer.

Reports are provided in standard formats, facilitating import for use by virtually any registrar analytical tool. Registrar reports are available for download via a secure administrative interface. A given registrar will only have access to their own reports. These include the following:
• Daily Reports: Transaction Report, Billable Transactions Report, and Transfer Reports;
• Weekly: Domain Status and Nameserver Report, Weekly Nameserver Report, Domains Hosted by Nameserver Weekly Report; and,
• Monthly: Billing Report and Monthly Expiring Domains Report.

Weekly registrar reports are maintained for each registrar for four weeks. Weekly reports older than four weeks will be archived for a period of six months, after which they will be deleted.

Financial Reporting
Registrar account balances are updated real-time when payments and withdrawals are posted to the registrarsʹ accounts. In addition, the registrar account balances are updated as and when they perform billable transactions at the registry level.

Afilias provides Deposit⁄Withdrawal Reports that are updated periodically to reflect payments received or credits and withdrawals posted to the registrar accounts.

The following reports are also available: a) Daily Billable Transaction Report, containing details of all the billable transactions performed by all the registrars in the Shared Registry System (SRS), b) daily email reports containing the number of domains in the registry and a summary of the number and types of billable transactions performed by the registrars, and c) registry operator versions of most registrar reports (for example, a daily Transfer Report that details all transfer activity between all of the registrars in the SRS).

There are no additional proposed registry services for the launch of this gTLD

4. Security and Stability
Afilias addresses security in every significant aspect – physical, data and network as well as process. Afilias’ approach to security permeates every aspect of the registry services provided. A dedicated security function exists within the company to continually identify existing and potential threats, and to put in place comprehensive mitigation plans for each identified threat. In addition, a rapid security response plan exists to respond comprehensively to unknown or unidentified threats. The specific threats and Afilias mitigation plans are defined in our response to Evaluation Question #30b; please see that response for complete information. In short, Afilias is committed to ensuring the confidentiality, integrity, and availability of all information.

PIR and Afilias will deliver a secure, stable and reliable registry service. This gTLD will utilize an existing, proven team and platform for registry services with:
• A stable and secure, state-of-the-art, EPP-based SRS with ample storage capacity, data security provisions and scalability that is proven with registrars who account for over 95% of all TLD domain name registration activity (over 375 registrars);
• A reliable, 100% available DNS service (zone file generation, publication and dissemination) tested to withstand severe DDoS attacks and dramatic growth in Internet use;
• A WHOIS service that is flexible and standards compliant, with search capabilities to address both registrar and end-user needs; includes consideration for evolving standards, such as RESTful, or draft-kucherawy-wierds;
• A registry platform that is both IPv6 and DNSSEC enabled;
• An experienced, respected team of professionals active in standards development of innovative services such as DNSSEC and IDN support;
• Methods to limit domain abuse, remove outdated and inaccurate data, and ensure the integrity of the SRS;
• Customer support and reporting capabilities to meet financial and administrative needs, e.g., 24x7 call center support, integration support, billing, and daily, weekly, and monthly reporting.

PIR with Afilias will support this gTLD in accordance with its specific policies and procedures leveraging a proven registry infrastructure that is fully operational, staffed with professionals, massively provisioned, and immediately ready to launch and maintain this gTLD.

About PIR’s Support
Public Interest Registry (PIR), the official manager of .ORG, employs a team of professionals in operations, legal, marketing, and finance who manage the planning activities and oversight of Afiliasʹ technical operations activities.

PIR’s express purpose is supporting and promoting the evolution and growth of the Internet as a global research and communications infrastructure, educating non-commercial, and the nonprofit community about how to more effectively and more efficiently utilize the Internet to accomplish their important missions. PIR’s primary activity is to maintain an exemplary gTLD registry service, including advocating for higher standards of Internet security, safety and reliability.

In its relationship with the Internet Society (reference Evaluation Questions #9a and #9b), PIR is committed to supporting the goals of encouraging the evolution of the Internet as research, education and communication infrastructure equally accessible to the global non-commercial, and nonprofit community. PIR’s activities also include funding educational programs focused on expanding the knowledge and ability of non-commercial, and nonprofit organizations located in technologically deprived areas of the world to more efficiently and effectively use the Internet as a tool to better accomplish their important mission.

About Afilias’ Approach to Registry Support
Afilias, the backend registry service provider for this gTLD, is dedicated to managing the technical operations and support of this gTLD in a secure, stable and reliable manner. Afilias has worked closely with the Public Interest Registry (PIR) to review specific needs and objectives of this gTLD. The resulting comprehensive plans are illustrated in technical responses to Evaluation Questions #24-44, drafted by Afilias given PIR’s requirements. Afilias and PIR also worked together to provide financial responses for this application which demonstrate cost and technology consistent with the size and objectives of this gTLD.

Afilias is the registry services provider for this and several other gTLD applications. Over the past 11 years of providing services for gTLDs and ccTLDs, Afilias has accumulated experience about resourcing levels necessary to provide high quality services with conformance to strict service requirements. Afilias currently supports over 20 million domain names, spread across 16 TLDs, with over 400 accredited registrars.

Since its founding, Afilias has focused on delivering secure, stable and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and ongoing maintenance of this gTLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the Afilias project management methodology allows efficient and effective use of its staff in a focused way.

With over a decade of registry experience, Afilias has the depth and breadth of experience to ensure existing and new needs are addressed, all while meeting or exceeding service level requirements and customer expectations. This is evident in Afilias’ participation in business, policy and technical organizations supporting registry and Internet technology within ICANN and related organizations. This allows Afilias to be at the forefront of security initiatives such as: DNSSEC, where Afilias worked with PIR to make the .ORG registry the first DNSSEC enabled gTLD and the largest TLD enabled at the time; in enhancing the Internet experience for users across the globe by leading development of IDNs; in pioneering the use of open-source technologies by its usage of PostgreSQL; and, in being the first to offer near-real-time dissemination of DNS zone data.

The ability to observe tightening resources for critical functions and the capacity to add extra resources ahead of a threshold event are factors that Afilias is well versed in. Afilias’ human resources team, along with well-established relationships with external organizations, enables it to fill both long-term and short-term resource needs expediently.

Afilias’ growth from managing a few domains to serving 20 million domain names across 16 TLDs and 400 accredited registrars indicates that the relationship between the number of people required, and the volume of domains supported is not linear. In other words, servicing 100 TLDs does not automatically require 6 times more staff than servicing 16 TLDs. Similarly, an increase in the number of Domains Under Management (DUMs) does not require a linear increase in resources. Afilias carefully tracks the relationship between resources deployed and domains to be serviced, and proactively reviews this metric in order to retain a safe margin of error. This enables Afilias to add, train and prepare new staff well in advance of the need, allowing consistent delivery of high quality services.

THE RESPONSE FOR THIS QUESTION INCLUDES ANGLE BRACKETS (THE “〈” and “〉” CHARACTERS, or &lt; and &gt;), WHICH ICANN STATED IN CASE ID 11027, CANNOT BE PROPERLY RENDERED IN TAS DUE TO SECURITY CONCERNS. HENCE, THE ANSWER BELOW AS DISPLAYED IN TAS MAY NOT RENDER THE FULL RESPONSE AS INTENDED. THEREFORE, THE FULL ANSWER TO THIS QUESTION IS ALSO ATTACHED AS A PDF FILE, ACCORDING TO SPECIFIC GUIDANCE FROM ICANN UNDER CASE ID 11027.

Public Interest Registry (PIR) has been successfully managing .ORG, one of the internet’s original gTLDs, for over nine years. PIR uses Afilias Limited as the registry backend service provider who will also support this gTLD. Afilias has experience managing registrations for over a decade and supports comprehensive registration lifecycle services including the registration states, any modifications required with the introduction of any new ICANN policies, and the operation of a robust Shared Registration System (SRS).

Afilias operates a state-of-the-art EPP-based SRS that is secure, stable and reliable. The SRS is a critical component of registry operations that must balance the business requirements for the registry and its customers, such as numerous domain acquisition and management functions. The SRS meets or exceeds all ICANN requirements given that Afilias:
• Operates a secure, stable and reliable SRS which updates in real-time and in full compliance with Specification 6 of the new gTLD Registry Agreement;
• Is committed to continuously enhancing our SRS to meet existing and future needs;
• Currently exceeds contractual requirements and will perform in compliance with Specification 10 of the new gTLD Registry Agreement;
• Provides SRS functionality and staff, financial, and other resources to more than adequately meet the technical needs of this gTLD; and,
• Manages the SRS with a team of experienced technical professionals who can seamlessly integrate this g TLD into the Afilias registry platform and support the gTLD in a secure, stable and reliable manner.

Description of Operation of the SRS, Including Diagrams
Afilias’ SRS provides the same advanced functionality as that used in the .ORG registry, as well as the fifteen other TLDs currently supported by Afilias. The Afilias registry system is standards-compliant and utilizes proven technology, ensuring global familiarity for registrars, and it is protected by our massively provisioned infrastructure that mitigates the risk of disaster.

An abbreviated list of Afilias SRS functionality includes the list below. EPP functionality is described fully in our response to Evaluation Question #25.
• Domain registration: provides registration of names in the gTLD, in both ASCII and IDN forms, to accredited registrars via EPP and a web-based administration tool.
• Domain renewal: provides services that allow registrars the ability to renew domains under sponsorship at any time. Further, the registry performs the automated renewal of all domain names at the expiration of their term, and allows registrars to rescind automatic renewals within a specified number of days after the transaction for a full refund.
• Transfer: provides efficient and automated procedures to facilitate the transfer of sponsorship of a domain name between accredited registrars. Further, the registry enables bulk transfers of domains under the provisions of the Registry-Registrar Agreement.
• RGP and restoring deleted domain registrations: provides support for the Redemption Grace Period (RGP) as needed, enabling the restoration of deleted registrations.
• Other grace periods and conformance with ICANN guidelines: provides support for other grace periods that are evolving as standard practice inside the ICANN community. In addition, the Afilias registry backend services system supports the evolving ICANN guidelines on IDNs.

Afilias also supports the basic check, delete, and modify commands.

As required for all new gTLDs, “thick” registry system functionality is provided. In this model, all key contact details for each domain are stored in the registry. This allows better access to domain data and provides uniformity in storing the information.

Afilias’ SRS complies today and will continue to comply with global best practices including relevant RFCs, ICANN requirements, and the gTLD’s respective domain policies. With over a decade of experience, Afilias has fully documented and tested policies and procedures, and our highly skilled team members are active participants in the major relevant technology and standards organizations, so ICANN can be assured that SRS performance and compliance are met. Full details regarding the SRS system and network architecture are provided in responses to Evaluation Questions #31 and #32.

SRS Servers and Software
All applications and databases for the gTLD will run in a virtual environment currently hosted by a cluster of servers equipped with the latest Intel Westmere multi-core processors. (It is possible that by the time this application is evaluated and systems deployed, Westmere processors may no longer be the “latest”; the Afilias policy is to use the most advanced, stable technology available at the time of deployment.) The data for the registry will be stored on storage arrays of solid state drives shared over a fast storage area network. The virtual environment allows the infrastructure to easily scale both vertically and horizontally to cater to changing demand. It also facilitates effective utilization of system resources, thus reducing energy consumption and carbon footprint.

The network firewalls, routers and switches support all applications and servers. Hardware traffic shapers are used to enforce an equitable access policy for connections coming from registrars. The registry system accommodates both IPv4 and IPv6 addresses. Hardware load balancers accelerate TLS⁄SSL handshaking and distribute load among a pool of application servers.

Each of the servers and network devices are equipped with redundant, hot-swappable components and multiple connections to ancillary systems. Additionally, 24x7 support agreements with a four-hour response time at all our data centers guarantee replacement of failed parts in the shortest time possible.

Examples of current system and network devices used are:
• Servers: Cisco UCS B230 blade servers
• SAN storage arrays: IBM Storwize V7000 with Solid State Drives
• SAN switches: Brocade 5100
• Firewalls: Cisco ASA 5585-X
• Load balancers: F5 Big-IP 6900
• Traffic shapers: Procera PacketLogic PL8720
• Routers: Juniper MX40 3D
• Network switches: Cisco Nexus 7010, Nexus 5548, Nexus 2232

These system components are upgraded and updated as required, and have usage and performance thresholds which trigger upgrade review points. In each data center, there is a minimum of two of each network component, a minimum of 25 servers, and a minimum of two storage arrays.

Technical components of the SRS include the following items, continually checked and upgraded as needed: SRS, WHOIS, web admin tool, DNS, DNS distributor, reporting, invoicing tools, and deferred revenue system (as needed).

All hardware is massively provisioned to ensure stability under all forecast volumes from launch through “normal” operations of average daily and peak capacities. Each and every system application, server, storage and network device is continuously monitored by the Afilias Network Operations Center for performance and availability. The data gathered is used by dynamic predictive analysis tools in real-time to raise alerts for unusual resource demands. Should any volumes exceed established thresholds, a capacity planning review is instituted that will address the need for additions well in advance of their actual need.

SRS Diagram and Interconnectivity Description
As with all core registry services, the SRS is run from a global cluster of registry system data centers, located in geographic centers with high Internet bandwidth, power, redundancy and availability. All of the registry systems will be run in a 〈n+1〉 setup, with a primary data center and a secondary data center. For detailed site information, please see our responses to Evaluation Questions #32 and #35. Registrars access the SRS in real-time using EPP.

A sample of the Afilias SRS technical and operational capabilities (displayed in figure 24-a) include:
• Geographically diverse redundant registry systems;
• Load balancing implemented for all registry services (e.g. EPP, WHOIS, web admin) ensuring equal experience for all customers and easy horizontal scalability;
• Disaster Recovery Point objective for the registry is within one minute of the loss of the primary system;
• Detailed and tested contingency plan, in case of primary site failure; and,
• Daily reports, with secure access for confidentiality protection.

As evidenced in figure 24-a, the SRS contains several components of the registry system. The interconnectivity ensures near-real-time distribution of the data throughout the registry infrastructure, timely backups, and up-to-date billing information.

The WHOIS servers are directly connected to the registry database and provide real-time responses to queries using the most up-to-date information present in the registry.

Committed DNS-related EPP objects in the database are made available to the DNS Distributor via a dedicated set of connections. The DNS Distributor extracts committed DNS-related EPP objects in real-time and immediately inserts them into the zone for dissemination.

The Afilias system is architected such that read-only database connections are executed on database replicas and connections to the database master (where write-access is executed) are carefully protected to ensure high availability.

This interconnectivity is monitored, as is the entire registry system, according to the plans detailed in our response to Evaluation Question #42.

Synchronization Scheme
Registry databases are synchronized both within the same data center and in the backup data center using a database application called Slony. For further details, please see the responses to Evaluation Questions #33 and #37. Slony replication of transactions from the publisher (master) database to its subscribers (replicas) works continuously to ensure the publisher and its subscribers remain synchronized. When the publisher database completes a transaction the Slony replication system ensures that each replica also processes the transaction. When there are no transactions to process, Slony “sleeps” until a transaction arrives or for one minute, whichever comes first. Slony “wakes up” each minute to confirm with the publisher that there has not been a transaction and thus ensures subscribers are synchronized and the replication time lag is minimized. The typical replication time lag between the publisher and subscribers depends on the topology of the replication cluster, specifically the location of the subscribers relative to the publisher. Subscribers located in the same data center as the publisher are typically updated within a couple of seconds, and subscribers located in a secondary data center are typically updated in less than ten seconds. This ensures real-time or near-real-time synchronization between all databases, and in the case where the secondary data center needs to be activated, it can be done with minimal disruption to registrars.

SRS SLA Performance Compliance
Afilias has a ten-year record of delivering on the demanding ICANN SLAs, and will continue to provide secure, stable and reliable service in compliance with SLA requirements as specified in the new gTLD Registry Agreement, Specification 10, as presented in figure 24-b.

The Afilias SRS currently handles over 200 million EPP transactions per month for just .INFO and .ORG. Overall the Afilias SRS manages over 700 million EPP transactions per month for all TLDs under management.

Given this robust functionality, and more than a decade of experience supporting a thick gTLD registry with a strong performance history, Afilias, on behalf of PIR, will meet or exceed the performance metrics in Specification 10 of the new gTLD Registry Agreement. The Afilias services and infrastructure are designed to scale both vertically and horizontally without any downtime to provide consistent performance as this gTLD grows. The Afilias architecture is also massively provisioned to meet seasonal demands and marketing campaigns. Afilias’ experience also gives high confidence in the ability to scale and grow registry operations for the gTLD in a secure, stable and reliable manner.

SRS Resourcing Plans
Since its founding, Afilias has focused on delivering secure, stable and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and ongoing maintenance of this gTLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the Afilias project management methodology allows efficient and effective use of its staff in a focused way.

Over 100 Afilias team members contribute to the management of the SRS code and network that will support this gTLD. The SRS team is composed of Software Engineers, Quality Assurance Analysts, Application Administrators, System Administrators, Storage Administrators, Network Administrators, Database Administrators, and Security Analysts located at three geographically separate Afilias facilities. The systems and services set up and administered by these team members are monitored 24x7 by skilled analysts at two NOCs located in Toronto, Ontario (Canada) and Horsham, Pennsylvania (USA). In addition to these team members, Afilias also utilizes trained project management staff to maintain various calendars, work breakdown schedules, utilization and resource schedules and other tools to support the technical and management staff. It is this team who will both deploy this gTLD on the Afilias infrastructure, and maintain it. Together, the Afilias team has managed 11 registry transitions and six new TLD launches, which illustrate its ability to securely and reliably deliver regularly scheduled updates as well as a secure, stable and reliable SRS service for this gTLD.

Public Interest Registry (PIR) has been successfully managing .ORG, one of the internet’s original gTLDs, for over nine years. PIR uses Afilias Limited as the registry backend service provider who will also support this gTLD. Afilias has experience managing registrations for over a decade and supports comprehensive registration lifecycle services including the registration states, any modifications required with the introduction of any new ICANN policies, and the operation of a state-of-the art Extensible Provisioning Protocol (EPP) Shared Registration System (SRS).

Afilias has been a pioneer and innovator in the use of EPP. .INFO was the first EPP-based gTLD registry and launched on EPP version 02⁄00. Afilias has a track record of supporting TLDs on standards-compliant versions of EPP. Afilias will operate the EPP registrar interface as well as a web-based interface for this gTLD in accordance with RFCs and global best practices. In addition, Afilias will maintain a proper OT&E (Operational Testing and Evaluation) environment to facilitate registrar system development and testing.

Afilias’ EPP technical performance meets or exceeds all ICANN requirements as demonstrated by:
• A completely functional, state-of-the-art, EPP-based SRS that currently meets the needs of various TLDs and will meet this gTLD’s needs;
• A track record of success in developing extensions to meet client and registrar business requirements such as multi-script support for IDNs;
• Supporting six ICANN TLDs on EPP: .INFO, .ORG, .MOBI, .AERO, .ASIA and .XXX
• EPP software that is operating today and has been fully tested to be standards-compliant;
• Proven interoperability of existing EPP software with ICANN-accredited registrars; and,
• An SRS that currently processes over 200 million EPP transactions per month for both .INFO and .ORG. Overall, Afilias processes over 700 million EPP transactions per month for all 16 TLDs under management.

The EPP service is offered in accordance with the performance specifications defined in the new gTLD Registry Agreement, Specification 10.

EPP Standards
The Afilias registry system complies with the following revised versions of the RFCs and operates multiple ICANN TLDs on these standards, including .INFO, .ORG, .MOBI, .ASIA and .XXX. The systems have been tested by our Quality Assurance (QA) team for RFC compliance, and have been used by registrars for an extended period of time:
• 3735 - Guidelines for Extending EPP
• 3915 - Domain Registry Grace Period Mapping
• 5730 - Extensible Provisioning Protocol (EPP)
• 5731 - Domain Name Mapping
• 5732 - Host Mapping
• 5733 - Contact Mapping
• 5734 - Transport Over TCP
• 5910 - Domain Name System (DNS) Security Extensions Mapping for the Extensible Provisioning Protocol (EPP)

This gTLD will support all valid EPP commands. The EPP commands discussed below are in operation today and will be made available for this gTLD. See attachment #25-a for the base set of EPP commands and copies of Afilias XSD schema files, which define all the rules of valid, RFC compliant EPP commands and responses that Afilias supports. Any customized EPP extensions, if necessary, will also conform to relevant RFCs.

Afilias staff members actively participated in the Internet Engineering Task Force (IETF) process that finalized the new standards for EPP. Afilias will continue to actively participate in the IETF and will stay abreast of any updates to the EPP standards.

EPP Software Interface and Functionality
Afilias will provide all registrars with a free open-source EPP toolkit. Afilias provides this software for use with both Microsoft Windows and Unix⁄Linux operating systems. This software, which includes all relevant templates and schema defined in the RFCs, is available on sourceforge.net and will be available through the registry operator’s website.

Afilias’ SRS EPP software complies with all relevant RFCs and includes the following functionality:
• EPP Greeting: A response to a successful connection returns a greeting to the client. Information exchanged can include: name of server, server date and time in UTC, server features, e.g., protocol versions supported, languages for the text response supported, and one or more elements which identify the objects that the server is capable of managing;
• Session management controls: 〈login〉 to establish a connection with a server, and 〈logout〉 to end a session;
• EPP Objects: Domain, Host and Contact for respective mapping functions;
• EPP Object Query Commands: Info, Check, and Transfer (query) commands to retrieve object information; and,
• EPP Object Transform Commands: five commands to transform objects: 〈create〉 to create an instance of an object, 〈delete〉 to remove an instance of an object, 〈renew〉 to extend the validity period of an object, 〈update〉 to change information associated with an object, and 〈transfer〉 to manage changes in client sponsorship of a known object.

Currently, 100% of the top domain name registrars in the world have software that has already been tested and certified to be compatible with the Afilias SRS registry. In total, over 375 registrars, representing over 95% of all registration volume worldwide, operate software that has been certified compatible with the Afilias SRS registry. Afilias’ EPP Registrar Acceptance Criteria are available in attachment #25-b, EPP OT&E Criteria.

Free EPP Software Support
Afilias analyzes and diagnoses registrar EPP activity log files as needed and is available to assist registrars who may require technical guidance regarding how to fix repetitive errors or exceptions caused by misconfigured client software.

Registrars are responsible for acquiring a TLS⁄SSL certificate from an approved certificate authority, as the registry-registrar communication channel requires mutual authentication; Afilias will acquire and maintain the server-side TLS⁄SSL certificate. The registrar is responsible for developing support for TLS⁄SSL in their client application. Afilias will provide free guidance for registrars unfamiliar with this requirement.

Registrar Data Synchronization
There are two methods available for registrars to synchronize their data with the registry:
• Automated synchronization: Registrars can, at any time, use the EPP 〈info〉 command to obtain definitive data from the registry for a known object, including domains, hosts (nameservers) and contacts.
• Personalized synchronization: A registrar may contact technical support and request a data file containing all domains (and associated host (nameserver) and contact information) registered by that registrar, within a specified time interval. The data will be formatted as a comma separated values (CSV) file and made available for download using a secure server.

EPP Modifications
There are no unique EPP modifications planned for this gTLD.

All ICANN TLDs must offer a Sunrise as part of a rights protection program. Afilias uses EPP extensions that allow registrars to submit trademark and other Intellectual Property Rights (IPR) data to the registry. These extensions are:
• An 〈ipr:name〉 element that indicates the name of Registered Mark.
• An 〈ipr:number〉 element that indicates the registration number of the IPR.
• An 〈ipr:ccLocality〉 element that indicates the origin for which the IPR is established (a national or international trademark registry).
• An 〈ipr:entitlement〉 element that indicates whether the applicant holds the trademark as the original “OWNER”, “CO-OWNER”, “LICENSEE”, or “ASSIGNEE”.
• An 〈ipr:appDate〉 element that indicates the date the Registered Mark was applied for.
• An 〈ipr:regDate〉 element that indicates the date the Registered Mark was issued and registered.
• An 〈ipr:class〉 element that indicates the class of the registered mark.
• An 〈ipr:type〉 element that indicates the Sunrise phase the application applies for.

Note that some of these extensions might be subject to change based on ICANN-developed requirements for the Trademark Clearinghouse.

EPP Resourcing Plans
Since its founding, Afilias has focused on delivering secure, stable and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and ongoing maintenance of this gTLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the Afilias project management methodology allows efficient and effective use of its staff in a focused way.

108 Afilias team members directly contribute to the management and development of the EPP based registry systems. As previously noted Afilias is an active member of IETF and has a long documented history developing and enhancing EPP. These contributors include 11 developers and 14 QA engineers focused on maintaining and enhancing EPP server side software. These engineers work directly with business staff to timely address existing needs and forecast registry⁄registrar needs to ensure the Afilias EPP software is effective today and into the future. A team of eight data analysts work with the EPP software system to ensure that the data flowing through EPP is securely and reliably stored in replicated database systems. In addition to the EPP developers, QA engineers, and data analysts, other EPP contributors at Afilias include: Technical Analysts, the Network Operations Center and Data Services team members.

Public Interest Registry (PIR) has been successfully managing .ORG, one of the internet’s original gTLDs, for over nine years. PIR uses Afilias Limited as the registry backend service provider who will also support this gTLD. Afilias has had experience managing registrations for over a decade and supports comprehensive registration lifecycle services including the registration states, all standard grace periods, can address any modifications required with the introduction of any new ICANN policies, and the operation of the registry WHOIS service.

Afilias operates the WHOIS (registration data directory service) infrastructure in accordance with RFCs and global best practices, as it does for the 16 TLDs it currently supports. Designed to be robust and scalable, Afilias’ WHOIS service has exceeded all contractual requirements for over a decade. It has extended search capabilities, and methods of limiting abuse.

The WHOIS service operated by Afilias meets and exceeds ICANN’s requirements. Specifically, Afilias will:
• Offer a WHOIS service made available on port 43 that is flexible and standards- compliant;
• Comply with all ICANN policies, and meeting or exceeding WHOIS performance requirements in Specification 10 of the new gTLD Registry Agreement;
• Enable a Searchable WHOIS with extensive search capabilities that offers ease of use while enforcing measures to mitigate access abuse; and,
• Employ a team with significant experience managing a compliant WHOIS service.

Such extensive knowledge and experience managing a WHOIS service enables Afilias to offer a comprehensive plan for this gTLD that meets the needs of constituents of the domain name industry and Internet users. The service has been tested by our Quality Assurance (QA) team for RFC compliance, and has been used by registrars and many other parties for an extended period of time. Afilias’ WHOIS service currently serves almost 500 million WHOIS queries per month, with the capacity already built in to handle an order of magnitude increase in WHOIS queries, and the ability to smoothly scale should greater growth be needed.

WHOIS System Description and Diagram
The Afilias WHOIS system, depicted in figure 26-a, is designed with robustness, availability, compliance, and performance in mind. Additionally, the system has provisions for detecting abusive usage (e.g., excessive numbers of queries from one source). The WHOIS system is generally intended as a publicly available single object lookup system. Afilias uses an advanced, persistent caching system to ensure extremely fast query response times.

Afilias will develop restricted WHOIS functions based on specific domain policy and regulatory requirements as needed for operating the business (as long as they are standards compliant). It will also be possible for contact and registrant information to be returned according to regulatory requirements. The WHOIS database supports multiple string and field searching through a reliable, free, secure web-based interface.

Data Objects, Interfaces, Access and Lookups
Registrars can provide an input form on their public websites through which a visitor is able to perform WHOIS queries. The registry operator can also provide a Web-based search on its site. The input form must accept the string to query, along with the necessary input elements to select the object type and interpretation controls. This input form sends its data to the Afilias port 43 WHOIS server. The results from the WHOIS query are returned by the server and displayed in the visitor’s Web browser. The sole purpose of the Web interface is to provide a user-friendly interface for WHOIS queries.

Afilias will provide WHOIS output as per Specification 4 of the new gTLD Registry Agreement. The output for domain records generally consists of the following elements:
• The name of the domain registered and the sponsoring registrar;
• The names of the primary and secondary nameserver(s) for the registered domain name;
• The creation date, registration status and expiration date of the registration;
• The name, postal address, email address, and telephone and fax numbers of the domain name holder;
• The name, postal address, email address, and telephone and fax numbers of the technical contact for the domain name holder;
• The name, postal address, email address, and telephone and fax numbers of the administrative contact for the domain name holder; and,
• The name, postal address, email address, and telephone and fax numbers of the billing contact for the domain name holder.

The following additional features are also present in Afilias’ WHOIS service:
• Support for IDNs, including the language tag and the Punycode representation of the IDN in addition to Unicode Hex and Unicode HTML formats;
• Enhanced support for privacy protection relative to the display of confidential information.

Afilias will also provide sophisticated WHOIS search functionality that includes the ability to conduct multiple string and field searches.

Query Controls
For all WHOIS queries, a user is required to enter the character string representing the information for which they want to search. The object type and interpretation control parameters to limit the search may also be specified. If object type or interpretation control parameter is not specified, WHOIS will search for the character string in the Name field of the Domain object.

WHOIS queries are required to be either an ʺexact searchʺ or a ʺpartial search,ʺ both of which are insensitive to the case of the input string.

An exact search specifies the full string to search for in the database field. An exact match between the input string and the field value is required.

A partial search specifies the start of the string to search for in the database field. Every record with a search field that starts with the input string is considered a match. By default, if multiple matches are found for a query, then a summary containing up to 50 matching results is presented. A second query is required to retrieve the specific details of one of the matching records.

If only a single match is found, then full details will be provided. Full detail consists of the data in the matching object as well as the data in any associated objects. For example: a query that results in a domain object includes the data from the associated host and contact objects.

WHOIS query controls fall into two categories: those that specify the type of field, and those that modify the interpretation of the input or determine the level of output to provide. Each is described below.

The following keywords restrict a search to a specific object type:
• Domain: Searches only domain objects. The input string is searched in the Name field.
• Host: Searches only nameserver objects. The input string is searched in the Name field and the IP Address field.
• Contact: Searches only contact objects. The input string is searched in the ID field.
• Registrar: Searches only registrar objects. The input string is searched in the Name field.

By default, if no object type control is specified, then the Name field of the Domain object is searched.

In addition, Afilias WHOIS systems can perform and respond to WHOIS searches by registrant name, postal address and contact names. Deployment of these features is provided as an option to the registry operator, based upon registry policy and business decision making.

Figure 26-b presents the keywords that modify the interpretation of the input or determine the level of output to provide.

By default, if no interpretation control keywords are used, the output will include full details if a single match is found and a summary if multiple matches are found.

Unique TLD Requirements
There are no unique WHOIS requirements for this gTLD.

Sunrise WHOIS Processes
All ICANN TLDs must offer a Sunrise as part of a rights protection program. Afilias uses EPP extensions that allow registrars to submit trademark and other intellectual property rights (IPR) data to the registry. The following corresponding data will be displayed in WHOIS for relevant domains:
• Trademark Name: element that indicates the name of the Registered Mark.
• Trademark Number: element that indicates the registration number of the IPR.
• Trademark Locality: element that indicates the origin for which the IPR is established (a national or international trademark registry).
• Trademark Entitlement: element that indicates whether the applicant holds the trademark as the original “OWNER”, “CO-OWNER”, “LICENSEE”, or “ASSIGNEE”.
• Trademark Application Date: element that indicates the date the Registered Mark was applied for.
• Trademark Registration Date: element that indicates the date the Registered Mark was issued and registered.
• Trademark Class: element that indicates the class of the Registered Mark.
• IPR Type: element that indicates the Sunrise phase the application applies for.

IT and Infrastructure Resources
All the applications and databases for this gTLD will run in a virtual environment hosted by a cluster of servers equipped with the latest Intel Westmere multi-core processors (or a more advanced, stable technology available at the time of deployment). The registry data will be stored on storage arrays of solid-state drives shared over a fast storage area network. The virtual environment allows the infrastructure to easily scale both vertically and horizontally to cater to changing demand. It also facilitates effective utilization of system resources thus reducing energy consumption and carbon footprint.

The applications and servers are supported by network firewalls, routers and switches.
The WHOIS system accommodates both IPv4 and IPv6 addresses.

Each of the servers and network devices are equipped with redundant hot-swappable components and multiple connections to ancillary systems. Additionally, 24x7 support agreements with our hardware vendor with a 4-hour response time at all our data centers guarantees replacement of failed parts in the shortest time possible.

Models of system and network devices used are:
• Servers: Cisco UCS B230 blade servers
• SAN storage arrays: IBM Storwize V7000 with Solid State Drives
• Firewalls: Cisco ASA 5585-X
• Load balancers: F5 Big-IP 6900
• Traffic shapers: Procera PacketLogic PL8720
• Routers: Juniper MX40 3D
• Network switches: Cisco Nexus 7010, Nexus 5548, Nexus 2232

There will be at least four virtual machines (VMs) offering WHOIS service. Each VM will run at least two WHOIS server instances - one for registrars and one for the public. All instances of the WHOIS service is made available to registrars and the public are rate limited to mitigate abusive behavior.

Frequency of Synchronization Between Servers
Registration data records from the EPP publisher database will be replicated to the WHOIS system database on a near-real-time basis whenever an update occurs.

Specifications 4 and 10 Compliance
The WHOIS service for this gTLD will meet or exceed the performance requirements in the new gTLD Registry Agreement, Specification 10. Figure 26-c provides the exact measurements and commitments. Afilias has a 10 year track record of exceeding WHOIS performance and a skilled team to ensure this continues for all TLDs under management.

The WHOIS service for this gTLD will meet or exceed the requirements in the new gTLD Registry Agreement, Specification 4.

RFC 3912 Compliance
Afilias will operate the WHOIS infrastructure in compliance with RFCs and global best practices, as it does with the 16 TLDs Afilias currently supports.

Afilias maintains a registry-level centralized WHOIS database that contains information for every registered domain and for all host and contact objects. The WHOIS service will be available on the Internet standard WHOIS port (port 43) in compliance with RFC 3912. The WHOIS service contains data submitted by registrars during the registration process. Changes made to the data by a registrant are submitted to Afilias by the registrar and are reflected in the WHOIS database and service in near-real-time, by the instance running at the primary data center, and in under ten seconds by the instance running at the secondary data center, thus providing all interested parties with up-to-date information for every domain. This service is compliant with the new gTLD Registry Agreement, Specification 4.

The WHOIS service maintained by Afilias will be authoritative and complete, as this will be a “thick” registry (detailed domain contact WHOIS is all held at the registry); users do not have to query different registrars for WHOIS information, as there is one central WHOIS system. Additionally, visibility of different types of data is configurable to meet the registry operator’s needs.

Searchable WHOIS
Afilias offers a searchable WHOIS on a web-based Directory Service. Partial match capabilities are offered on the following fields: domain name, registrar ID, and IP address. In addition, Afilias WHOIS systems can perform and respond to WHOIS searches by registrant name, postal address and contact names.

Providing the ability to search important and high-value fields such as registrant name, address and contact names increases the probability of abusive behavior. An abusive user could script a set of queries to the WHOIS service and access contact data in order to create or sell a list of names and addresses of registrants with this gTLD. Making the WHOIS machine readable, while preventing harvesting and mining of WHOIS data, is a key requirement integrated into the Afilias WHOIS systems. For instance, Afilias limits search returns to 50 records at a time. If bulk queries were ever necessary (e.g., to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process), Afilias makes such query responses available to carefully screened and limited staff members at the registry operator (and customer support staff) via an internal data warehouse. The Afilias WHOIS system accommodates anonymous access as well as pre-identified and profile-defined uses, with full audit and log capabilities.

The WHOIS service has the ability to tag query responses with labels such as “Do not redistribute” or “Special access granted”. This may allow for tiered response and reply scenarios. Further, the WHOIS service is configurable in parameters and fields returned, which allow for flexibility in compliance with various jurisdictions, regulations or laws.

Afilias offers exact-match capabilities on the following fields: registrar ID, nameserver name, and nameserver’s IP address (only applies to IP addresses stored by the registry, i.e., glue records). Search capabilities are fully available, and results include domain names matching the search criteria (including IDN variants). Afilias manages abuse prevention through rate limiting and CAPTCHA (described below). Queries do not require specialized transformations of internationalized domain names or internationalized data fields.

Please see “Query Controls” above for details about search options and capabilities.

Deterring WHOIS Abuse
Afilias has adopted two best practices to prevent abuse of the WHOIS service: rate limiting and CAPTCHA.

Abuse of WHOIS services on port 43 and via the Web is subject to an automated rate-limiting system. This ensures that uniformity of service to users is unaffected by a few parties whose activities abuse or otherwise might threaten to overload the WHOIS system.

Abuse of web-based public WHOIS services is subject to the use of CAPTCHA (Completely Automated Public Turing test to tell Computers and Humans Apart) technology. The use of CAPTCHA ensures that uniformity of service to users is unaffected by a few parties whose activities abuse or otherwise might threaten to overload the WHOIS system. The registry operator will adopt a CAPTCHA on its Web-based WHOIS.

Data mining of any sort on the WHOIS system is strictly prohibited, and this prohibition is published in WHOIS output and in terms of service.

For rate limiting on IPv4, there are configurable limits per IP and subnet. For IPv6, the traditional limitations do not apply. Whenever a unique IPv6 IP address exceeds the limit of WHOIS queries per minute, the same rate-limit for the given 64 bits of network prefix that the offending IPv6 IP address falls into will be applied. At the same time, a timer will start and rate-limit validation logic will identify if there are any other IPv6 address within the original 80-bit(⁄48) prefix. If another offending IPv6 address does fall into the ⁄48 prefix then rate-limit validation logic will penalize any other IPv6 addresses that fall into that given 80-bit (⁄48) network. As a security precaution, Afilias will not disclose these limits.

Pre-identified and profile-driven role access allows greater granularity and configurability in both access to the WHOIS service, and in volume⁄frequency of responses returned for queries.

Afilias staff are key participants in the ICANN Security & Stability Advisory Committee’s deliberations and outputs on WHOIS, including SAC003, SAC027, SAC033, SAC037, SAC040, and SAC051. They are also active participants in both technical and policy decision making in ICANN, aimed at restricting abusive behavior.

WHOIS Staff Resourcing Plans
Since its founding, Afilias has focused on delivering secure, stable and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and ongoing maintenance of this gTLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the Afilias project management methodology allows efficient and effective use of its staff in a focused way.

Within Afilias, there are 11 staff members who develop and maintain the compliant WHOIS systems. They keep pace with access requirements, thwart abuse, and continually develop software. Of these resources, approximately two staffers are typically required for WHOIS-related code customization. Other resources provide quality assurance, and operations personnel maintain the WHOIS system itself. This team will be responsible for the implementation and ongoing maintenance of the new gTLD WHOIS service.

Public Interest Registry (PIR) has been successfully managing .ORG, one of the internet’s original gTLDs, for over nine years. PIR uses Afilias Limited as the registry backend service provider who will also support this gTLD. Afilias has experience managing registrations for over a decade and supports comprehensive registration lifecycle services including the registration states, all standard grace periods, and can address any modifications required with the introduction of any new ICANN policies.

This gTLD will follow the ICANN standard domain lifecycle, similar to other gTLDs, such as .ORG. There are four main phases in the lifecycle of this gTLD domain name. These include: 1) the Registration period, 2) the Auto-renew grace period, 3) the Redemption grace period, and 4) the Pending delete period. The response below includes a description of a domain lifecycle, including domain creation, transfer protocols, grace period implementation, and the respective time frames for each, as well as, a summary of the resources needed to support them. All gTLD domains are subject to the policies defined in Evaluation Questions #28 and #29.

As depicted in figure 27-a, prior to the beginning of the Trademark Claims Service or Sunrise IP protection program, PIR, through Afilias, will support the reservation of names in accordance with the new gTLD Registry Agreement, Specification 5.

1. Registration Period
After the IP protection program and the general launch, registrants may choose to register a gTLD domain name through an ICANN accredited registrar. The registrar will check availability on the requested domain name and if available, will collect required contact and host (nameserver) information and provision this information into the registry system using standard Extensible Provisioning Protocol (EPP) commands through a secure connection to the registry backend service provider.

When the domain is created, the standard five day Add Grace Period begins, the domain and contact information are available in WHOIS, and normal operating EPP domain statuses will apply.

Other specifics regarding registration rules for a gTLD active domain include:
• The domain must be unique;
• Restricted or reserved domains cannot be registered;
• The domain can be registered from 1-10 years;
• The domain can be renewed at any time for 1-10 years, but cannot exceed 10 years;
• The domain can be explicitly deleted at any time;
• The domain can be transferred from one registrar to another except during the first 60 days following a successful registration or within 60 days following a transfer; and,
• Contacts and hosts can be modified at any time.

The following describe gTLD domain status values recognized in WHOIS when using the EPP protocol following RFC 5731.
• OK or Active: This is the normal status for a domain that has no pending operations or restrictions.
• Inactive: The domain has no delegated name servers.
• Locked: No action can be taken on the domain. The domain cannot be renewed, transferred, updated, or deleted. No objects such as contacts or hosts can be associated to, or disassociated from the domain. This status includes: Delete Prohibited ⁄ Server Delete Prohibited, Update Prohibited ⁄ Server Update Prohibited, Transfer Prohibited, Server Transfer Prohibited, Renew Prohibited, Server Renew Prohibited.
• Hold: The domain will not be included in the zone. This status includes: Client Hold, Server Hold.
• Transfer Prohibited: The domain cannot be transferred away from the sponsoring registrar. This status includes: Client Transfer Prohibited, Server Transfer Prohibited.

The following describe the registration operations that apply to the domain name during the registration period.

a) Domain Modifications: This operation allows for modifications or updates to the domain attributes to include:
i. Registrant Contact
ii. Admin Contact
iii. Technical Contact
iv. Billing Contact
v. Host or nameservers
vi. Authorization information
vii. Associated status values

A domain with the EPP status of Client Update Prohibited or Server Update Prohibited may not be modified until the status is removed.

b) Domain Renewals: This operation extends the registration period of a domain by changing the expiration date. The following rules apply:
i. A domain can be renewed at any time during its registration term,
ii. The registration term cannot exceed a total of 10 years.

A domain with the EPP status of Client Renew Prohibited or Server Renew Prohibited cannot be renewed.

c) Domain Deletions: This operation deletes the domain from the SRS. The following rules apply:
i. A domain can be deleted at any time during its registration term,
ii. If the domain is deleted during the Add Grace Period or the Renew⁄Extend Grace Period, the sponsoring registrar will receive a credit,
iii. A domain cannot be deleted if it has “child” nameservers that are associated to other domains.

A domain with the EPP status of Client Delete Prohibited or Server Delete Prohibited cannot be deleted.

d) Domain Transfers: A transfer of the domain from one registrar to another is conducted by following the steps below.
i. The registrant must obtain the applicable 〈authInfo〉 code from the sponsoring (losing) registrar.
• Every domain name has an 〈authInfo〉 code as per EPP RFC 5731. The 〈authInfo〉 code is a six- to 16-character code assigned by the registrar at the time the name was created. Its purpose is to aid identification of the domain owner so proper authority can be established (it is the ʺpasswordʺ to the domain).
• Under the Registry-Registrar Agreement, registrars will be required to provide a copy of the 〈authInfo〉 code to the domain registrant upon his or her request.
ii. The registrant must provide the 〈authInfo〉 code to the new (gaining) registrar, who will then initiate a domain transfer request. A transfer cannot be initiated without the 〈authInfo〉 code.
• Every EPP 〈transfer〉 command must contain the 〈authInfo〉 code or the request will fail. The 〈authInfo〉 code represents authority to the registry to initiate a transfer.
iii. Upon receipt of a valid transfer request, the registry automatically asks the sponsoring (losing) registrar to approve the request within five calendar days.
• When a registry receives a transfer request the domain cannot be modified, renewed or deleted until the request has been processed. This status must not be combined with either Client Transfer Prohibited or Server Transfer Prohibited status.
• If the sponsoring (losing) registrar rejects the transfer within five days, the transfer request is cancelled. A new domain transfer request will be required to reinitiate the process.
• If the sponsoring (losing) registrar does not approve or reject the transfer within five days, the registry automatically approves the request.
iv. After a successful transfer, it is strongly recommended that registrars change the 〈authInfo〉 code, so that the prior registrar or registrant cannot use it anymore.
v. Registrars must retain all transaction identifiers and codes associated with successful domain object transfers and protect them from disclosure.
vi. Once a domain is successfully transferred the status of TRANSFERPERIOD is added to the domain for a period of five days.
vii. Successful transfers will result in a one year term extension (resulting in a maximum total of 10 years), which will be charged to the gaining registrar.

e) Bulk Transfer: PIR, through Afilias, supports bulk transfer functionality within the SRS for situations where ICANN may request the registry to perform a transfer of some or all registered objects (includes domain, contact and host objects) from one registrar to another registrar. Once a bulk transfer has been executed, expiry dates for all domain objects remain the same, and all relevant states of each object type are preserved. In some cases the gaining and the losing registrar as well as the registry must approved bulk transfers. A detailed log is captured for each bulk transfer process and is archived for audit purposes.

PIR will support ICANN’s Transfer Dispute Resolution Process. PIR will work with Afilias to respond to Requests for Enforcement (law enforcement or court orders) and will follow that process.

2. Auto-Renew Grace Period
The Auto-Renew Grace Period displays as AUTORENEWPERIOD in WHOIS. An auto-renew must be requested by the registrant through the sponsoring registrar and occurs if a domain name registration is not explicitly renewed or deleted by the expiration date and is set to a maximum of 45 calendar days. In this circumstance the registration will be automatically renewed by the registry system the first day after the expiration date. If a Delete, Extend, or Transfer occurs within the AUTORENEWPERIOD the following rules apply:
i. Delete. If a domain is deleted the sponsoring registrar at the time of the deletion receives a credit for the auto-renew fee. The domain then moves into the Redemption Grace Period with a status of PENDING DELETE RESTORABLE.
ii. Renew⁄Extend. A domain can be renewed as long as the total term does not exceed 10 years. The account of the sponsoring registrar at the time of the extension will be charged for the additional number of years the registration is renewed.
iii. Transfer (other than ICANN-approved bulk transfer). If a domain is transferred, the losing registrar is credited for the auto-renew fee, and the year added by the operation is cancelled. As a result of the transfer, the expiration date of the domain is extended by minimum of one year as long as the total term does not exceed 10 years. The gaining registrar is charged for the additional transfer year(s) even in cases where a full year is not added because of the maximum 10 year registration restriction.

3. Redemption Grace Period
During this period, a domain name is placed in the PENDING DELETE RESTORABLE status when a registrar requests the deletion of a domain that is not within the Add Grace Period. A domain can remain in this state for up to 30 days and will not be included in the zone file. The only action a registrar can take on a domain is to request that it be restored. Any other registrar requests to modify or otherwise update the domain will be rejected. If the domain is restored it moves into PENDING RESTORE and Server Renew Prohibited, Server Delete Prohibited, Server Update Prohibited, Server Update Prohibited, and then OK once a restore report is received from the registrar of record. After 30 days if the domain is not restored it moves into PENDING DELETE SCHEDULED FOR RELEASE before the domain is released back into the pool of available domains.

4. Pending Delete
During this period, a domain name is placed in PENDING DELETE SCHEDULED FOR RELEASE status for five days, and all Internet services associated with the domain will remain disabled and domain cannot be restored. After five days the domain is released back into the pool of available domains.

Other Grace Periods
All ICANN required grace periods will be implemented in the registry backend service provider’s system including the Add Grace Period (AGP), Renew⁄Extend Grace Period (EGP), Transfer Grace Period (TGP), Auto-Renew Grace Period (ARGP), and Redemption Grace Period (RGP). The lengths of grace periods are configurable in the registry system. At this time, the grace periods will be implemented following other gTLDs such as .ORG. More than one of these grace periods may be in effect at any one time. The following are accompanying grace periods to the registration lifecycle.

Add Grace Period
The Add Grace Period displays as ADDPERIOD in WHOIS and is set to five calendar days following the initial registration of a domain. If the domain is deleted by the registrar during this period, the registry provides a credit to the registrar for the cost of the registration. If a Delete, Renew⁄Extend, or Transfer operation occurs within the five calendar days, the following rules apply.
• Delete. If a domain is deleted within this period the sponsoring registrar at the time of the deletion is credited for the amount of the registration. The domain is deleted from the registry backend service provider’s database and is released back into the pool of available domains.
• Renew⁄Extend. If the domain is renewed within this period and then deleted, the sponsoring registrar will receive a credit for both the registration and the extended amounts. The account of the sponsoring registrar at the time of the renewal will be charged for the initial registration plus the number of years the registration is extended. The expiration date of the domain registration is extended by that number of years as long as the total term does not exceed 10 years.
• Transfer (other than ICANN-approved bulk transfer). Transfers under Part A of the ICANN Policy on Transfer of Registrations between registrars may not occur during the ADDPERIOD or at any other time within the first 60 days after the initial registration. Enforcement is the responsibility of the registrar sponsoring the domain name registration and is enforced by the Shared Registration System (SRS).

Renew ⁄ Extend Grace Period
The Renew ⁄ Extend Grace Period displays as RENEWPERIOD in WHOIS and is set to five calendar days following an explicit renewal on the domain by the registrar. If a Delete, Extend, or Transfer occurs within the five calendar days, the following rules apply:
i. Delete. If a domain is deleted within this period the sponsoring registrar at the time of the deletion receives a credit for the renewal fee. The domain then moves into the Redemption Grace Period with a status of PENDING DELETE RESTORABLE.
ii. Renew⁄Extend. A domain registration can be renewed within this period as long as the total term does not exceed 10 years. The account of the sponsoring registrar at the time of the extension will be charged for the additional number of years the registration is renewed.
iii. Transfer (other than ICANN-approved bulk transfer). If a domain is transferred within the Renew⁄Extend Grace Period, there is no credit to the losing registrar for the renewal fee. As a result of the transfer, the expiration date of the domain registration is extended by a minimum of one year as long as the total term for the domain does not exceed 10 years.

If a domain is auto-renewed, then extended, and then deleted within the Renew⁄Extend Grace Period, the registrar will be credited for any auto-renew fee charged and the number of years for the extension. The years that were added to the domain’s expiration as a result of the auto-renewal and extension are removed. The deleted domain is moved to the Redemption Grace Period with a status of PENDING DELETE RESTORABLE.

Transfer Grace Period
The Transfer Grace period displays as TRANSFERPERIOD in WHOIS and is set to five calendar days after the successful transfer of domain name registration from one registrar to another registrar. Transfers under Part A of the ICANN Policy on Transfer of Registrations between registrars may not occur during the TRANSFERPERIOD or within the first 60 days after the transfer. If a Delete or Renew⁄Extend occurs within that five calendar days, the following rules apply:
i. Delete. If the domain is deleted by the new sponsoring registrar during this period, the registry provides a credit to the registrar for the cost of the transfer. The domain then moves into the Redemption Grace Period with a status of PENDING DELETE RESTORABLE.
ii. Renew⁄Extend. If a domain registration is renewed within the Transfer Grace Period, there is no credit for the transfer. The registrarʹs account will be charged for the number of years the registration is renewed. The expiration date of the domain registration is extended by the renewal years as long as the total term does not exceed 10 years.

Overlapping Grace Periods
If an operation is performed that falls into more than one grace period, the actions appropriate for each grace period apply (with some exceptions as noted below).

If a domain is deleted within the Add Grace Period and the Renew⁄Extend Grace Period, then the registrar is credited the registration and extend amounts, taking into account the number of years for which the registration and extend were done. The domain is removed from the registry database and is immediately available for registration by any registrar.

Overlap Exceptions
If a domain is deleted within one or several Transfer Grace Periods, then only the current sponsoring registrar is credited for the transfer amount. For example, if a domain is transferred from Registrar A to Registrar B and then to Registrar C and finally deleted by Registrar C within the Transfer Grace Period of the first and second transfers, then only the last transfer is credited to Registrar C.

If a domain registration is extended within the Transfer Grace Period, then the current registrarʹs account is charged for the number of years the registration is extended.

Resource Plans
PIR will devote resources to support the registrar onboarding and sign-up process, marketing campaigns, the domain registration lifecycle, and any dispute resolution processes necessary, similar to its current role in maintaining the .ORG domain. PIR estimates no more than 1 compliance officer, and anticipates using a .ORG resource to handle disputes as they arise.
Since its founding, Afilias has focused on delivering secure, stable and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and ongoing maintenance of this gTLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the project management methodology allows efficient and effective use of staff to focus on all aspects of the registration lifecycle.

Afilias has its development and quality assurance departments on hand to modify the grace period functionality as needed, if ICANN issues new consensus policies or the RFCs change. Afilias has more than 30 staff members in these departments.

The Public Interest Registry (PIR), working with Afilias Limited, the registry backend service provider, will take the requisite operational and technical steps to promote WHOIS data accuracy, limit abusive registrations, remove outdated and inaccurate data, and other security measures to ensure the integrity of this gTLD. The specific measures include, but are not limited to:
• Posting a gTLD Anti-Abuse Policy that clearly defines abuse, and provides point-of-contact information for reporting suspected abuse;
• Committing to rapid identification and resolution of abuse, including suspensions;
• Ensuring completeness of WHOIS information at the time of registration;
• Publishing and maintaining procedures for removing orphan glue records for names removed from the zone; and,
• Establishing measures to deter WHOIS abuse, including rate-limiting, determining data syntax validity, and implementing and enforcing requirements from the Registry-Registrar Agreement.

Abuse Policy
The Anti-Abuse Policy stated below will be enacted under the contractual authority of PIR through the Registry-Registrar Agreement, and the obligations will be passed onto and made binding with registrants. This policy will be posted on the gTLD website along with contact information for registrants or users to report suspected abuse.

The policy is designed to address the malicious use of domain names. PIR and its registrars will make reasonable attempts to limit significant harm to Internet users. This policy is not intended to take the place of the Uniform Dispute Resolution Policy (UDRP) or the Uniform Rapid Suspension procedure (URS), and it is not to be used as an alternate form of dispute resolution or as a brand protection mechanism. Its intent is to deter those who use domain names maliciously by engaging in illegal or fraudulent activity, not to burden law-abiding or innocent registrants and domain users.

Repeat violations of the abuse policy will result in a case-by-case review of the abuser(s), and the registry operator reserves the right to escalate the issue, with the intent of levying sanctions that are allowed under the TLD Anti-Abuse Policy.

The Anti-Abuse Policy described below is a recent version of the policy that has been used by the .ORG registry since 2009 and will be effective upon launch of this gTLD. It has proven to be an effective and flexible tool.

Anti-Abuse Policy:
Abusive use(s) of the IDN gTLD domain names will not be tolerated. The nature of such abuses creates security and stability issues for the registry, registrars, and registrants, as well as for users of the Internet in general. The registry operator’s definition of abusive use of a domain includes without limitation, the following:
• Illegal or fraudulent actions;
• Spam: The use of electronic messaging systems to send unsolicited bulk messages. The term applies to email spam and similar abuses such as instant messaging spam, mobile messaging spam, and the spamming of websites and Internet forums;
• Phishing: The use of counterfeit web pages that are designed to trick recipients into divulging sensitive data such as personally identifying information, usernames, passwords, or financial data;
• Pharming: The redirecting of unknowing users to fraudulent sites or services, typically through, but not limited to, DNS hijacking or poisoning;
• Willful distribution of malware: The dissemination of software designed to infiltrate or damage a computer system without the ownerʹs informed consent. Examples include, without limitation, computer viruses, worms, keyloggers, and Trojan horses.
• Malicious fast-flux hosting: Use of fast-flux techniques with a botnet to disguise the location of websites or other Internet services, or to avoid detection and mitigation efforts, or to host illegal activities.
• Botnet command and control: Services run on a domain name that are used to control a collection of compromised computers or ʺzombies,ʺ or to direct distributed denial-of-service attacks (DDoS attacks);
• Illegal Access to Other Computers or Networks: Illegally accessing computers, accounts, or networks belonging to another party, or attempting to penetrate security measures of another individualʹs system (often known as ʺhackingʺ). Also, any activity that might be used as a precursor to an attempted system penetration (e.g., port scan, stealth scan, or other information gathering activity).

Pursuant to the Registry-Registrar Agreement, PIR reserves the right at its sole discretion to deny, cancel, or transfer any registration or transaction, or place any domain name(s) on registry lock, hold, or similar status, that it deems necessary: (1) to protect the integrity and stability of the registry; (2) to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of registry operator, as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement and this Anti-Abuse Policy, or (5) to correct mistakes made by registry operator or any registrar in connection with a domain name registration. PIR also reserves the right to place upon a domain a registry lock, hold, or similar status during resolution of a dispute.

The policy stated above will be accompanied by notes about how to submit a report to PIR’s abuse point of contact, and how to report an orphan glue record suspected of being used in connection with malicious conduct (see below).

Abuse Point of Contact and Procedures for Handling Abuse Complaints
PIR will establish an abuse point of contact. This contact will be a role-based email address from the registry operator. This email address will allow multiple staff members to monitor abuse reports on a 24x7 basis, and then work toward closure of cases as each situation calls for. For tracking purposes, there will be a ticketing system with which all complaints will be tracked internally. The reporter will be provided with the ticket reference identifier for potential follow-up. Afilias will integrate its existing ticketing system with the registry operator’s to ensure uniform tracking and handling of the complaint. This role-based approach has been used successfully by ISPs, email service providers, and registrars for many years, and is considered a global best practice.

PIR’s designated abuse handlers will then evaluate complaints received via the abuse system address. They will decide whether a particular issue is of concern, and decide what action, if any, is appropriate.

In general, PIR may find itself receiving abuse reports from a wide variety of parties, including security researchers and Internet security companies, financial institutions such as banks, ordinary Internet users, and law enforcement agencies among others. Some of these parties may provide good forensic data or supporting evidence of the malicious behavior. In other cases, the party reporting an issue may not be familiar with how to provide such data or proof of malicious behavior. PIR will review all evidence before taking any action on complaints.

The security function includes a communication and outreach function, with information sharing with industry partners regarding malicious or abusive behavior, in order to ensure coordinated abuse mitigation across multiple TLDs.

Assessing abuse reports requires great care, and the registry operator will rely upon professional, trained investigators who are versed in such matters. The goals are accuracy, good record-keeping, and a zero false-positive rate so as not to harm innocent registrants.

Different types of malicious activities require different methods of investigation and documentation. Further, PIR expects to face unexpected or complex situations that call for professional advice, and will rely upon professional, trained investigators as needed.

In general, there are two types of domain abuse that must be addressed:
a) Compromised domains. These domains have been hacked or otherwise compromised by criminals, and the registrant is not responsible for the malicious activity taking place on the domain. For example, the majority of domain names that host phishing sites are compromised. The goal in such cases is to get word to the registrant (usually via the registrar) that there is a problem that needs attention, with the expectation that the registrant will address the problem in a timely manner. Ideally such domains do not get suspended, since suspension would disrupt legitimate activity on the domain.
b) Malicious registrations. These domains are registered by malefactors for the purpose of abuse. Such domains are generally targets for suspension, since they have no legitimate use.

The standard procedure is that the registry operator will forward a credible alleged case of malicious domain name use to the domain’s sponsoring registrar with a request that the registrar investigate the case and act appropriately. The registrar will be provided evidence collected as a result of the investigation conducted by the trained abuse handlers. The registrar is the party with a direct relationship with—and a direct contract with—the registrant. The registrar will also have vital information that the registry operator will not, such as:
• Details about the domain registration, such as the payment method used (credit card, PayPal, etc.);
• The identity of a proxy-protected registrant;
• The registrant’s IP address;
• Whether there is a reseller involved; and,
• The registrant’s past sales history and registrations in other TLDs (insofar as the registrar can determine this).

Registrars do not share the above information with registry operators due to privacy and liability concerns, among others. Because they have more information with which to continue the investigation, and because they have a direct relationship with the registrant, the registrar is in the best position to evaluate alleged abuse. The registrar can determine if the use violates the registrar’s legal terms of service or the registry Anti-Abuse Policy, and can decide whether or not to take any action. While the language and terms vary, registrars will be expected to include language in their registrar-registrant contracts that indemnifies the registrar if it takes action, and allows the registrar to suspend or cancel a domain name; this will be in addition to the registry Anti-Abuse Policy. Generally, registrars can act if the registrant violates the registrar’s terms of service, or violates ICANN policy, or if illegal activity is involved, or if the use violates PIR’s Anti-Abuse Policy.

If a registrar does not take action within an established time period indicated by the registry operator – usually 24 hours, PIR may then decide to take action itself. At all times, PIR reserves the right to act directly and immediately if the potential harm to Internet users seems significant or imminent, with or without notice to the sponsoring registrar.

PIR is prepared to call upon relevant law enforcement bodies as needed. There are certain cases, for example, illegal pharmacy domains, where the registry operator will contact the law enforcement agencies to share information about these domains, provide all the evidence collected and work closely with them before any action will be taken for suspension. The specific action is often dependent upon the jurisdiction of the registry operator, although the operator in all cases will adhere to applicable laws and regulations.

When valid court orders or seizure warrants are received from courts or law enforcement agencies of relevant jurisdiction, PIR will review them and order execution in an expedited fashion. Compliance with these will be a top priority and will be completed as soon as possible and within the defined timelines of the order. There are certain cases where law enforcement agencies request information about a domain including but not limited to:
• Registration information
• History of a domain, including recent updates made
• Other domains associated with a registrant’s account
• Patterns of registrant portfolio

Requests for such information is handled on a priority basis and sent back to the requestor as soon as possible. A goal is set to respond to such requests within 24 hours.

PIR and Afilias may also engage in proactive screening of its zone for malicious use of the domains in the gTLD, and report problems to the sponsoring registrars. Combinations of the following additional resources are available, among others:
• Blocklists of domain names and nameservers published by organizations such as SURBL and Spamhaus.
• Anti-phishing feeds, which will provide URLs of compromised and maliciously registered domains being used for phishing.
• Analyses of registration or DNS query data (DNS query data received by the gTLD nameservers.)

PIR will keep records and track metrics regarding abuse and abuse reports. These may include:
• Number of abuse reports received by the registry’s abuse point of contact described above;
• Number of cases and domains referred to registrars for resolution;
• Number of cases and domains where the registry took direct action;
• Resolution times;
• Number of domains in the gTLD that have been blacklisted by major anti-spam blocklist providers; and,
• Phishing site uptimes in the gTLD.

Removal of Orphan Glue Records
By definition, orphan glue records used to be glue records. Glue records are related to delegations and are necessary to guide iterative resolvers to delegated nameservers. A glue record becomes an orphan when its parent nameserver record is removed without also removing the corresponding glue record. (Please reference the ICANN SSAC paper SAC048 at: http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf.) Orphan glue records may be created when a domain (example.tld) is placed on EPP Server Hold or Client Hold status. When placed on Hold, the domain is removed from the zone and will stop resolving. However, any child nameservers (now orphan glue) of that domain (e.g., ns1.example.tld) are left in the zone. It is important to keep these orphan glue records in the zone so that any innocent sites using that nameserver will continue to resolve. This use of Hold status is an essential tool for suspending malicious domains.

PIR and Afilias observe the following procedures, which are being followed by other registries and are generally accepted as DNS best practices. These procedures are also in keeping with ICANN SSAC recommendations.

When a request to delete a domain is received from a registrar, the registry first checks for the existence of glue records. If glue records exist, the registry will check to see if other domains in the registry are using the glue records. If other domains in the registry are using the glue records then the request to delete the domain will fail until no other domains are using the glue records. If no other domains in the registry are using the glue records then the glue records will be removed before the request to delete the domain is satisfied. If no glue records exist then the request to delete the domain will be satisfied.

If a registrar cannot delete a domain because of the existence of glue records that are being used by other domains, then the registrar may refer to the zone file or the “weekly domain hosted by nameserver report” to find out which domains are using the nameserver in question and attempt to contact the corresponding registrar to request that they stop using the nameserver in the glue record. The registry operator does not plan on performing mass updates of the associated DNS records.

The registry operator will accept, evaluate, and respond appropriately to complaints that orphan glue is being used maliciously. Such reports should be made in writing to the registry operator, and may be submitted to the registry’s abuse point-of-contact. If it is confirmed that an orphan glue record is being used in connection with malicious conduct, the registry operator will have the orphan glue record removed from the zone file. Afilias has the technical ability to execute such requests as needed.

Methods to Promote WHOIS Accuracy
The creation and maintenance of accurate WHOIS records is an important part of registry management. As described in our response to Evaluation Question #26, (WHOIS), PIR will manage a secure, robust and searchable WHOIS service for this gTLD.

WHOIS Data Accuracy:
PIR will offer a “thick” registry system. In this model, all key contact details for each domain name will be stored in a central location by the registry. This allows better access to domain data, and provides uniformity in storing the information. PIR will ensure that the required fields for WHOIS data (as per the defined policies for the gTLD) are enforced at the registry level. This ensures that the registrars are providing required domain registration data. Fields defined by the registry policy that are mandatory, are documented as such, and must be submitted by registrars. Afilias’ system verifies formats for relevant individual data fields (e.g. email, and phone⁄fax numbers). Only valid country codes are allowed as defined by the ISO 3166-1 code list. The WHOIS system is extensible, and is capable of using the VAULT system, described further below.

Similar to the centralized abuse point of contact described above, PIR can institute a contact email address which could be utilized by third parties to submit complaints for inaccurate or false WHOIS data detected. This information will be processed by Afilias’ support department and forwarded to the registrars. The registrars can work with the registrants of those domains to address these complaints. Afilias will audit registrars on a yearly basis to verify whether the complaints being forwarded are being addressed or not. This functionality, available to all registry operators, is activated based on the registry operator’s business policy.

Afilias also incorporates a spot-check verification system where a randomly selected set of domain names are checked periodically for accuracy of WHOIS data. Afilias’ .PRO registry system incorporates such a verification system whereby 1% of total registrations or 100 domains, whichever number is larger, are spot-checked every month to verify the domain name registrant’s critical information provided with the domain registration data. With both a highly qualified corps of engineers and a 24x7 staffed support function, Afilias has the capacity to integrate such spot-check functionality into this gTLD, based on PIR’s business policy. Note: This functionality will not work for proxy protected WHOIS information, where registrars or their resellers have the actual registrant data. The solution to that problem lies with either registry or registrar policy, or a change in the general marketplace practices with respect to proxy registrations.

Finally, Afilias’ registry systems have a sophisticated set of billing and pricing functionality which aids registry operators who decide to provide a set of financial incentives to registrars for maintaining or improving WHOIS accuracy. For instance, it is conceivable that PIR may decide to provide a discount for the domain registration or renewal fees for validated registrants, or levy a larger cost for the domain registration or renewal of proxy domain names. The Afilias system has the capability to support such incentives on a configurable basis, towards the goal of promoting better WHOIS accuracy.

Role of Registrars:
As part of the Registry Registrar Agreement (RRA), PIR will require the registrar to be responsible for ensuring the input of accurate WHOIS data by their registrants. The Registrar-Registered Name Holder Agreement will include a specific clause to ensure accuracy of WHOIS data, and to give the registrar rights to cancel or suspend registrations if the registered name holder fails to respond to the registrar’s query regarding accuracy of data. ICANN’s WHOIS Data Problem Reporting System (WDPRS) will be available to those who wish to file WHOIS inaccuracy reports, as per ICANN policy (http:⁄⁄wdprs.internic.net⁄).

Controls to Ensure Proper Access to Domain Functions
Several measures are in place in the registry backend service provider’s system to ensure proper access to domain functions, including authentication provisions in the RRA relative to notification and contact updates via use of authorization codes.

IP address access control lists, TLS⁄SSL certificates and proper authentication are used to control access to the registry system. Registrars are only given access to perform operations on the objects they sponsor.

Every domain will have a unique authorization code. The authorization code is a six- to 16-character code assigned by the registrar at the time the name is created. Its purpose is to aid identification of the domain owner so proper authority can be established. It is the ʺpasswordʺ to the domain name. Registrars must use the domain’s password in order to initiate a registrar-to-registrar transfer. It is used to ensure that domain updates (update contact information, transfer, or deletion) are undertaken by the proper registrant, and that this registrant is adequately notified of domain update activity. Only the sponsoring registrar of a domain has access to the domain’s authorization code stored in the registry, and this is accessible only via encrypted, password-protected channels.

Information about other registry security measures such as encryption and security of registrar channels are confidential to ensure the security of the registry system. The details can be found in the response to Evaluation Question #30b.

Registry Actions
PIR reserves the right to deny, cancel or transfer any registration that it deems necessary, in its discretion, to protect the integrity and stability of the registry, to comply with any applicable laws, government rules or requirements, requests of law enforcement, in compliance with any dispute resolution process, or to avoid any liability, civil or criminal, on the part of registry operator, as well as its affiliates, subsidiaries, officers, directors and employees. PIR reserves the right to freeze a domain name during resolution of a dispute. PIR reserves the right to terminate a domain at any time for failure by the registrant to comply with this IDN Registration Policies.

Afilias Limited, the registry backend service provider, has developed advanced validation and abuse mitigation mechanisms. These capabilities and mechanisms are described below. These services and capabilities are discretionary and may be utilized by the registry operator based on their policy and business need.

Validation and Abuse Mitigation Mechanisms:
The registry backend service provider has the ability to analyze the registration data for known patterns at the time of registration. A database of these known patterns is developed from domains and other associated objects (e.g., contact information) which have been previously detected and suspended after being flagged as abusive. Any domains matching the defined criteria can be flagged for investigation by the domain anti-abuse team members. Once analyzed and confirmed, these domains may be suspended. This provides proactive detection of abusive domains.

Registrant Pre-Verification and Authentication:
One of the systems that could be used for validity and identity authentication is VAULT (Validation and Authentication Universal Lookup). It utilizes information obtained from a series of trusted data sources with access to billions of records containing data about individuals for the purpose of providing independent age and ID verification as well as the ability to incorporate additional public or private data sources as required. At present it has the following: U.S. residential coverage - 90% of adult population and also International Coverage - varies from country to country with a minimum of 80% coverage (24 countries, mostly European).

Various verification elements can be used; as an example: name, address, phone, etc. Multiple methods could be used for verification include integrated solutions utilizing API (XML Application Programming Interface) or sending batches of requests.

• Verification and authentication requirements would be based on the requirements or specific criteria developed by PIR.
• Based on required WHOIS Data; registrant contact details (name, address, phone).
• If address⁄ZIP can be validated by VAULT, the validation process can continue (N. America +25 International countries).
• If in-line processing and registration and EPP⁄API call would go to the verification clearinghouse and return up to 4 challenge questions.
• If two-step registration is required, then registrants would get a link to complete the verification at a separate time. The link could be specific to a domain registration and pre-populated with data about the registrant.
• If WHOIS data is validated a token would be generated and could be given back to the registrar which registered the domain.
• WHOIS data would reflect the validated data or some subset, i.e., fields displayed could be first initial and last name, country of registrant and date validated. Other fields could be generic validation fields much like a “privacy service”.
• A “Validation Icon” customized script would be sent to the registrants email address. This could be displayed on the website and would be dynamically generated to avoid unauthorized use of the Icon. When clicked on the Icon would should limited WHOIS details, i.e., Registrant: jdoe, Country: USA, Date Validated: March 29, 2011, as well as legal disclaimers.
• Validation would be annually renewed, and validation date displayed in the WHOIS.

Abuse Prevention Resourcing Plans:
Since its founding, Afilias has focused on delivering secure, stable and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and ongoing maintenance of this TLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the Afilias project management methodology allows efficient and effective use of its staff in a focused way. Abuse prevention and detection is a function that is staffed across the various groups inside Afilias, and requires a team effort when abuse is either well hidden or widespread, or both. While all of Afilias’ 200+ employees are charged with responsibility to report any detected abuse, the engineering and analysis teams, numbering over 30, provide specific support based on the type of abuse and volume and frequency of analysis required. The Afilias security and support teams have the authority to initiate mitigation.

Afilias has developed advanced validation and abuse mitigation mechanisms. These capabilities and mechanisms are described below. These services and capabilities are discretionary and may be utilized by the registry operator based on their policy and business need.

PIR and Afilias will maintain resources to:
1. Evaluate incoming reports to the abuse point of contact, and either act upon them or refer them to registrars as per the above-described procedures.
2. Evaluate incoming reports from other sources and either act upon them or refer them to registrars as per the above-described procedures.
3. If these validation and abuse mitigation mechanisms are used, then Afilias will maintain resources to analyze the registry and gTLD DNS zone activity for malicious and suspicious activity and either act upon them or refer them to registrars as per the above-described procedures.

This gTLD’s anticipated volume of registrations in the first three years of operations is listed in response to Evaluation Question #46. PIR’s and Afilias’ anti-abuse function anticipates the expected volume and type of registrations, and together will adequately cover the staffing needs for this gTLD. PIR will maintain an abuse response team, which may be a combination of internal staff and outside specialty contractors, adjusting to the needs of the size and type of gTLD. The team structure planned for this gTLD is based on several years of experience responding to, mitigating, and managing abuse for gTLDs of various sizes. The team will generally consist of abuse handlers (internal), a junior analyst, (either internal or external), and a senior security consultant (likely an external resource providing the registry operator with extra expertise as needed). These responders will be specially trained in the investigation of abuse complaints, and will have the latitude to act expeditiously to suspend domain names (or apply other remedies) when called for.

The exact resources required to maintain an abuse response team must change with the size and registration procedures of the gTLD. An initial abuse handler is necessary as a point of contact for reports, even if a part-time responsibility. The abuse handlers monitor the abuse email address for complaints and evaluate incoming reports from a variety of sources. A large percentage of abuse reports to the registry operator may be unsolicited commercial email. The designated abuse handlers can identify legitimate reports and then decide what action is appropriate, either to act upon them, escalate to a security analyst for closer investigation, or refer them to registrars as per the above-described procedures. A gTLD with rare cases of abuse would conform to this structure.

If multiple cases of abuse within the same week occur regularly, PIR will consider staffing internally a security analyst to investigate the complaints as they become more frequent. Training an abuse analyst requires 3-6 months and likely requires the active guidance of an experienced senior security analyst for guidance and verification of assessments and recommendations being made.

If this gTLD were to regularly experience multiple cases of abuse within the same day, a full-time senior security analyst would likely be necessary. A senior security analyst capable of fulfilling this role should have several years of experience and able to manage and train the internal abuse response team.

The abuse response team will also maintain subscriptions for several security information services, including the blocklists from organizations like SURBL and Spamhaus and anti-phishing and other domain related abuse (malware, fast-flux etc.) feeds. The pricing structure of these services may depend on the size of the domain and some services will include a number of rapid suspension requests for use as needed.

For a large gTLD, regular audits of the registry data are required to maintain control over abusive registrations. When a registrar with a significant number of registrations has been compromised or acted maliciously, the registry operator may need to analyze a set of registration or DNS query data. A scan of all the domains of a registrar is conducted only as needed. Scanning and analysis for a large registrar may require as much as a week of full-time effort for a dedicated machine and team.

Rights protection is a core responsibility of the gTLD registry operator, and is supported by a well-developed plan for rights protection that includes:
• Implementing a robust Sunrise program, utilizing the Trademark Clearinghouse, the services of one of ICANN’s approved dispute resolution providers, a trademark validation agent, and drawing upon Sunrise Policies and rules used successfully in previous gTLD launches;
• Implementing a professional trademark claims program that utilizes the Trademark Clearinghouse, and drawing upon models of similar programs used successfully in previous TLD launches;
• Complying with the URS requirements;
• Complying with the UDRP; 
• Complying with the PDDRP; and, 
• Including all ICANN-mandated and independently developed Rights Protection Mechanisms (RPMs) in the Registry-Registrar Agreement entered into by ICANN-accredited registrars authorized to register names in the gTLD.

The response below details the Rights Protection Mechanisms at the launch of the gTLD (Sunrise and Trademark Claims Service) which comply with rights protection policies (URS, UDRP, PDDRP, and other ICANN RPMs), and outlines additional provisions made for rights protection, and provides the resourcing plans.

Safeguards for Rights Protection at the Launch of the gTLD
The launch of this gTLD will include the operation of a Trademark Claims Service according to the defined ICANN processes for checking a registration request and alerting trademark holders of potential rights infringement. The registry operator will recognize and honor all word marks that have been or are: (i) nationally or regionally registered; (ii) court validated; or (iii) specifically protected by a statute or treaty in effect at the time the mark is submitted to the Clearinghouse for inclusion. No demonstration of use will be required.

Sunrise Intellectual Property Protection
PIR has employed the following concerning protection of intellectual property.

The Sunrise policy will be in effect during the Sunrise pre-registration period where eligible intellectual property holders will get a first chance to register their gTLD domain name. In order to complete a gTLD domain name registration during the Sunrise pre-registration period, a registrant must fulfill the IDN Registration Policies defined in Evaluation Question #18b(iv), and Sunrise requirements set forth below.

PIR will implement the Trademark Clearinghouse (TMCH) guidelines and rules when available. Names provided to PIR via the TMCH that also are names that registrants are requesting, will proceed to be registered by those that qualify. 

Following the end of the Sunrise Period, names that are not otherwise reserved will be available. Disputes concerning results from the Sunrise can be raised in the Sunrise Dispute Resolution Policy (SDRP) defined below.

The Sunrise Period will be an exclusive period of time, prior to the opening of general registration, when trademark and service mark holders will be able to reserve marks that are an identical match to the gTLD domain. Following the Sunrise Period, Quiet Period, and Landrush Period, PIR will open registration to qualified applicants.

The anticipated rollout schedule for this gTLD will be approximately as follows:
- Sunrise Period of 60 days begins for trademark holders and service mark holders to submit registrations for their exact marks in this domain. Following this, PIR expects the balance of Sunrise registrations to be awarded in real-time.
- Quiet Period of 30 days begins at the close of Sunrise.
- Landrush Period of 30 days opens after the Quiet Period.
- Quiet Period of 30 days begins at the close of Landrush.
- General Registration (for qualified applicants) begins after the Quiet Period.

Sunrise Period Requirements & Restrictions:
- Those wishing to reserve their marks in this domain during the Sunrise Period must be the current trademark or service mark owner that meets the criteria set forth in Section 7.2 of the Trademark Clearinghouse specifications, whether or not actually listed in the Clearinghouse. With respect to trademark holders in the Clearinghouse, notice must be provided to all trademark holders if someone is seeking a Sunrise registration. This notice will be provided to holders of marks in the TMCH that are an identical match (as defined in the Trademark Clearinghouse) to the name to be registered during Sunrise.
- Each Sunrise registration will require a minimum term of five years.
- PIR will establish the following Sunrise Eligibility Requirements (SERs) as minimum requirements, verified by TMCH data, and incorporate a Sunrise Dispute Resolution Policy (SDRP).
- The SERs include: (i) ownership of a mark that satisfies the criteria set forth in Section 7.2 of the Trademark Clearinghouse specifications, (ii) description of international class of goods or services covered by registration; (iii) representation that all provided information is true and correct; and (iv) provision of data sufficient to document rights in the trademark.
- The SDRP will allow challenges based on the following four grounds: (i) at the time that the challenged domain name was registered, the registrants did not hold a trademark registration of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; (ii) the domain name is not identical to the mark on which the registrant based its Sunrise registration; (iii) the trademark registration on which the registrant based its Sunrise registration is not of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; or (iv) the trademark registration on which the domain name registrant based its Sunrise registration did not issue on or before the effective date of the new gTLD Registry Agreement and was not applied for on or before ICANN announced the applications received.

Ongoing Rights Protection Mechanisms
Several mechanisms will be in place to protect rights in this gTLD. As described in our responses to Evaluation Questions #27 and #28, measures are in place to ensure domain transfers and updates are only initiated by the appropriate domain holder, and the registry operator will have staff available to respond to legal actions such as court orders.

This gTLD will conform to all ICANN RPMs including Uniform Rapid Suspension (URS, discussed below), UDRP, and all measures defined in Specification 7 of the new gTLD Registry Agreement.

Uniform Rapid Suspension (URS): The registry operator will implement decisions rendered under the URS on an ongoing basis. Per the URS policy included the Applicant Guidebook, the registry operator will receive notice of URS actions from the ICANN-approved URS providers. These emails will be directed immediately to the registry operator’s support staff, which is on duty 24x7. The support staff will be responsible for creating a ticket for each case, and for executing the directives from the URS provider. All support staff will receive pertinent training.

As per ICANN’s URS guidelines, within 24 hours of receipt of the notice of complaint from the URS provider, the registry operator shall “lock” the domain, meaning the registry shall restrict all changes to the registration data, including transfer and deletion of the domain names, but the name can remain in the TLD DNS zone file and can thus continue to resolve. The support staff will “lock” the domain by associating the following EPP statuses with the domain and relevant contact objects: 
- Server Update Prohibited, with an EPP reason code of “URS”
- Server Delete Prohibited, with an EPP reason code of “URS”
- Server Transfer Prohibited, with an EPP reason code of “URS”
- The registry operator’s support staff will then notify the URS provider immediately upon locking the domain name, via email.

The registry operator’s support staff will retain all copies of emails from the URS providers, assign them a tracking or ticket number, and will track the status of each opened URS case through to resolution via a spreadsheet or database.

The registry operator’s support staff will execute further operations upon notice from the URS providers. The URS provider is required to specify the remedy and required actions of the registry operator, with notification to the registrant, the complainant, and the registrar.

As per the URS guidelines, if the complainant prevails, the “registry operator shall suspend the domain name, which shall remain suspended for the balance of the registration period and would not resolve to the original website. The nameservers shall be redirected to an informational web page provided by the URS provider about the URS. The WHOIS for the domain name shall continue to display all of the information of the original registrant except for the redirection of the nameservers. In addition, the WHOIS shall reflect that the domain name will not be able to be transferred, deleted or modified for the life of the registration.”

Rights Protection via the RRA:
The following will be memorialized and be made binding via the Registry-Registrar and Registrar-Registrant agreements:

The registry may reject a registration request or a reservation request, or may delete, revoke, suspend, cancel, or transfer a registration or reservation under the following criteria:
a. to enforce registry policies and ICANN requirements; each as amended from time to time;
b. that is not accompanied by complete and accurate information as required by ICANN requirements and⁄or registry policies or where required information is not updated and⁄or corrected as required by ICANN requirements and⁄or registry policies;
c. to protect the integrity and stability of the registry, its operations, and the gTLD system;
d. to comply with any applicable law, regulation, holding, order, or decision issued by a court, administrative authority, or dispute resolution service provider with jurisdiction over the registry;
e. to establish, assert, or defend the legal rights of the registry or a third party or to avoid any civil or criminal liability on the part of the registry and⁄or its affiliates, subsidiaries, officers, directors, representatives, employees, contractors, and stockholders;
f. to correct mistakes made by the registry or any accredited registrar in connection with a registration; or
g. as otherwise provided in the Registry-Registrar Agreement and⁄or the Registrar-Registrant Agreement.

Reducing Opportunities for Behaviors such as Phishing or Pharming
In our response to Evaluation Question #28, the registry operator has described its anti-abuse program designed to address phishing, pharming, malware, and other forms of abuse that may harm Internet users. This program is designed to actively discover, verify, and mitigate problems without infringing upon the rights of legitimate registrants. This program is designed for use in the general registration period and includes an optional system for monitoring the gTLD for phishing attacks and policies and procedures for verifying and mitigating phishing attacks. These procedures include the reporting of compromised websites⁄domains to registrars for cleanup by the registrants and their hosting providers, and rapid takedown procedures for maliciously registered phishing domains. Rather than repeating the policies and procedures here, please see our response in Section #28 for full details.

These procedures will sometimes allow the registry operator to identify the domain name portfolios of phishers, and suspend those portfolios before all of the domains in them are used. This will reduce damage to Internet users and the brands that such phishers target.

Every six months, the Anti-Phishing Working Group (APWG) publishes its latest Global Phishing Survey. (See http:⁄⁄www.apwg.org⁄resources.html#apwg.) Each edition of this study contains an analysis of how phishers construct phishing URLs and register domain names. The registry operator and the registry backend service provider will continue to track that report and ongoing trends. APWG studies show that in the first half of 2011, just two percent (2%) of the domain names used for phishing (or 12% of malicious phishing registrations) contained a targeted brand name or misspelling thereof. According to the APWG, in the year July 2010 through June 2011, there were only about 5,700 known brand-or-misspelling phishing domains registered in all TLDs worldwide.

The demonstrated phishing problem is therefore a tiny percentage of domain registrations overall, and should be balanced against the impact that filtering or denying incoming domain registrations in the open registration period may have upon other parties. The number of potential variations and misspellings of target brand names is very large, and attempts to deny registrations containing them might infringe upon the rights of other trademark holders. This variant or misspelling problem is one reason why ICANN specified that only exact domain name string matches will be addressed by the Trademark Clearinghouse. In addition, most generic words are trademarked, and trademarked terms may be found within larger words that would be legitimate for registrants to register.

For these reasons, the registry operator does not plan on heuristics based filtering or denying registrations as they come to the registry during the Landrush and general registration periods based on misspelling detection algorithms. Instead, PIR prefers an approach that addresses registered domain names (rather than potentially registered domains). Our planned approach will not infringe upon the rights of legitimate registrants to register domains, and allows the ICANN community-developed UDRP and URS policies and procedures to deal with complaints.

Afilias Limited, the registry backend service provider, is a member of various security fora which provide access to lists of name in each TLD which may be used for malicious purposes. Such identified names will be subject to this gTLD Anti-Abuse Policy including rapid suspensions after due process.

Rights Protection Resourcing Plans
Supporting Rights Protection Mechanisms (RPM) requires several departments within the registry operator as well as within Afilias, the registry backend service provider. The implementation of Sunrise and the Trademark Claims service and ongoing RPM activities will pull from the 102 Afilias staff members of the engineering, product management, development, security and policy teams as well as resources at the registry operator. No additional hardware or software resources are required to support this, as Afilias has fully-operational capabilities to manage abuse today.

Afilias aggressively and actively protects the registry system from known threats and vulnerabilities, and has deployed an extensive set of security protocols, policies and procedures to thwart compromise. Afilias’ robust and detailed plans are continually updated and tested to ensure new threats are mitigated prior to becoming issues. Afilias will continue these rigorous security measures, which include:
• Multiple layers of security and access controls throughout registry and support systems;
• 24x7 monitoring of all registry and DNS systems, support systems and facilities;
• Unique, proven registry design that ensures data integrity by granting only authorized access to the registry system, all while meeting performance requirements;
• Detailed incident and problem management processes for rapid review, communications, and problem resolution; and,
• Yearly external audits by independent, industry-leading firms, as well as twice-yearly internal audits.

Security Policies and Protocols
Afilias has included security in every element of its service, including facilities, hardware, equipment, connectivity⁄Internet services, systems, computer systems, organizational security, outage prevention, monitoring, disaster mitigation, and escrow⁄insurance, from the original design, through development, and finally as part of production deployment. Examples of threats and the confidential and proprietary mitigation procedures are detailed in our response to Evaluation Question #30b.

There are several important aspects of the security policies and procedures to note:
• Afilias hosts domains in data centers around the world that meet or exceed global best practices.
• Afilias’ DNS infrastructure is massively provisioned as part of its DDoS mitigation strategy, thus ensuring sufficient capacity and redundancy to support new gTLDs.
• Diversity is an integral part of all of our software and hardware stability and robustness plan, thus avoiding any single points of failure in our infrastructure.
• Access to any element of our service (applications, infrastructure and data) is only provided on an as-needed basis to employees and a limited set of others to fulfill their job functions. The principle of least privilege is applied.
• All registry components – critical and non-critical – are monitored 24x7 by staff at our Network Operations Centers (NOCs), and the technical staff has detailed plans and procedures that have stood the test of time for addressing even the smallest anomaly. Well-documented incident management procedures are in place to quickly involve the on-call technical and management staff members to address any issues.

Afilias follows the guidelines from the ISO 27001 Information Security Standard (Reference: http:⁄⁄www.iso.org⁄iso⁄iso_catalogue⁄catalogue_tc⁄catalogue_detail.htm?csnumber=42103) for the management and implementation of its Information Security Management System. Afilias also utilizes the COBIT IT governance framework to facilitate policy development and enable controls for appropriate management of risk (Reference: http:⁄⁄www.isaca.org⁄cobit). Best practices defined in ISO 27002 are followed for defining the security controls within the organization. Afilias continually looks to improve the efficiency and effectiveness of our processes, and follows industry best practices as defined by the IT Infrastructure Library, or ITIL (Reference: http:⁄⁄www.itil-officialsite.com⁄).

The Afilias registry system is located within secure data centers that implement a multitude of security measures both to minimize any potential points of vulnerability and to limit any damage should there be a breach. The characteristics of these data centers are described fully in our response to Evaluation Question #30b.

The Afilias registry system employs a number of multi-layered measures to prevent unauthorized access to its network and internal systems. Before reaching the registry network, all traffic is required to pass through a firewall system. Packets passing to and from the Internet are inspected, and unauthorized or unexpected attempts to connect to the registry servers are both logged and denied. Management processes are in place to ensure each request is tracked and documented, and regular firewall audits are performed to ensure proper operation. Twenty-four by seven (24x7) monitoring is in place and, if potential malicious activity is detected, appropriate personnel are notified immediately.

Afilias employs a set of security procedures to ensure maximum security on each of its servers, including disabling all unnecessary services and processes and regular application of security-related patches to the operating system and critical system applications. Regular external vulnerability scans are performed to verify that only services intended to be available are accessible.

Regular detailed audits of the server configuration are performed to verify that the configurations comply with current best security practices. Passwords and other access means are changed on a regular schedule and are revoked whenever a staff member’s employment is terminated.

Access to Registry System
Access to all production systems and software is strictly limited to authorized operations staff members. Access to technical support and network operations teams where necessary are read only and limited only to components required to help troubleshoot customer issues and perform routine checks. Strict change control procedures are in place and are followed each time a change is required to the production hardware⁄application. User rights are kept to a minimum at all times. In the event of a staff member’s employment termination, all access is removed immediately.

Afilias applications use encrypted network communications. Access to the registry server is controlled. Afilias allows access to an authorized registrar only if each of the authentication factors matches the specific requirements of the requested authorization. These mechanisms are also used to secure any web-based tools that allow authorized registrars to access the registry. Additionally, all write transactions in the registry (whether conducted by authorized registrars or the registryʹs own personnel) are logged.

EPP connections are encrypted using TLS⁄SSL, and mutually authenticated using both certificate checks and login⁄password combinations. Web connections are encrypted using TLS⁄SSL for an encrypted tunnel to the browser, and authenticated to the EPP server using login⁄password combinations.

All systems are monitored for security breaches within the data center and outside the data center using both system-based and network-based testing tools. Operations’ staff also monitor systems for security-related performance anomalies. Triple-redundant continual monitoring ensures multiple detection paths for any potential incident or problem. Details are provided in our response to Evaluation Questions #30b and #42. Network Operations and Security Operations teams perform regular audits in search of any potential vulnerability.

To ensure that registrar hosts configured erroneously or maliciously cannot deny service to other registrars, Afilias uses traffic shaping technologies to prevent attacks from any single registrar account, IP address, or subnet. This additional layer of security reduces the likelihood of performance degradation for all registrars, even in the case of a security compromise at a subset of registrars.

There is a clear accountability policy that defines what behaviors are acceptable and unacceptable on the part of non-staff users, staff users, and management. Periodic audits of policies and procedures are performed to ensure that any weaknesses are discovered and addressed. Aggressive escalation procedures and well-defined Incident Response management procedures ensure that decision makers are involved at early stages of any event.

In short, security is a consideration in every aspect of business at Afilias, and this is evidenced in a track record of a decade of secure, stable and reliable service.

Independent Assessment
Supporting operational excellence as an example of security practices, Afilias performs a number of internal and external security audits each year of the existing policies, procedures and practices for:
• Access control
• Security policies
• Production change control
• Backups and restores
• Batch monitoring
• Intrusion detection
• Physical security

Afilias has an annual Type 2 SSAE 16 audit performed by PricewaterhouseCoopers (PwC). Further, PwC performs testing of the general information technology controls in support of the financial statement audit. A Type 2 report opinion under SSAE 16 covers whether the controls were properly designed, were in place, and operating effectively during the audit period (calendar year). This SSAE 16 audit includes testing of internal controls relevant to Afiliasʹ domain registry system and processes. The report includes testing of key controls related to the following control objectives:
• Controls provide reasonable assurance that registrar account balances and changes to the registrar account balances are authorized, complete, accurate and timely.
• Controls provide reasonable assurance that billable transactions are recorded in the Shared Registry System (SRS) in a complete, accurate and timely manner.
• Controls provide reasonable assurance that revenue is systemically calculated by the Deferred Revenue System (DRS) in a complete, accurate and timely manner.
• Controls provide reasonable assurance that the summary and detail reports, invoices, statements, registrar and registry billing data files, and ICANN transactional reports provided to registry operator(s) are complete, accurate and timely.
• Controls provide reasonable assurance that new applications and changes to existing applications are authorized, tested, approved, properly implemented and documented.
• Controls provide reasonable assurance that changes to existing system software and implementation of new system software are authorized, tested, approved, properly implemented and documented.
• Controls provide reasonable assurance that physical access to data centers is restricted to properly authorized individuals.
• Controls provide reasonable assurance that logical access to system resources is restricted to properly authorized individuals.
• Controls provide reasonable assurance that processing and backups are appropriately authorized and scheduled and that deviations from scheduled processing and backups are identified and resolved.

The last Type 2 report issued was for the year 2010, and it was unqualified, i.e., all systems were evaluated with no material problems found.

During each year, Afilias monitors the key controls related to the SSAE controls. Changes or additions to the control objectives or activities can result due to deployment of new services, software enhancements, infrastructure changes or process enhancements. These are noted and after internal review and approval, adjustments are made for the next review.

In addition to the PricewaterhouseCoopers engagement, Afilias performs internal security audits twice a year. These assessments are constantly being expanded based on risk assessments and changes in business or technology.

Additionally, Afilias engages an independent third-party security organization, PivotPoint Security, to perform external vulnerability assessments and penetration tests on the sites hosting and managing the Registry infrastructure. These assessments are performed with major infrastructure changes, release of new services or major software enhancements. These independent assessments are performed at least annually. A report from a recent assessment is attached with our response to Evaluation Question #30b.

Afilias has engaged with security companies specializing in application and web security testing to ensure the security of web-based applications offered by Afilias, such as the Web Admin Tool (WAT) for registrars and registry operators.

Finally, Afilias has engaged IBM’s Security services division to perform ISO 27002 gap assessment studies so as to review alignment of Afilias’ procedures and policies with the ISO 27002 standard. Afilias has since made adjustments to its security procedures and policies based on the recommendations by IBM.

Special TLD Considerations
Afilias’ rigorous security practices are regularly reviewed; if there is a need to alter or augment procedures for this gTLD, they will be done so in a planned and deliberate manner.

Commitments to Registrant Protection
With over a decade of experience protecting domain registration data, Afilias understands registrant security concerns. Afilias supports a “thick” registry system in which data for all objects are stored in the registry database that is the centralized authoritative source of information. As an active member of IETF (Internet Engineering Task Force), ICANN’s SSAC (Security & Stability Advisory Committee), APWG (Anti-Phishing Working Group), MAAWG (Messaging Anti-Abuse Working Group), USENIX, and ISACA (Information Systems Audits and Controls Association), the Afilias team is highly attuned to the potential threats and leading tools and procedures for mitigating threats. As such, registrants should be confident that:
• Any confidential information stored within the registry will remain confidential;
• The interaction between their registrar and Afilias is secure;
• The Afilias DNS system will be reliable and accessible from any location;
• The registry system will abide by all polices, including those that address registrant data;
• Afilias will not introduce any features or implement technologies that compromise access to the registry system or that compromise registrant security.

Afilias has directly contributed to the development of the documents listed below and we have implemented them where appropriate. All of these have helped improve registrants’ ability to protect their domains name(s) during the domain name lifecycle.
• [SAC049]: SSAC Report on DNS Zone Risk Assessment and Management (03 June 2011)
• [SAC044]: A Registrantʹs Guide to Protecting Domain Name Registration Accounts (05 November 2010)
• [SAC040]: Measures to Protect Domain Registration Services Against Exploitation or Misuse (19 August 2009)
• [SAC028]: SSAC Advisory on Registrar Impersonation Phishing Attacks (26 May 2008)
• [SAC024]: Report on Domain Name Front Running (February 2008)
• [SAC022]: Domain Name Front Running (SAC022, SAC024) (20 October 2007)
• [SAC011]: Problems caused by the non-renewal of a domain name associated with a DNS Name Server (7 July 2006)
• [SAC010]: Renewal Considerations for Domain Name Registrants (29 June 2006)
• [SAC007]: Domain Name Hijacking Report (SAC007) (12 July 2005)

To protect any unauthorized modification of registrant data, Afilias mandates TLS⁄SSL transport (per RFC 5246) and authentication methodologies for access to the registry applications. Authorized registrars are required to supply a list of specific individuals (five to ten people) who are authorized to contact the registry. Each such individual is assigned a pass phrase. Any support requests made by an authorized registrar to registry customer service are authenticated by registry customer service. All failed authentications are logged and reviewed regularly for potential malicious activity. This prevents unauthorized changes or access to registrant data by individuals posing to be registrars or their authorized contacts.

These items reflect an understanding of the importance of balancing data privacy and access for registrants, both individually and as a collective, worldwide user base.

The Afilias 24x7 Customer Service Center consists of highly trained staff who collectively are proficient in 15 languages, and who are capable of responding to queries from registrants whose domain name security has been compromised – for example, a victim of domain name hijacking. Afilias provides specialized registrant assistance guides, including specific hand-holding and follow-through in these kinds of commonly occurring circumstances.

Security Resourcing Plans
Please refer to our response to Evaluation Question #30b for security resourcing plans.

Amitabh Singhal	Assistant Secretary
Arthur Reilly	Director
Erik Huizer	Vice Chair
Maarten Botterman	Chair
Raimundo Beca	Director

Brian Cute	CEO
David Maher	General Counsel
Lance Wolak	Vice President
Larry Martin	Vice President

New gTLD Application Submitted to ICANN by: Public Interest Registry

String: संगठन

Originally Posted: 13 June 2012

Application ID: 1-910-41904

Applicant Information

1. Full legal name

2. Address of the principal place of business

3. Phone number

4. Fax number

5. If applicable, website or URL

Primary Contact

6(a). Name

6(b). Title

6(c). Address

6(d). Phone Number

6(e). Fax Number

6(f). Email Address

Secondary Contact

7(a). Name

7(b). Title

7(c). Address

7(d). Phone Number

7(e). Fax Number

7(f). Email Address

Proof of Legal Establishment

8(a). Legal form of the Applicant

8(b). State the specific national or other jursidiction that defines the type of entity identified in 8(a).

8(c). Attach evidence of the applicant's establishment.

9(a). If applying company is publicly traded, provide the exchange and symbol.

9(b). If the applying entity is a subsidiary, provide the parent company.

9(c). If the applying entity is a joint venture, list all joint venture partners.

Applicant Background

11(a). Name(s) and position(s) of all directors

11(b). Name(s) and position(s) of all officers and partners

11(c). Name(s) and position(s) of all shareholders holding at least 15% of shares

11(d). For an applying entity that does not have directors, officers, partners, or shareholders: Name(s) and position(s) of all individuals having legal or executive responsibility

Applied-for gTLD string

13. Provide the applied-for gTLD string. If an IDN, provide the U-label.

14(a). If an IDN, provide the A-label (beginning with "xn--").

14(b). If an IDN, provide the meaning or restatement of the string in English, that is, a description of the literal meaning of the string in the opinion of the applicant.

14(c). If an IDN, provide the language of the label (in English).

14(c). If an IDN, provide the language of the label (as referenced by ISO-639-1).

14(d). If an IDN, provide the script of the label (in English).

14(d). If an IDN, provide the script of the label (as referenced by ISO 15924).

14(e). If an IDN, list all code points contained in the U-label according to Unicode form.

15(a). If an IDN, Attach IDN Tables for the proposed registry.

15(b). Describe the process used for development of the IDN tables submitted, including consultations and sources used.

15(c). List any variant strings to the applied-for gTLD string according to the relevant IDN tables.

16. Describe the applicant's efforts to ensure that there are no known operational or rendering problems concerning the applied-for gTLD string. If such issues are known, describe steps that will be taken to mitigate these issues in software and other applications.

17. (OPTIONAL) Provide a representation of the label according to the International Phonetic Alphabet (http://www.langsci.ucl.ac.uk/ipa/).

Mission/Purpose

18(a). Describe the mission/purpose of your proposed gTLD.

18(b). How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

18(c). What operating rules will you adopt to eliminate or minimize social costs?

Community-based Designation

19. Is the application for a community-based TLD?

20(a). Provide the name and full description of the community that the applicant is committing to serve.

20(b). Explain the applicant's relationship to the community identified in 20(a).

20(c). Provide a description of the community-based purpose of the applied-for gTLD.

20(d). Explain the relationship between the applied-for gTLD string and the community identified in 20(a).

20(e). Provide a description of the applicant's intended registration policies in support of the community-based purpose of the applied-for gTLD.

20(f). Attach any written endorsements from institutions/groups representative of the community identified in 20(a).

Geographic Names

21(a). Is the application for a geographic name?

Protection of Geographic Names

22. Describe proposed measures for protection of geographic names at the second and other levels in the applied-for gTLD.

Registry Services

23. Provide name and full description of all the Registry Services to be provided.

Demonstration of Technical & Operational Capability

24. Shared Registration System (SRS) Performance

25. Extensible Provisioning Protocol (EPP)

26. Whois

27. Registration Life Cycle

28. Abuse Prevention and Mitigation

29. Rights Protection Mechanisms

30(a). Security Policy: Summary of the security policy for the proposed registry

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