ICANN New gTLD Application

New gTLD Application Submitted to ICANN by: Stable Tone Limited

String: 健康

Originally Posted: 13 June 2012

Application ID: 1-1708-88054


Applicant Information


1. Full legal name

Stable Tone Limited

2. Address of the principal place of business

Unit 10-18, 32⁄F, Tower 1, Millennium City 1
388 Kwun Tong Road, Kwun Tong
Hong Kong Kowloon
HK

3. Phone number

+85 2 2824 8694

4. Fax number

+85 2 3972 2211

5. If applicable, website or URL


Primary Contact


6(a). Name

Mike Rodenbaugh

6(b). Title

Founder - Rodenbaugh Law

6(c). Address


6(d). Phone Number

+01 415 738 8087

6(e). Fax Number

+01 415 738 8087

6(f). Email Address

stabletonetld@rodenbaugh.com

Secondary Contact


7(a). Name

Qiang Jason Du

7(b). Title

Director

7(c). Address


7(d). Phone Number

+85 2 2824 8694

7(e). Fax Number

+85 2 3972 2211

7(f). Email Address

jasonscdu@aol.com

Proof of Legal Establishment


8(a). Legal form of the Applicant

Limited Company

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

incorporated in Hong Kong under the Companies Ordinance (Chapter 32)

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

Attachments are not displayed on this form.

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

Qiang Jason DuDirector
Yang YuehuaDirector

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

Qiang Jason DuDirector
Yang YuehuaDirector

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.

健康

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

xn--nyqy26a

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.

healthy

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

Chinese

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

zh

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

Hans

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

Han (simplified variant)

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

U+5065 U+5EB7

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

Attachments are not displayed on this form.

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

This character repertoire was derived from the following sources:

-	Registration and Administration Guidelines for Chinese Domain Names http:⁄⁄www.ietf.org⁄rfc⁄rfc4713.txt
-	http:⁄⁄www.iana.org⁄domains⁄idn-tables⁄tables⁄cn_zh-cn_4.0.html 
-	http:⁄⁄www.iana.org⁄domains⁄idn-tables⁄tables⁄tw_zh-tw_4.0.1.html 

Neustar would like to thank CNNIC and TWNIC for making their language tables available on the IANA Repository of TLD IDN Practices.

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

Please see attachment.

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.

Stable Tone Limited foresees no known rendering issues in connection with the proposed .健康 string which it is seeking to apply for as a TLD.  This answer is based upon consultation with Stable Tone Limited’s preferred backend provider, Neustar, which has successfully launched a number of new TLDs over the last decade.  In reaching this determination, the following data points were analyzed:

- ICANN’s Security Stability Advisory Committee (SSAC) entitled Alternative TLD Name Systems and Roots: Conflict, Control and - IAB - RFC3696 “Application Techniques for Checking and Transformation of Names”

- Known software issues which Neustar has encountered during the last decade launching new TLDs;

-  Character type and length;

-  ICANN supplemental notes to Question 16; and

-  ICANN’s presentation during its Costa Rica regional meeting on TLD Universal Acceptance.


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

ʨiɛn(51) kʻɑŋ(55)

Mission/Purpose


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

(a) Stable Tone Limited is applying to become an ICANN accredited Top Level Domain (TLD) registry for the .健康TLD (.jiankang).  The .健康TLD is intended to benefit Chinese-speaking internet users by providing a designated and focused namespace for individuals and entities interested in issues related to healthy lifestyles, products and services. The Chinese letters “健康 “translate to ‘healthy’ in English, and are pronounced roughly “Jian-Kang”. The .jiankang TLD is targeted primarily at potential registrants and Internet users in Mainland China, therefore most of the registrations will be in the Chinese language and Simplified Chinese characters. Stable Tone will allow English language second level registrations, though these are seen to constitute a minority of the domains under management (DUM).  Stable Tone will enable registration of secondary level Chinese IDN names in .健康TLD and English language ASCII names, by individuals as well as organizations who would like to provide goods and services as well as information related to healthy lifestyles, products and services. The target market is wellness care, leisure care, fitness and sports, healthy food and drink companies.  The channel to market is through a specialized sales team that will work with accredited registrars with specific emphasis on the .jiankang (healthy) themed market.

The concept of healthy lifestyle has been intertwined with Chinese culture for thousands of years. Healthy and wellness practices such as dietary therapy, acupuncture, herbal medicine and teas, exercise such as Tai Chi and Qui Gong, and massage such as Tui Na have been a mainstay of Chinese culture and lifestyle for several thousand years. Even though, with a median age of 35.5, the average Chinese is considered somewhat young, interest in and consistent practice of at least one of these healthy lifestyle concepts is widespread.(Source: http:⁄⁄www.indexmundi.com⁄china⁄median_age.html)

The Chinese internet users have increased in dramatic numbers, from 22.5M in 2000 to 513.1M in 2012 (Source: http:⁄⁄www.internetworldstats.com⁄top20.htm and http:⁄⁄www.cnnic.net.cn⁄en⁄index⁄0O⁄index.htm). Yet there are only 11.21M domain names and only 2.79M websites to address any and all types of content (Source: http:⁄⁄www.cnnic.net.cn⁄en⁄index⁄0O⁄index.htm). CNNIC has recently announced policies to expand the use of Chinese IDNs. The Company sees this as an encouraging sign that the Chinese IDN market is a growing opportunity.



Given the growing internet user base and the lack of any designated and focused TLD targeted at the healthy lifestyle interest, the .健康TLD (.jiankang) is intended to fill a market gap and provide not only a focused and designated TLD, but also an innovative and intuitive address in the Chinese language and script.

The .健康TLD is also envisioned to be a premium Internet space, under control of Stable Tone, to allow the distribution and exchange of information, products and services relevant to healthy lifestyle, by means of, but not limited to, websites, social networks, email and other technologies that will reside within the .健康TLD (.jiankang) domain name space. In addition, ancillary services may be provided in relation to registration of domains within the TLD, including, but not limited to, website hosting, SEO, marketing and consulting services. Stable Tone will take both technical as well as policy measures to differentiate and distinguish .健康TLD (.jiankang) from other TLDs rife with abusive domains which seek to misguide and defraud the consumer. The lack of monitoring and abuse mitigation has led to a plethora of websites with fraudulent, unhealthy, even dangerous products and information.

Stable Tone is founded by Jason Du, who serves as CEO and Chairman. Mr. Du has more than 14 years of technical and managerial experience in Internet businesses. He is joined by a distinguished set of executives with proven track records of establishing successful Internet businesses both in China and in the USA.

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

(b) The .健康TLD (.jiankang) is intended to benefit Chinese-speaking internet users by enabling such persons, entities and organizations to communicate more easily and effectively with each other and with all internet users about personal healthy lifestyles.  Internet users will benefit from a more distinctive and trustworthy Internet experience in dealing with .健康 domain registrants and users.  Today, there is no particular top-level domain space devoted to personal healthy lifestyle issues, in any language.  Instead, relevant content is dispersed among a variety of the existing gTLDs and ccTLDs without any consistency. This presents two problems.  The prospective registrants (individuals, companies and entities in the wellness  care, leisure care, fitness and sports, healthy food and drink, etc. market) have but a limited choice of TLDs to register in. Furthermore, since the choices of TLDs are limited, they are unable to rely on an intuitive and in-language address, hence they are forced to compete for a very targeted audience with a number of other entities representing any and all content.  Introducing a targeted and intuitive TLD focused on healthy lifestyles, products and services, will not only prove to be innovative, but it will also help the average internet end-user to have choices other than paid-for search to find the content they seek.

(i) What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?

Stable Tone intends to provide a distinctive and Intuitive TLD for Chinese-speaking individuals, entities and organizations to communicate and provide content and products relating to healthy lifestyles, products and services. Concern with and an interest in healthy lifestyle, products and services is an almost universal phenomenon, across many demographics. These individuals or Internet users will benefit from an easy and intuitive way to find the content they are looking for. In addition, other individuals, as well as companies and organizations with information, products or services related to healthy lifestyles, products and services would benefit from registering and using the .健康domain to differentiate and distinguish their site or business. There are virtually no existing gTLDs in any character script other than ASCII. Stable Tone seeks to make .健康 domain names familiar to Chinese-speaking people, entities and organizations as a TLD focused on quality content, and thus make the .健康TLD (.jiankang) valuable to companies, entities and individuals who have or plan to provide information, goods or services related to healthy lifestyles, products and services. Stable Tone will do this by actively marketing the TLD as a premium and recognized platform for registrants to express themselves online.

In order to achieve this goal, Stable Tone intends to provide a trusted and secure domain space, with industry standard service levels. Stable Tone has chosen Neustar as its back-end registry services provider, with the expectation that Neustar will deliver world class service to Stable Tone and to all .健康 domain registrants and users. Stable Tone also intends to implement an Acceptable Use Policy designed to set and maintain expectations with the registrants to ensure the namespace maintains its focus on quality content related to healthy lifestyles, products and services.

(ii) What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

This TLD will provide an alternative to the current TLDs, which are, for the most part, ASCII and very generic (ex: .com or .cn). The .健康TLD (.jiankang) is focused on the general topic of healthy lifestyles, products and services, and would cater specifically to the Chinese speaking population, specifically mainland Chinese who use Simplified Chinese characters. The TLD will automatically be differentiated from the current choices, as a distinctive name space that simplifies users’ choice to interact with individuals, entities and organizations that wish to communicate about topics of healthy lifestyles, products and services.

Stable Tone expects that many users will be able to directly navigate to intuitive .健康domains and subdomains, saving time and resources from first accessing a search engine.

The registration and use of domains within the .健康TLD (.jiankang) will provide stark differentiation from existing competition because Stable Tone intends to focus on premium domains at premium pricing. This model may provide valuable experience for other existing and future registries in pricing their domains. Either way, the model proposed for .健康TLD (.jiankang) marketing and sales will help fulfill one of ICANN’s purposes for the new gTLD program, namely to bring more innovation and experimentation in the domain industry, towards the goal of serving internet users better.

Today, it is often difficult to find a relevant and easily available domain name from existing registration providers. The .健康TLD (.jiankang) will allow people and entities with an interest in communicating about healthy lifestyle, products and services to innovate, and to create many uses for domain names which, with today’s restrictions on the availability of domain names, are too complicated.

(iii) What goals does your proposed gTLD have in terms of user experience?

The .健康TLD (.jiankang) is supported by leading-edge technologies such as DNSSEC, and internationalized Whois, not to mention a reliable and scalable registration and resolution infrastructure provided by Neustar. In addition, policies such as the Acceptable Use Policy, as well as the registry’s business model and processes which rely on a dedicated sales force to sell the secondary domain names and use the registrars for provisioning, all ensure a curated, trustworthy and positive user experience. Stable Tone will promote the .健康TLD (.jiankang) online infrastructure and services to encourage Chinese-speaking Internet users to become aware of the .健康TLD (.jiankang) and to then prefer to interact online with each other regarding issues of healthy lifestyles, products and services, using this TLD above all others.

More specifically, Stable Tone intends for users to perceive the TLD as a trustworthy indicator of the source of online information, goods and services relevant to healthy lifestyles, products and services. Stable Tone intends to provide a safe and legitimate Internet space, enhancing user experience by mitigating security-associated risks, as further described in response to Questions 26, 28 and 29.

In addition, the .健康TLD (.jiankang) will provide an easily recognizable, navigable and predictable domain name space. For example, there will be secondary domain names in Simplified Chinese characters such as “geographicnames.健康” for localized websites, and “product.健康” for websites related to products relevant to healthy lifestyle, products and services. All of this will lessen users’ confusion when interacting online.

(iv) Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.

The .健康TLD (.jiankang) will be open and unrestricted, allowing anyone to select an appropriate .健康 domain name for their own legitimate purposes.

Reserved Names:

However, Stable Tone recognizes both the ICANN requirement and domain industry practice of reserving (preventing) the registrations of selected strings and intends to comply pursuant to the following Reserved Names and Dispute Resolution Mechanism policies.

In .健康TLD (.jiankang) we will reserve the following classes of domain names, which will not be available to register via the Sunrise or subsequent periods:

- The reserved names required in Specification 5 of the new gTLD Registry Agreement.

- The geographic names required in Specification 5 of the new gTLD Registry Agreement, and as described in Question 21 and Question 22 (“Protection of Geographic Names”).

- The registry operator will reserve its own name and variations thereof, and registry operations names (such as nic.健康, registry.健康TLD etc. These may be reserved in both Simplified Chinese script and in English (ASCII). This has been a standard practice in ICANN’s past gTLDs.

-Stable Tone will also reserve names related to ICANN and Internet standards bodies (ex: iana.健康TLD, etc.).

Stable Tone does intend to set aside some generic names relevant to healthy lifestyle, products and services market in both Chinese IDN and English (ASCII) second level. However, since the business model for this TLD already calls for secondary names to be sold at a high price, Stable Tone has kept any financial projections related to Premium Names to zero.

Dispute Resolution Mechanisms:
Trademark rights holders will have access to several dispute mechanisms. These are fair and transparent processes to adjudicate claims to domain names, such as:

- Stable Tone will operate a Sunrise Dispute Policy to provide special protection of qualified trademark rights. Additional details on this process can be found in Question 29.

- The ICANN required Uniform Dispute Resolution Policy (UDRP) will apply to .健康TLD. Please note details in question 29.

- .健康TLD domains will also be subject to the Universal Rapid Suspension (URS) policy. We detail our implementation of the URS in question 29.

- Stable Tone will also comply with ICANN’s Registrar Transfer Dispute Resolutions Policy (http:⁄⁄www.icann.org⁄en⁄transfers⁄dispute-policy-12jul04.htm ). Our technical and operational services are designed to support this dispute mechanism.

Regular Sunrise Period Use of Trademark Claims Services System:
Stable Tone will initiate a Sunrise period of 30 days to allow trademark rights holders to obtain their desired names. However since the .健康TLD is envisioned as a very small and exclusive TLD, the volume at sunrise will be very small.

Stable Tone will also use the Trademark Clearing House services for the duration of Sunrise and will comply with all ICANN related policies.
Other:

Stable Tone will also employ Abuse mitigation and detection technologies and policies to mitigate abusive and fraudulent uses of the .健康TLD . Stable Tone will also implement an Acceptable Use Policy as further described in response to Question 28. Please see additional detail in responses Questions 26, 28 and 29.

(v) Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users? If so, please describe any such measures.

Stable Tone intends for users to perceive the TLD as a trustworthy indicator of the source of online information, products and services. User trust is enhanced when users are confident that their private or confidential information is securely protected. Stable Tone intends to provide a safe and legitimate Internet space, enhancing user experience by mitigating security-associated risks. With respect to WHOIS data, Stable Tone intends to comply with ICANN policies and otherwise to ensure that complete and accurate WHOIS information is readily accessible for every .健康TLD (.jiankang) domain name.

Stable Tone intends to deploy DNSSEC and to comply with all of the other policies and practices required by ICANN in the Registry Agreement and⁄or via any Consensus Policy. And of course, Stable Tone complies with all applicable laws and regulations relating to Internet security and the privacy of users’ confidential information. Furthermore, Stable Tone already employs commercially reasonable practices with respect to the security of online transactions and users’ private or confidential information.

Stable Tone reserves the right to manually verify the WHOIS information of every applicant for any domain name, at any time in its discretion.

(vi) Describe whether and in what ways outreach and communications will help to achieve your projected benefits.

Use of domains in the .健康TLD (.jiankang) will serve as a visible indication of the type of content, namely information, goods and services related to healthy lifestyles, products and services. For example, a user who first sees an advertisement for “productname.健康” may later directly navigate to “company.健康” to search for other products of the producer. Besides, Stable Tone plans its own specific efforts to communicate .健康TLD (.jiankang) to its intended audience. As one of the first Chinese-language IDN gTLDs, Stable Tone expects a substantial degree of publicity and word-of-mouth marketing within the Chinese-speaking community.

In sum, outreach and communication are important in order to achieve the projected benefits of the TLD, but also will be inherent via use of the TLD, and further will be enhanced by the viral nature of communications about the TLD and individuals and entities who use健康TLD (.jiankang) domains. There will be many other new gTLDs presented to internet users, including a number of other Chinese-language IDN gTLDs, it is expected that the outreach, communications and media relating to each of them, individually, will lead to collective benefit insofar as many internet users will quickly grasp the concept behind these TLDs, and will expect many companies to operate them in generally consistent ways.

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

(c) The .健康TLD (.jiankang)  is supported by leading-edge technologies such as DNSSEC, and internationalized Whois, not to mention a reliable and scalable registration and resolution infrastructure provided by Neustar.  In addition, policies such as the Acceptable Use Policy, as well as the registry’s business model and processes which rely on a dedicated sales force to sell the secondary domain names and use the registrars for provisioning, all ensure a curated, trustworthy and positive user experience.  

In general, Stable Tone intends for users to perceive the TLD as a trustworthy and intuitive indicator of online information and services relevant to the general topic of healthy lifestyles, products and services. Stable Tone intends to provide a safe and trustworthy Internet space, enhancing user experience by mitigating security-associated risks. Precise details are set forth in answers to Questions 26, 28 and 29.

In addition, the TLD will provide an easily navigable and predictable domain name space. For example, “geographicnames.健康” for localized websites, and “product.健康” for websites related to products relevant to healthy lifestyles, products and services. All of this will lessen users’ confusion when interacting online.

(i) How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first-serve basis?

Stable Tone will offer a phased launch, consistent with many prior gTLD domain name launches. First, a 30-daySunrise Period will be offered as required by ICANN, for trademark holders to register domain names that correspond to their marks. Stable Tone plans to use the Trademark Clearing House during the Sunrise Phase. If there is more than one qualified Sunrise applicant, then they will be invited to participate in an auction to select the registrant of the contested name. After the close of the Sunrise Period, Stable Tone will conduct a Premium Name Availability Period, accepting applications for registrations of any available .健康 domain names. In the event of more than one applicant contending for any domain during this Period, all such applicants will be invited to participate in an auction to select the registrant of the contested name. After the Premium Name Availability Period, Stable Tone will initiate the General Availability phase, where all names become generally available for open registration by any interested person or entity, on a first-come⁄first-served basis.

(ii) Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).

(iii) Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation?

Stable Tone intends to promote early adoption of the .健康TLD (.jiankang) by initially offering substantial discounts for multi-year registrations and for purchase of multiple domain registrations. Ultimately, this promotional pricing would provide a registrant who chooses a multi-year registration a lower effective price for the second and successive years, when paid in advance. A registrant who chooses to register multiple domain names at one time will receive a discount on the second and successive registrations made at the same time. It may be possible to combine both discounts for greater savings.

Additionally, promotional pricing programs would provide registrants who choose to spend extra effort and budget in promoting the .健康TLD (.jiankang) potential for additional discounts from Stable Tone. These types of promotions may last more than 5 years. Stable Tone is aware that it may need to spend many years’ efforts educating the Chinese internet population, creating the awareness of the .健康TLD (.jiankang) and ultimately convincing the Internet users to prefer the .健康TLD address search or to other TLDs when looking for healthy lifestyle, products and services related websites. In addition, Stable Tone is also aware that it may take several years to convince a critical mass of healthy lifestyle, products and services target registrant market to adopt the .健康TLD and build high profile content associated with it. In fact, although it is counter-intuitive, it may take a number of years for Chinese users to get used to Chinese gTLDs, since they have never had much choice other than ASCII TLDs.

Stable Tone also intends to make clear contractual commitments to registrants regarding the magnitude of price escalation upon renewal. This will be clearly stated in Registry-Registrar Agreement, requiring registrars to include this commitment in all .健康 Domain Name Registration Agreements. Stable Tone will take risks in pioneering innovative pricing for premium IDN domains for Chinese speaking people. The price escalation or fluctuation may be higher than generic and ASCII new gTLDs, since there are many precedents for pricing in those categories.

Community-based Designation


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

No

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).

Attachments are not displayed on this form.

Geographic Names


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

No

Protection of Geographic Names


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

We have engaged Neustar, Inc. to deliver registry services for this TLD.

This response describes protection of geographic names as implemented in the managed TLD registry service.

1. PROTECTION OF GEOGRAPHIC NAMES

a. Initial Reservation

Stable Tone Limited is committed to complying with all of its obligations under the Registry Agreement and as such will meet its obligations to initially reserve all of the enumerated geographic names. More specifically, in accordance with Specification 5 of the Registry Agreement, the Registry Operator will initially reserve all geographic names at the second level and at all other levels within the TLD at which the Registry Operator provides for registrations.

The Company will support this requirement by using the following internationally recognized lists to develop a comprehensive master list of all geographic names that will be initially reserved:

-The 2-letter alpha-2 code of all country and territory names contained on the ISO 3166-1 list, including all reserved and unassigned codes [http:⁄⁄www.iso.org⁄iso⁄support⁄country_codes⁄iso_3166_code_lists⁄iso-31661_ decoding_table.htm];

-The short form (in English) of all country and territory names contained on the ISO 3166-1 list, including the European Union, which is exceptionally reserved on the ISO 3166-1 List, and its scope extended in August 1999 to any application needing to represent the name European Union [http:⁄⁄www.iso.org⁄iso⁄support⁄country_codes⁄iso_3166_code_lists⁄iso-31661_ decoding_table.htm#EU];

-The United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardization of Geographical Names, Part III Names of Countries of the World. This lists the names of 193 independent States generally recognized by the international community in the language or languages used in an official capacity within each country and is current as of August 2006 [http:⁄⁄unstats.un.org⁄unsd⁄geoinfo⁄ungegn%20tech%20ref%20manual_M87_combined.pdf]; and

-The list of UN member states in 6 official UN languages prepared by the Working Group on Country Names of the United Nations Conference on the standardization of Geographical Names [http:⁄⁄unstats.un.org⁄unsd⁄geoinfo⁄UNGEGN⁄docs⁄9th-uncsgndocs⁄econf⁄9th_UNCSGN_e-conf-98-89-add1.pdf]

b. Release Mechanism
Notwithstanding the above, Stable Tone Limited believes that the use of geographic designations in connection with .jiankang will significantly benefit Stable Tone Limited’s customers, end users, partners and the global Internet community in that it will assist them in locating Stable Tone Limited’s content by physical geography. Given the goodwill of the Company itself, there is little likelihood of confusion between the second-level geographic registration and the country or country-code designation. For example, few consumers would be confused that us.jiankang is associated with the country-code TLD of the United States administered by the United States Department of Commerce. Therefore, although the geographic names will initially be reserved, Stable Tone Limited does believe that at the appropriate time, certain geographic names should be able to be released from reservation.

This is especially true of the two character second level domain names. Stable Tone Limited recognizes that there have been several successful and non-misleading use of two character second level names by TLD operators such as AA.com, ge.com, and my.biz, to name a few. In the event that Stable Tone Limited wishes to use the two-character strings, or any other geographically reserved names, for its own purposes related to the mission of the TLD, Stable Tone Limited shall propose to ICANN the release of such strings in accord with the Registry Agreement.

Registry Services


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

Stable Tone Limited has elected to partner with Neustar, Inc. to provide back-end services for the .jiankang registry. In making this decision, Stable Tone Limited recognized that Neustar already possesses a production-proven registry system that can be quickly deployed and smoothly operated over its robust, flexible, and scalable world-class infrastructure. The existing registry services will be leveraged for the .jiankang registry. The following section describes the registry services to be provided.

23.2 Standard Technical and Business Components
Neustar will provide the highest level of service while delivering a secure, stable and comprehensive registry platform. Stable Tone Limited will use Neustar’s Registry Services platform to deploy the .jiankang registry, by providing the following Registry Services (none of these services are offered in a manner that is unique to .jiankang:
- Registry-Registrar Shared Registration Service (SRS)
- Extensible Provisioning Protocol (EPP)
- Domain Name System (DNS)
- WHOIS
- DNSSEC
- Data Escrow
- Dissemination of Zone Files using Dynamic Updates
- Access to Bulk Zone Files
- Dynamic WHOIS Updates
- IPv6 Support
- Rights Protection Mechanisms

The following is a description of each of the services.

SRS
Neustar’s secure and stable SRS is a production-proven, standards-based, highly reliable, and high-performance domain name registration and management system. The SRS includes an EPP interface for receiving data from registrars for the purpose of provisioning and managing domain names and name servers. The response to Question 24 provides specific SRS information.

EPP
The .jiankang registry will use the Extensible Provisioning Protocol (EPP) for the provisioning of domain names. The EPP implementation will be fully compliant with all RFCs. Registrars are provided with access via an EPP API and an EPP based Web GUI. With more than 10 gTLD, ccTLD, and private TLD implementations, Neustar has extensive experience building EPP-based registries. Additional discussion on the EPP approach is presented in the response to Question 25.

DNS
Stable Tone Limited will leverage Neustar’s world-class DNS network of geographically distributed nameserver sites to provide the highest level of DNS service. The service utilizes “Anycast” routing technology, and supports both IPv4 and IPv6. The DNS network is highly proven, and currently provides service to over 20 TLDs and thousands of enterprise companies. Additional information on the DNS solution is presented in the response to Questions 35.

WHOIS
Neustar’s existing standard WHOIS solution will be used for .jiankang. The service provides supports for near real-time dynamic updates. The design and construction is agnostic with regard to data display policy is flexible enough to accommodate any data model. In addition, a searchable WHOIS service that complies with all ICANN requirements will be provided. The following WHOIS options will be provided:
Standard WHOIS (Port 43)
Standard WHOIS (Web)
Searchable WHOIS (Web)

DNSSEC
An RFC compliant DNSSEC implementation will be provided using existing DNSSEC capabilities. Neustar is an experienced provider of DNSSEC services, and currently manages signed zones for three large top level domains: .biz, .us, and .co. Registrars are provided with the ability to submit and manage DNS records using EPP, or through a web GUI. Additional information on DNSSEC, including the management of security extensions is found in the response to Question 43.

Data Escrow
Data escrow will be performed in compliance with all ICANN requirements in conjunction with an approved data escrow provider. The data escrow service will:
- Protect against data loss
- Follow industry best practices
- Ensure easy, accurate, and timely retrieval and restore capability in the event of a hardware failure
- Minimizes the impact of software or business failure.

Additional information on the Data Escrow service is provided in the response to Question 38.

Dissemination of Zone Files using Dynamic Updates
Dissemination of zone files will be provided through a dynamic, near real-time process. Updates will be performed within the specified performance levels. The proven technology ensures that updates pushed to all nodes within a few minutes of the changes being received by the SRS. Additional information on the DNS updates may be found in the response to Question 35.

Access to Bulk Zone Files
Stable Tone Limited will provide third party access to the bulk zone file in accordance with specification 4, Section 2 of the Registry Agreement. Credentialing and dissemination of the zone files will be facilitated through the Central Zone Data Access Provider.

Dynamic WHOIS Updates
Updates to records in the WHOIS database will be provided via dynamic, near real-time updates. Guaranteed delivery message oriented middleware is used to ensure each individual WHOIS server is refreshed with dynamic updates. This component ensures that all WHOIS servers are kept current as changes occur in the SRS, while also decoupling WHOIS from the SRS. Additional information on WHOIS updates is presented in response to Question 26.

IPv6 Support
The .jiankang registry will provide IPv6 support in the following registry services: SRS, WHOIS, and DNS⁄DNSSEC. In addition, the registry supports the provisioning of IPv6 AAAA records. A detailed description on IPv6 is presented in the response to Question 36.

Required Rights Protection Mechanisms
Stable Tone Limited, will provide all ICANN required Rights Protection Mechanisms, including:
- Trademark Claims Service
- Trademark Post-Delegation Dispute Resolution Procedure (PDDRP)
- Registration Restriction Dispute Resolution Procedure (RRDRP)
- UDRP
- URS
- Sunrise service

More information is presented in the response to Question 29.

Internationalized Domain Names (IDN)
IDN registrations are provided in full compliance with the IDNA protocol. Neustar possesses extensive experience offering IDN registrations in numerous TLDs, and its IDN implementation uses advanced technology to accommodate the unique bundling needs of certain languages. Character mappings are easily constructed to block out characters that may be deemed as confusing to users. A detailed description of the IDN implementation is presented in response to Question 44.


23.3 Unique Services
Stable Tone Limited will not be offering Registry Services, as defined in the Registry Agreement, that are unique to .jiankang.


23.4 Security or Stability Concerns
All services offered are standard registry services that have no known security or stability concerns. Neustar has demonstrated a strong track record of security and stability within the industry.

Demonstration of Technical & Operational Capability


24. Shared Registration System (SRS) Performance

24.1 Introduction

Stable Tone Limited has partnered with Neustar, Inc., an experienced TLD registry operator, for the operation of the .jiankang Registry. The applicant is confident that the plan in place for the operation of a robust and reliable Shared Registration System (SRS) as currently provided by Neustar will satisfy the criterion established by ICANN.

Neustar built its SRS from the ground up as an EPP based platform and has been operating it reliably and at scale since 2001. The software currently provides registry services to five TLDs (.BIZ, .US, TEL, .CO and .TRAVEL) and is used to provide gateway services to the .CN and .TW registries. Neustar’s state of the art registry has a proven track record of being secure, stable, and robust. It manages more than 6 million domains, and has over 300 registrars connected today.

The following describes a detailed plan for a robust and reliable SRS that meets all ICANN requirements including compliance with Specifications 6 and 10.


24.2 The Plan for Operation of a Robust and Reliable SRS

High-level SRS System Description
The SRS to be used for .jiankang will leverage a production-proven, standards-based, highly reliable and high-performance domain name registration and management system that fully meets or exceeds the requirements as identified in the Applicant Guidebook.

The SRS is the central component of any registry implementation and its quality, reliability and capabilities are essential to the overall stability of the TLD. Neustar has a documented history of deploying SRS implementations with proven and verifiable performance, reliability and availability. The SRS adheres to all industry standards and protocols. By leveraging an existing SRS platform, Stable Tone Limited is mitigating the significant risks and costs associated with the development of a new system. Highlights of the SRS include:
- State-of-the-art, production proven multi-layer design
- Ability to rapidly and easily scale from low to high volume as a TLD grows
- Fully redundant architecture at two sites
- Support for IDN registrations in compliance with all standards
- Use by over 300 Registrars
- EPP connectivity over IPv6
- Performance being measured using 100% of all production transactions (not sampling)

SRS Systems, Software, Hardware, and Interoperability
The systems and software that the registry operates are a critical element to providing a high quality of service. Neustar has a decade of experience operating registry infrastructure to extremely high service level requirements. The infrastructure is designed using best of breed systems and software. Much of the application software that performs registry-specific operations was developed by the current engineering team and as a result the team is intimately familiar with its operations.

The architecture is highly scalable and provides the same high level of availability and performance as volumes increase. It combines load balancing technology with scalable server technology to provide a cost effective and efficient method for scaling.

The Registry is able to limit the ability of any one registrar from adversely impacting other registrars by consuming too many resources due to excessive EPP transactions. The system uses network layer 2 level packet shaping to limit the number of simultaneous connections registrars can open to the protocol layer.

All interaction with the Registry is recorded in log files. Log files are generated at each layer of the system. These log files record at a minimum:
- The IP address of the client
- Timestamp
- Transaction Details
- Processing Time.

In addition to logging of each and every transaction with the SRS, Neustar maintains audit records, in the database, of all transformational transactions. These audit records allow the Registry, in support of the applicant, to produce a complete history of changes for any domain name.

SRS Design
The SRS incorporates a multi-layer architecture that is designed to mitigate risks and easily scale as volumes increase. The three layers of the SRS are:
- Protocol Layer
- Business Policy Layer
- Database.

Each of the layers is described below.

Protocol Layer
The first layer is the protocol layer, which includes the EPP interface to registrars. It consists of a high availability farm of load-balanced EPP servers. The servers are designed to be fast processors of transactions. The servers perform basic validations and then feed information to the business policy engines as described below. The protocol layer is horizontally scalable as dictated by volume.

The EPP servers authenticate against a series of security controls before granting service, as follows:
- The registrar’s host exchanges keys to initiates a TLS handshake session with the EPP server.
- The registrar’s host must provide credentials to determine proper access levels.
- The registrar’s IP address must be preregistered in the network firewalls and traffic-shapers.

Business Policy Layer
The Business Policy Layer is the “brain” of the registry system. Within this layer, the policy engine servers perform rules-based processing as defined through configurable attributes. This process takes individual transactions, applies various validation and policy rules, parses data and dispatches notification through the central database in order to publish to various external systems. External systems fed by the Business Policy Layer include backend processes such as dynamic update of DNS, WHOIS and Billing.

Similar to the EPP protocol farm, the SRS consists of a farm of application servers within this layer. This design ensures that there is sufficient capacity to process every transaction in a manner that meets or exceeds all service level requirements. Some registries couple the business logic layer directly in the protocol layer or within the database. This architecture limits the ability to scale the registry. Using a decoupled architecture enables the load to be distributed among farms of inexpensive servers that can be scaled up or down as demand changes.

The SRS today processes over 30 million EPP transactions daily.

Database
The database is the third core component of the SRS. The primary function of the SRS database is to provide highly reliable, persistent storage for all registry information required for domain registration services. The database is highly secure, with access limited to transactions from authenticated registrars, trusted application-server processes, and highly restricted access by the registry database administrators. A full description of the database can be found in response to Question 33.
Figure 24-1 depicts the overall SRS architecture including network components.

Number of Servers
As depicted in the SRS architecture diagram referenced above, Neustar operates a high availability architecture where at each level of the stack there are no single points of failures. Each of the network level devices run with dual pairs as do the databases. For the .jiankang registry, the SRS will operate with 8 protocol servers and 6 policy engine servers. These expand horizontally as volume increases due to additional TLDs, increased load, and through organic growth. In addition to the SRS servers described above, there are multiple backend servers for services such as DNS and WHOIS. These are discussed in detail within those respective response sections.

Description of Interconnectivity with Other Registry Systems
The core SRS service interfaces with other external systems via Neustar’s external systems layer. The services that the SRS interfaces with include:
- WHOIS
- DNS
- Billing
- Data Warehouse (Reporting and Data Escrow).

Other external interfaces may be deployed to meet the unique needs of a TLD. At this time there are no additional interfaces planned for .jiankang.

The SRS includes an “external notifier” concept in its business policy engine as a message dispatcher. This design allows time-consuming backend processing to be decoupled from critical online registrar transactions. Using an external notifier solution, the registry can utilize “control levers” that allow it to tune or to disable processes to ensure optimal performance at all times. For example, during the early minutes of a TLD launch, when unusually high volumes of transactions are expected, the registry can elect to suspend processing of one or more back end systems in order to ensure that greater processing power is available to handle the increased load requirements. This proven architecture has been used with numerous TLD launches, some of which have involved the processing of over tens of millions of transactions in the opening hours. The following are the standard three external notifiers used by the SRS:

WHOIS External Notifier
The WHOIS external notifier dispatches a work item for any EPP transaction that may potentially have an impact on WHOIS. It is important to note that, while the WHOIS external notifier feeds the WHOIS system, it intentionally does not have visibility into the actual contents of the WHOIS system. The WHOIS external notifier serves just as a tool to send a signal to the WHOIS system that a change is ready to occur. The WHOIS system possesses the intelligence and data visibility to know exactly what needs to change in WHOIS. See response to Question 26 for greater detail.

DNS External Notifier
The DNS external notifier dispatches a work item for any EPP transaction that may potentially have an impact on DNS. Like the WHOIS external notifier, the DNS external notifier does not have visibility into the actual contents of the DNS zones. The work items that are generated by the notifier indicate to the dynamic DNS update sub-system that a change occurred that may impact DNS. That DNS system has the ability to decide what actual changes must be propagated out to the DNS constellation. See response to Question 35 for greater detail.

Billing External Notifier
The billing external notifier is responsible for sending all billable transactions to the downstream financial systems for billing and collection. This external notifier contains the necessary logic to determine what types of transactions are billable. The financial systems use this information to apply appropriate debits and credits based on registrar.

Data Warehouse
The data warehouse is responsible for managing reporting services, including registrar reports, business intelligence dashboards, and the processing of data escrow files. The Reporting Database is used to create both internal and external reports, primarily to support registrar billing and contractual reporting requirements. The data warehouse databases are updated on a daily basis with full copies of the production SRS data.

Frequency of Synchronization between Servers
The external notifiers discussed above perform updates in near real-time, well within the prescribed service level requirements. As transactions from registrars update the core SRS, update notifications are pushed to the external systems such as DNS and WHOIS. These updates are typically live in the external system within 2-3 minutes.

Synchronization Scheme (e.g., hot standby, cold standby)
Neustar operates two hot databases within the data center that is operating in primary mode. These two databases are kept in sync via synchronous replication. Additionally, there are two databases in the secondary data center. These databases are updated real time through asynchronous replication. This model allows for high performance while also ensuring protection of data. See response to Question 33 for greater detail.

Compliance with Specification 6 Section 1.2
The SRS implementation for .jiankang is fully compliant with Specification 6, including section 1.2. EPP Standards are described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. Extensible Provisioning Protocol or EPP is defined by a core set of RFCs that standardize the interface that make up the registry-registrar model. The SRS interface supports EPP 1.0 as defined in the following RFCs shown in Table 24-1.

Additional information on the EPP implementation and compliance with RFCs can be found in the response to Question 25.

Compliance with Specification 10
Specification 10 of the New TLD Agreement defines the performance specifications of the TLD, including service level requirements related to DNS, RDDS (WHOIS), and EPP. The requirements include both availability and transaction response time measurements. As an experienced registry operator, Neustar has a long and verified track record of providing registry services that consistently exceed the performance specifications stipulated in ICANN agreements. This same high level of service will be provided for the .jiankang Registry. The following section describes Neustar’s experience and its capabilities to meet the requirements in the Registry Agreement.

To properly measure the technical performance and progress of TLDs, Neustar collects data on key essential operating metrics. These measurements are key indicators of the performance and health of the registry. Neustar’s current .biz SLA commitments are among the most stringent in the industry today, and exceed the requirements for new TLDs. Table 24-2 compares the current SRS performance levels compared to the requirements for new TLDs, and clearly demonstrates the ability of the SRS to exceed those requirements.

Neustar’s ability to commit and meet such high performance standards is a direct result of their philosophy towards operational excellence. See response to Question 31 for a full description of their philosophy for building and managing for performance.


24.3 Resourcing Plans

The development, customization, and on-going support of the SRS are the responsibility of a combination of Neustar’s technical and operational teams, including:
- Development⁄Engineering
- Database Administration
- Systems Administration
- Network Engineering.

Additionally, if customization or modifications are required, then Neustar’s Product Management and Quality Assurance teams will be involved in the design and testing. Finally, Neustar’s Network Operations and Information Security play an important role in ensuring the systems involved are operating securely and reliably.

The necessary resources will be pulled from the pool of operational resources described in detail in the response to Question 31. Neustar’s SRS implementation is very mature, and has been in production for over 10 years. As such, very little new development related to the SRS will be required for the implementation of the .jiankang registry. The following resources are available from those teams:
- Development⁄Engineering – 19 employees
- Database Administration- 10 employees
- Systems Administration – 24 employees
- Network Engineering – 5 employees

The resources are more than adequate to support the SRS needs of all the TLDs operated by Neustar, including the .jiankang registry.

25. Extensible Provisioning Protocol (EPP)

25.1 Introduction

Stable Tone Limited’s back-end registry operator, Neustar, has over 10 years of experience operating EPP based registries. They deployed one of the first EPP registries in 2001 with the launch of .biz. In 2004, they were the first gTLD to implement EPP 1.0 and registrations of internationalized domain names (IDN). Over the last ten years Neustar has implemented numerous extensions to meet various unique TLD requirements. Neustar will leverage its extensive experience to ensure Stable Tone Limited is provided with an unparalleled EPP based registry. The following discussion explains the EPP interface which will be used for the .shijie registry. This interface exists within the protocol farm layer as described in Question 24 and is depicted in Figure 25-1.


25.2 EPP Interface

Registrars are provided with two different interfaces for interacting with the registry. Both are EPP based, and both contain all the functionality necessary to provision and manage domain names. The primary mechanism is an EPP interface to connect directly with the registry. This is the interface registrars will use for most of their interactions with the registry.

However, an alternative web GUI (Registry Administration Tool) that can also be used to perform EPP transactions will be provided. The primary use of the Registry Administration Tool is for performing administrative or customer support tasks.

The main features of the EPP implementation are:

- Standards Compliance: The EPP XML interface is compliant to the EPP RFCs. As future EPP RFCs are published or existing RFCs are updated, Neustar makes changes to the implementation keeping in mind of any backward compatibility issues.

- Scalability: The system is deployed keeping in mind that it may be required to grow and shrink the footprint of the Registry system for a particular TLD.

- Fault-tolerance: The EPP servers are deployed in two geographically separate data centers to provide for quick failover capability in case of a major outage in a particular data center. The EPP servers adhere to strict availability requirements defined in the SLAs.

- Configurability: The EPP extensions are built in a way that they can be easily configured to turn on or off for a particular TLD.

- Extensibility: The software is built ground up using object oriented design. This allows for easy extensibility of the software without risking the possibility of the change rippling through the whole application.

- Auditable: The system stores detailed information about EPP transactions from provisioning to DNS and WHOIS publishing. In case of a dispute regarding a name registration, the Registry can provide comprehensive audit information on EPP transactions.

- Security: The system provides IP address based access control, client credential-based authorization test, digital certificate exchange, and connection limiting to the protocol layer.


25.3 Compliance with RFCs and Specifications

The registry-registrar model is described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. As shown in Table 25-1, EPP is defined by the core set of RFCs that standardize the interface that registrars use to provision domains with the SRS. As a core component of the SRS architecture, the implementation is fully compliant with all EPP RFCs.

Neustar ensures compliance with all RFCs through a variety of processes and procedures. Members from the engineering and standards teams actively monitor and participate in the development of RFCs that impact the registry services, including those related to EPP. When new RFCs are introduced or existing ones are updated, the team performs a full compliance review of each system impacted by the change. Furthermore, all code releases include a full regression test that includes specific test cases to verify RFC compliance.

Neustar has a long history of providing exceptional service that exceeds all performance specifications. The SRS and EPP interface have been designed to exceed the EPP specifications defined in Specification 10 of the Registry Agreement and profiled in Table 25-2. Evidence of Neustar’s ability to perform at these levels can be found in the .biz monthly progress reports found on the ICANN website.

EPP Toolkits
Toolkits, under open source licensing, are freely provided to registrars for interfacing with the SRS. Both Java and C++ toolkits will be provided, along with the accompanying documentation. The Registrar Tool Kit (RTK) is a software development kit (SDK) that supports the development of a registrar software system for registering domain names and IDNs in the registry using EPP. The SDK consists of software and documentation as described below.

The software consists of working Java and C++ EPP common APIs and samples that implement the EPP core functions and EPP extensions used to communicate between the registry and registrar. The RTK illustrates how XML requests (registration events) can be assembled and forwarded to the registry for processing. The software provides the registrar with the basis for a reference implementation that conforms to the EPP registry-registrar protocol. The software component of the SDK also includes XML schema definition files for all Registry EPP objects and EPP object extensions. The RTK also includes a “dummy” server to aid in the testing of EPP clients.

The accompanying documentation describes the EPP software package hierarchy, the object data model, and the defined objects and methods (including calling parameter lists and expected response behavior). New versions of the RTK are made available from time to time to provide support for additional features as they become available and support for other platforms and languages.


25.3 Proprietary EPP Extensions

The .shijie registry will not includeuse proprietary EPP extensions for registration of IDNs. When an IDN is registered, it must contain a language indicator, “IDNLang”, as a name⁄value pair in the “unpec” tag of “neulevel:extension”. The extension is in compliance with RFC 3735 and is described in the “EPP Schema” document.

Neustar has implemented various EPP extensions for both internal and external use in other TLD registries. These extensions use the standard EPP extension framework described in RFC 5730. Table 25-3 provides a list of extensions developed for other TLDs. Should the .shijie registry require an additional EPP extension at some point in the future, the extension will be implemented in compliance with all RFC specifications including RFC 3735.

The full EPP schema to be used in the .shijie registry is attached in the document titled “EPP Schema.”


25.4 Resourcing Plans
The development and support of EPP is largely the responsibility of Neustar’s Development⁄Engineering and Quality Assurance teams. As an experienced registry operator with a fully developed EPP solution, on-going support is largely limited to periodic updates to the standard and the implementation of TLD specific extensions.

The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those Neustar teams:

- Development⁄Engineering – 19 employees
- Quality Assurance - 7 employees.

- These resources are more than adequate to support any EPP modification needs of the .shijie registry.


26. Whois

25.1 Introduction

Stable Tone Limited’s back-end registry operator, Neustar, has over 10 years of experience operating EPP based registries. They deployed one of the first EPP registries in 2001 with the launch of .biz. In 2004, they were the first gTLD to implement EPP 1.0. Over the last ten years Neustar has implemented numerous extensions to meet various unique TLD requirements. Neustar will leverage its extensive experience to ensure Stable Tone Limited is provided with an unparalleled EPP based registry. The following discussion explains the EPP interface which will be used for the. jiankang registry. This interface exists within the protocol farm layer as described in Question 24 and is depicted in Figure 25-1.


25.2 EPP Interface

Registrars are provided with two different interfaces for interacting with the registry. Both are EPP based, and both contain all the functionality necessary to provision and manage domain names. The primary mechanism is an EPP interface to connect directly with the registry. This is the interface registrars will use for most of their interactions with the registry.

However, an alternative web GUI (Registry Administration Tool) that can also be used to perform EPP transactions will be provided. The primary use of the Registry Administration Tool is for performing administrative or customer support tasks.

The main features of the EPP implementation are:

- Standards Compliance: The EPP XML interface is compliant to the EPP RFCs. As future EPP RFCs are published or existing RFCs are updated, Neustar makes changes to the implementation keeping in mind of any backward compatibility issues.

- Scalability: The system is deployed keeping in mind that it may be required to grow and shrink the footprint of the Registry system for a particular TLD.

- Fault-tolerance: The EPP servers are deployed in two geographically separate data centers to provide for quick failover capability in case of a major outage in a particular data center. The EPP servers adhere to strict availability requirements defined in the SLAs.

- Configurability: The EPP extensions are built in a way that they can be easily configured to turn on or off for a particular TLD.

- Extensibility: The software is built ground up using object oriented design. This allows for easy extensibility of the software without risking the possibility of the change rippling through the whole application.

- Auditable: The system stores detailed information about EPP transactions from provisioning to DNS and WHOIS publishing. In case of a dispute regarding a name registration, the Registry can provide comprehensive audit information on EPP transactions.

- Security: The system provides IP address based access control, client credential-based authorization test, digital certificate exchange, and connection limiting to the protocol layer.


25.3 Compliance with RFCs and Specifications

The registry-registrar model is described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. As shown in Table 25-1, EPP is defined by the core set of RFCs that standardize the interface that registrars use to provision domains with the SRS. As a core component of the SRS architecture, the implementation is fully compliant with all EPP RFCs.

Neustar ensures compliance with all RFCs through a variety of processes and procedures. Members from the engineering and standards teams actively monitor and participate in the development of RFCs that impact the registry services, including those related to EPP. When new RFCs are introduced or existing ones are updated, the team performs a full compliance review of each system impacted by the change. Furthermore, all code releases include a full regression test that includes specific test cases to verify RFC compliance.

Neustar has a long history of providing exceptional service that exceeds all performance specifications. The SRS and EPP interface have been designed to exceed the EPP specifications defined in Specification 10 of the Registry Agreement and profiled in Table 25-2. Evidence of Neustar’s ability to perform at these levels can be found in the .biz monthly progress reports found on the ICANN website.

EPP Toolkits
Toolkits, under open source licensing, are freely provided to registrars for interfacing with the SRS. Both Java and C++ toolkits will be provided, along with the accompanying documentation. The Registrar Tool Kit (RTK) is a software development kit (SDK) that supports the development of a registrar software system for registering domain names in the registry using EPP. The SDK consists of software and documentation as described below.

The software consists of working Java and C++ EPP common APIs and samples that implement the EPP core functions and EPP extensions used to communicate between the registry and registrar. The RTK illustrates how XML requests (registration events) can be assembled and forwarded to the registry for processing. The software provides the registrar with the basis for a reference implementation that conforms to the EPP registry-registrar protocol. The software component of the SDK also includes XML schema definition files for all Registry EPP objects and EPP object extensions. The RTK also includes a “dummy” server to aid in the testing of EPP clients.

The accompanying documentation describes the EPP software package hierarchy, the object data model, and the defined objects and methods (including calling parameter lists and expected response behavior). New versions of the RTK are made available from time to time to provide support for additional features as they become available and support for other platforms and languages.


25.3 Proprietary EPP Extensions

The .jiankang registry will not include proprietary EPP extensions. Neustar has implemented various EPP extensions for both internal and external use in other TLD registries. These extensions use the standard EPP extension framework described in RFC 5730. Table 25-3 provides a list of extensions developed for other TLDs. Should the .jiankang registry require an EPP extension at some point in the future, the extension will be implemented in compliance with all RFC specifications including RFC 3735.

The full EPP schema to be used in the .jiankang registry is attached in the document titled “EPP Schema.”


25.4 Resourcing Plans
The development and support of EPP is largely the responsibility of Neustar’s Development⁄Engineering and Quality Assurance teams. As an experienced registry operator with a fully developed EPP solution, on-going support is largely limited to periodic updates to the standard and the implementation of TLD specific extensions.

The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those Neustar teams:

- Development⁄Engineering – 19 employees
- Quality Assurance - 7 employees.
- These resources are more than adequate to support any EPP modification needs of the .jiankang registry.

27. Registration Life Cycle

27.1 Registration Life Cycle

Introduction
Stable Tone Limited will follow the lifecycle and business rules found in the majority of gTLDs today. Our back-end operator, Neustar, has over ten years of experience managing numerous TLDs that utilize standard and unique business rules and lifecycles. This section describes the business rules, registration states, and the overall domain lifecycle that will be used for our TLD.

Domain Lifecycle - Description
The registry will use the EPP 1.0 standard for provisioning domain names, contacts and hosts. Each domain record is comprised of three registry object types: domain, contacts, and hosts

Domains, contacts and hosts may be assigned various EPP defined statuses indicating either a particular state or restriction placed on the object. Some statuses may be applied by the Registrar; other statuses may only be applied by the Registry. Statuses are an integral part of the domain lifecycle and serve the dual purpose of indicating the particular state of the domain and indicating any restrictions placed on the domain. The EPP standard defines 17 statuses; however only 14 of these statuses are presently intended be used in the .jiankang registry per the defined .jiankang business rules.

The following is a brief description of each of the statuses. Server statuses may only be applied by the Registry, and client statuses may be applied by the Registrar.

- OK – Default status applied by the Registry.

- Inactive – Default status applied by the Registry if the domain has less than 2 nameservers.

- PendingCreate – Status applied by the Registry upon processing a successful Create command, and indicates further action is pending. This status will not be used in the .jiankang registry.

- PendingTransfer – Status applied by the Registry upon processing a successful Transfer request command, and indicates further action is pending.

- PendingDelete – Status applied by the Registry upon processing a successful Delete command that does not result in the immediate deletion of the domain, and indicates further action is pending.

- PendingRenew – Status applied by the Registry upon processing a successful Renew command that does not result in the immediate renewal of the domain, and indicates further action is pending. This status will not be used in the .jiankang registry.

- PendingUpdate – Status applied by the Registry if an additional action is expected to complete the update, and indicates further action is pending. This status will not be used in the .jiankang registry.

- Hold – Removes the domain from the DNS zone.

- UpdateProhibted – Prevents the object from being modified by an Update command.

- TransferProhibted – Prevents the object from being transferred to another Registrar by the Transfer command.

- RenewProhibted – Prevents a domain from being renewed by a Renew command.

DeleteProhibted – Prevents the object from being deleted by a Delete command.

The lifecycle of a domain begins with the registration of the domain. All registrations must follow the EPP standard, as well as the specific business rules set forth by Stable Tone Limited Upon registration a domain will either be in an active or inactive state. Domains in an active state are delegated and have their delegation information published to the zone. Inactive domains either have no delegation information or their delegation information in not published in the zone. Following the initial registration of a domain, one of five actions may occur during its lifecycle:
- Domain may be updated
- Domain may be deleted, either within or after the add-grace period
- Domain may be renewed at any time during the term
- Domain may be auto-renewed by the Registry
- Domain may be transferred to another registrar.

Each of these actions may result in a change in domain state. This is described in more detail in the following section. Every domain must eventually be renewed, auto-renewed, transferred, or deleted. A registrar may apply EPP statuses described above to prevent specific actions such as updates, renewals, transfers, or deletions.


27.1.1 Registration States

Domain Lifecycle – Registration States
As described above the .jiankang registry will implement a standard domain lifecycle found in most gTLD registries today. There are five possible domain states:
- Active
- Inactive
- Locked
- Pending Transfer
- Pending Delete.

All domains are always in either an Active or Inactive state, and throughout the course of the lifecycle may also be in a Locked, Pending Transfer, and Pending Delete state. Specific conditions such as applied EPP policies and registry business rules will determine whether a domain can be transitioned between states. Additionally, within each state, domains may be subject to various timed events such as grace periods, and notification periods.

Active State
The active state is the normal state of a domain and indicates that delegation data has been provided and the delegation information is published in the zone. A domain in an Active state may also be in the Locked or Pending Transfer states.

Inactive State
The Inactive state indicates that a domain has not been delegated or that the delegation data has not been published to the zone. A domain in an Inactive state may also be in the Locked or Pending Transfer states. By default all domain in the Pending Delete state are also in the Inactive state.

Locked State
The Locked state indicates that certain specified EPP transactions may not be performed to the domain. A domain is considered to be in a Locked state if at least one restriction has been placed on the domain; however up to eight restrictions may be applied simultaneously. Domains in the Locked state will also be in the Active or Inactive state, and under certain conditions may also be in the Pending Transfer or Pending Delete states.

Pending Transfer State
The Pending Transfer state indicates a condition in which there has been a request to transfer the domain from one registrar to another. The domain is placed in the Pending Transfer state for a period of time to allow the current (losing) registrar to approve (ack) or reject (nack) the transfer request. Registrars may only nack requests for reasons specified in ICANN’s Inter-Registrar Transfer Policy.

Pending Delete State
The Pending Delete State occurs when a Delete command has been sent to the Registry after the first 5 days (120 hours) of registration. The Pending Delete period is 35-days during which the first 30-days the name enters the Redemption Grace Period (RGP) and then after the last 5-days lapse the domain will be available for registration.


27.1.2 Typical Registration Lifecycle Activities

Domain Creation Process
The creation (registration) of domain names is the fundamental registry operation. All other operations are designed to support or compliment a domain creation. The following steps occur when a domain is created.
1. Contact objects are created in the SRS database. The same contact object may be used for each contact type, or they may all be different. If the contacts already exist in the database this step may be skipped.
2. Nameservers are created in the SRS database. Nameservers are not required to complete the registration process; however any domain with less than 2 name servers will not be resolvable.
3. The domain is created using the each of the objects created in the previous steps. In addition, the term and any client statuses may be assigned at the time of creation.

The actual number of EPP transactions needed to complete the registration of a domain name can be as few as one and as many as 40. The latter assumes seven distinct contacts and 13 nameservers, with Check and Create commands submitted for each object.

Update Process
Registry objects may be updated (modified) using the EPP Modify operation. The Update transaction updates the attributes of the object.

For example, the Update operation on a domain name will only allow the following attributes to be updated:
- Domain statuses
- Registrant ID
- Administrative Contact ID
- Billing Contact ID
- Technical Contact ID
- Nameservers
- AuthInfo
- Additional Registrar provided fields.

The Update operation will not modify the details of the contacts. Rather it may be used to associate a different contact object (using the Contact ID) to the domain name. To update the details of the contact object the Update transaction must be applied to the contact itself. For example, if an existing registrant wished to update the postal address, the Registrar would use the Update command to modify the contact object, and not the domain object.

Renew Process
The term of a domain may be extended using the EPP Renew operation. ICANN policy general establishes the maximum term of a domain name to be 10 years, and Neustar recommends not deviating from this policy. A domain may be renewed⁄extended at any point time, even immediately following the initial registration. The only stipulation is that the overall term of the domain name may not exceed 10 years. If a Renew operation is performed with a term value will extend the domain beyond the 10 year limit, the Registry will reject the transaction entirely.

Transfer Process
The EPP Transfer command is used for several domain transfer related operations:
- Initiate a domain transfer
- Cancel a domain transfer
- Approve a domain transfer
- Reject a domain transfer.

To transfer a domain from one Registrar to another the following process is followed:

1. The gaining (new) Registrar submits a Transfer command, which includes the AuthInfo code of the domain name.

2. If the AuthInfo code is valid and the domain is not in a status that does not allow transfers the domain is placed into pendingTransfer status

3. A poll message notifying the losing Registrar of the pending transfer is sent to the Registrar’s message queue

4. The domain remains in pendingTransfer status for up to 120 hours, or until the losing (current) Registrar Acks (approves) or Nack (rejects) the transfer request

5. If the losing Registrar has not Acked or Nacked the transfer request within the 120 hour timeframe, the Registry auto-approves the transfer

6. The requesting Registrar may cancel the original request up until the transfer has been completed.

A transfer adds an additional year to the term of the domain. In the event that a transfer will cause the domain to exceed the 10 year maximum term, the Registry will add a partial term up to the 10 year limit.

Deletion Process
A domain may be deleted from the SRS using the EPP Delete operation. The Delete operation may result in the domain being immediately removed from the database or the domain being placed in pendingDelete status. The outcome is dependent on when the domain is deleted. If the domain is deleted within the first five days (120 hours) of registration, the domain may be immediately removed from the database. A deletion at any other time may result in the domain being placed in pendingDelete status and entering the Redemption Grace Period (RGP). Additionally, domains that are deleted within five days (120) hours of any billable (add, renew, transfer) transaction may be deleted for credit.


27.1.3 Applicable Time Elements

The following section explains the time elements that are involved.

Grace Periods
There are six grace periods:
- Add-Delete Grace Period (AGP)
- Renew-Delete Grace Period
- Transfer-Delete Grace Period
- Auto-Renew-Delete Grace Period
- Auto-Renew Grace Period
- Redemption Grace Period (RGP).

The first four grace periods listed above are designed to provide the Registrar with the ability to cancel a revenue transaction (add, renew, or transfer) within a certain period of time and receive a credit for the original transaction.

The following describes each of these grace periods in detail.

Add-Delete Grace Period
The APG is associated with the date the Domain was registered. Domains may be deleted for credit during the initial 120 hours of a registration, and the Registrar will receive a billing credit for the original registration. If the domain is deleted during the Add Grace Period, the domain is dropped from the database immediately and a credit is applied to the Registrar’s billing account.

Renew-Delete Grace Period
The Renew-Delete Grace Period is associated with the date the Domain was renewed. Domains may be deleted for credit during the 120 hours after a renewal. The grace period is intended to allow Registrars to correct domains that were mistakenly renewed. It should be noted that domains that are deleted during the renew grace period will be placed into pendingDelete and may enter the RGP (see below).

Transfer-Delete Grace Period
The Transfer-Delete Grace Period is associated with the date the Domain was transferred to another Registrar. Domains may be deleted for credit during the 120 hours after a transfer. It should be noted that domains that are deleted during the renew grace period will be placed into pendingDelete and may enter the RGP. A deletion of domain after a transfer is not the best method used to correct a transfer mistake. Domains that have been erroneously transferred or hijacked by another party can be transferred back to the original registrar through various means including contacting the Registry.

Auto-Renew-Delete Grace Period
The Auto-Renew-Delete Grace Period is associated with the date the Domain was auto-renewed. Domains may be deleted for credit during the 120 hours after an auto-renewal. The grace period is intended to allow Registrars to correct domains that were mistakenly auto-renewed. It should be noted that domains that are deleted during the auto-renew delete grace period will be placed into pendingDelete and may enter the RGP.

Auto-Renew Grace Period
The Auto-Renew Grace Period is a special grace period intended to provide registrants with an extra amount of time, beyond the expiration date, to renew their domain name. The grace period lasts for 45 days from the expiration date of the domain name. Registrars are not required to provide registrants with the full 45 days of the period.

Redemption Grace Period
The RGP is a special grace period that enables Registrars to restore domains that have been inadvertently deleted but are still in pendingDelete status within the Redemption Grace Period.

The RGP period is 30 days, during which time the domain may be restored using the EPP RenewDomain command as described below. Following the 30-day RGP period the domain may remain in pendingDelete status for an additional five days. The domain is released from the SRS, at the end of the 5 day non-restore period. A restore fee applies and is detailed in the Billing Section. A renewal fee will be automatically applied for any domain past expiration.

Neustar has created a unique restoration process that uses the EPP Renew transaction to restore the domain and fulfill all the reporting obligations required under ICANN policy. The following describes the restoration process.


27.2 State Diagram

Figure 27-1 provides a description of the registration lifecycle.

The different states of the lifecycle are active, inactive, locked, pending transfer, and pending delete. Please refer to section 27.1.1 for detail description of each of these states. The lines between the states represent triggers that transition a domain from one state to another.

The details of each trigger are described below:

- Create: Registry receives a create domain EPP command.

- WithNS: The domain has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.

- WithOutNS: The domain has not met the minimum number of nameservers required by registry policy. The domain will not be in the DNS zone.

- Remove Nameservers: Domainʹs nameserver(s) is removed as part of an update domain EPP command. The total nameserver is below the minimum number of nameservers required by registry policy in order to be published in the DNS zone.

- Add Nameservers: Nameserver(s) has been added to domain as part of an update domain EPP command. The total number of nameservers has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.

- Delete: Registry receives a delete domain EPP command.

- DeleteAfterGrace: Domain deletion does not fall within the add grace period.

- DeleteWithinAddGrace: Domain deletion falls within add grace period.

- Restore: Domain is restored. Domain goes back to its original state prior to the delete command.

- Transfer: Transfer request EPP command is received.

- Transfer Approve⁄Cancel⁄Reject: Transfer requested is approved or cancel or rejected.

- TransferProhibited: The domain is in clientTransferProhibited and⁄or serverTranferProhibited status. This will cause the transfer request to fail. The domain goes back to its original state.

- DeleteProhibited: The domain is in clientDeleteProhibited and⁄or serverDeleteProhibited status. This will cause the delete command to fail. The domain goes back to its original state.

Note: the locked state is not represented as a distinct state on the diagram as a domain may be in a locked state in combination with any of the other states: inactive, active, pending transfer, or pending delete.


27.2.1 EPP RFC Consistency

As described above, the domain lifecycle is determined by ICANN policy and the EPP RFCs. Neustar has been operating ICANN TLDs for the past 10 years consistent and compliant with all the ICANN policies and related EPP RFCs.


27.3 Resources

The registration lifecycle and associated business rules are largely determined by policy and business requirements; as such the Product Management and Policy teams will play a critical role in working Applicant to determine the precise rules that meet the requirements of the TLD. Implementation of the lifecycle rules will be the responsibility of Development⁄Engineering team, with testing performed by the Quality Assurance team. Neustar’s SRS implementation is very flexible and configurable, and in many cases development is not required to support business rule changes.

The .jiankang registry will be using standard lifecycle rules, and as such no customization is anticipated. However should modifications be required in the future, the necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:
- Development⁄Engineering – 19 employees
- Registry Product Management – 4 employees

These resources are more than adequate to support the development needs of all the TLDs operated by Neustar, including the .jiankang registry.

28. Abuse Prevention and Mitigation

28.1 Abuse Prevention and Mitigation

Strong abuse prevention within a new gTLD is an important benefit to the internet community. .jiankang and its registry services provider, Neustar, intend to implement resources and policies designed to minimize the negative effects of any abusive domain name registrations. Neustar brings extensive experience establishing and implementing registration anti-abuse policies. This experience will be leveraged to help .jiankang combat abusive domain registrations and malicious domain activity within this new TLD, including, but not limited to:
- Illegal or fraudulent actions
- Spam
- Phishing
- Pharming
- Distribution of malware
- Fast flux hosting
- Botnets
- Distribution of child pornography
- Sale or distribution of illegal pharmaceuticals
- Violation of any governmental regulation pertaining to health or safety
- False advertising
- Provision of content that defames, or that offends community standards, or that is otherwise injurious to any person in any way

More specifically, although traditionally botnets have used Internet Relay Chat (IRC) servers to control registry servers and the compromised PCs, or bots, for DDoS attacks and the theft of personal information, an increasingly popular technique, known as fast-flux DNS, allows botnets to use a multitude of servers to hide a key host or to create a highly-available control network. This ability to shift the attacker’s infrastructure over a multitude of servers in various countries creates an obstacle for law enforcement and security researchers to mitigate the effects of these botnets. But a point of weakness in this scheme is its dependence on DNS for its translation services. By taking an active role in researching and monitoring these sorts of botnets, Neustar has developed the ability to efficiently work with various law enforcement and security communities to begin a new phase of mitigation of these types of threats.

Policies and Procedures to Minimize Abusive Registrations

A Registry must have the policies, resources, personnel, and expertise in place to combat such abusive DNS practices. As .jiankang’s registry provider, Neustar is at the forefront of the prevention of such abusive practices and is one of the few registry operators to have actually developed and implemented an active “domain takedown” policy. We also believe that a strong program is essential given that registrants have a reasonable expectation that they are in control of the data associated with their domains, especially its presence in the DNS zone. Because domain names are sometimes used as a mechanism to enable various illegitimate activities on the Internet, often the best preventative measure to thwart these attacks is to remove the names completely from the DNS before they can impart harm, not only to the domain name registrant, but also to millions of unsuspecting Internet users.

Removing the domain name from the zone has the effect of shutting down all activity associated with the domain name, including the use of all websites and e-mail. The use of this technique should not be entered into lightly. .jiankang has an extensive, defined, and documented process for taking the necessary action of removing a domain from the zone when its presence in the zone poses a threat to the security and stability of the infrastructure of the Internet or the registry.

Abuse Point of Contact

As required by the Registry Agreement, .jiankang will establish and publish on its website a single abuse point of contact responsible for addressing inquiries from law enforcement and the public related to malicious and abusive conduct. .jiankang will also provide such information to ICANN prior to the delegation of any domain names in the TLD. This information shall consist of, at a minimum, a valid e-mail address dedicated solely to the handling of malicious conduct complaints, and a telephone number, fax number, and mailing address for the primary contact. We will ensure that this information will be kept accurate and up to date and will be provided to ICANN if and when changes are made. In addition, with respect to inquiries from ICANN-Accredited registrars, our registry services provider, Neustar, shall have an additional point of contact, as it does today, handling requests by registrars related to abusive domain name practices.

28.2 Policies Regarding Abuse Complaints

.jiankang will implement and enforce an Acceptable Use Policy that clearly delineates the types of activities that constitute “abuse” -- and the repercussions associated with any abusive domain name registration or malicious activity. In addition, the policy will be incorporated into the applicable Registry-Registrar Agreement and will reserve the right for the registry to take the appropriate actions based on the type of abuse. This may include locking down the domain name, thus preventing any changes to the contact and nameserver information associated with the domain name, placing the domain name “on hold” rendering the domain name non-resolvable, transferring the domain name to another registrar, and⁄or in cases in which the domain name is associated with an existing law enforcement investigation and at the request of such law enforcement entity, substituting name servers to collect information about the DNS queries to assist the investigation.

.jiankang will adopt an Acceptable Use Policy that clearly defines the types of activities that will not be permitted in the TLD and reserves the right of the registry operator to lock, cancel, transfer or otherwise suspend or take down domain names violating the Acceptable Use Policy. Furthermore, it will allow the Registry to share information with law enforcement. Each ICANN-Accredited Registrar must agree to pass through the Acceptable Use Policy to its Resellers (if applicable) and ultimately to all domain name registrants within the .jiankang TLD. Below is the Registry’s draft Acceptable Use Policy intended for use in connection with the .jiankang.

.jiankang Acceptable Use Policy

This Acceptable Use Policy gives the Registry the ability to quickly lock, cancel, transfer or take ownership of any .jiankang domain name, either temporarily or permanently, if the domain name is being used in a manner that appears to threaten the stability, integrity or security of the Registry, or any of its registrar partners – and⁄or that may put the safety and security of any registrant or user at risk. The Acceptable Use Policy also allows the Registry to take preventive measures to avoid any such criminal or security threats.

The Acceptable Use Policy may be triggered through a variety of channels, including, among other things, private complaint, public alert, government or enforcement agency outreach, and the on-going monitoring by the Registry or its contractors. In all cases, the Registry or its designees will alert Registry’s registrars about any identified threats, and will work closely with them to bring offending domains registered by them into compliance.

The following are some (but not all) activities that may be subject to rapid compliance actions:

- Phishing: the attempt to trick Internet users into divulging personal data such as usernames, passwords, or financial data.

- Pharming: the redirection of Internet users to websites other than those the user intends to visit, usually through unauthorized changes to the Hosts file on a victim’s computer or DNS records in DNS servers.

- Dissemination of Malware: the intentional creation and distribution of ʺmaliciousʺ software designed to infiltrate a computer system without the owner’s consent, including, without limitation, computer viruses, worms, key loggers, and Trojans.

- Fast Flux Hosting: a technique used to shelter Phishing, Pharming and Malware sites and networks from detection and to frustrate methods employed to defend against such practices, whereby the IP address associated with fraudulent websites are changed rapidly so as to make the true location of the sites difficult to find.

- Botnetting: the development and use of a command, agent, motor, service, or software which is implemented: (1) to remotely control the computer or computer system of an Internet user without their knowledge or consent, (2) to generate direct denial of service (DDOS) attacks.

- Malicious Hacking: the attempt to gain unauthorized access (or exceed the level of authorized access) to a computer, information system, user account or profile, database, or security system.

- Child Pornography: the storage, publication, display and⁄or dissemination of pornographic materials depicting individuals under the age of majority in the relevant jurisdiction.

The Registry reserves the right, in its sole discretion, to take any administrative and operational actions necessary, including the use of computer forensics and information security technological services, among other things, in order to implement the Acceptable Use Policy. In addition, the Registry reserves the right 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, in its discretion; (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 as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement or (5) to correct mistakes made by the Registry or any Registrar in connection with a domain name registration. Registry also reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a dispute.

Monitoring for Malicious Activity

.jiankang’s registry services provider, Neustar Inc., is at the forefront of the prevention of abusive DNS practices. Neustar is one of only a few registry operators to have actually developed and implemented an active “domain takedown” policy in which the registry itself takes down abusive domain names.

Neustar’s approach is quite different from a number of other gTLD Registries, and the results have been unmatched. Neustar targets verified abusive domain names and removes them within 12 hours regardless of whether or not there is cooperation from the domain name registrar. This is because Neustar has determined that the interest in removing such threats of consumer harm outweighs any potential damage to the registrar⁄registrant relationship.

Neustar’s active prevention policies stem from the notion that registrants in the TLD have a reasonable expectation that they are in control of the data associated with their domains, especially its presence in the DNS zone. Because domain names are sometimes used as a mechanism to enable various illegitimate activities on the Internet, including malware, bot command and control, pharming, and phishing, the best preventative measure to thwart these attacks is often to remove the names completely from the DNS in order to mitigate any harm, not only to the domain name registrant, but also to other unsuspecting Internet users.

Rapid Takedown Process

Since implementing its monitoring and takedown program, Neustar has developed two basic variations of the process. The more common process variation is a light-weight process that is triggered by “typical” notices. The less-common variation is the full process that is triggered by unusual notices. These notices tend to involve the need for accelerated action by the registry in the event that a complaint is received by Neustar which alleges that a domain name is being used to threaten the stability and security of the TLD, or is part of an investigation by law enforcement or security researchers. These processes are described below:

Lightweight Process

In addition to having an active Information Security group that, on its own initiatives, seeks out abusive practices in the TLD, Neustar is an active member in a number of security organizations that have expertise and experience in receiving and investigating reports of abusive DNS practices, including but not limited to, the Anti-Phishing Working Group, Castle Cops, NSP-SEC, the Registration Infrastucture Safety Group and others. Each of these sources are well-known security organizations that have developed a reputation for the prevention of harmful agents affecting the Internet. Aside from these organizations, Neustar also actively participates in privately run security associations whose basis of trust and anonymity makes it much easier to obtain information regarding abusive DNS activity.

Once a complaint is received from a trusted source, law enforcement entity or other third-party, or malicious activity is detected by Neustar’s internal security group, information about the abusive practice is forwarded to an internal mail distribution list that includes members of the operations, legal, support, engineering, and security teams for immediate response (“CERT Team”). Although the impacted URL is included in the notification e-mail, the CERT Team is trained not to investigate the URLs themselves since often times the URLs in Question have scripts, bugs, etc. that can compromise the individual’s own computer and the network safety. Rather, the investigation is done by a few members of the CERT team that are able to access the URLs in a laboratory environment so as to not compromise the Neustar network. The lab environment is designed specifically for these types of tests and is scrubbed on a regular basis to ensure that none of Neustar’s internal or external network elements are harmed in any fashion.

Once the complaint has been reviewed and the alleged abusive domain name activity is verified to the best of the ability of the CERT Team, the sponsoring registrar is given 12 hours to investigate the activity and either 1) take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or 2) provide a compelling argument to the registry to keep the name in the zone.

If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), then Neustar may place the domain on “ServerHold”. Although this action removes the domain name from the TLD zone, the domain name record still appears in the TLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved.

Full Process.

In the event that Neustar receives a complaint which claims that a domain name is being used to threaten the stability and security of the TLD or is a part of an investigation by law enforcement or security researchers, Neustar follows a slightly different course of action.

Upon initiation of this process, members of the CERT Team are paged and a teleconference bridge is immediately opened up for the CERT Team to assess whether the activity warrants immediate action. If the CERT Team determines the incident is not an immediate threat to the security and the stability of critical internet infrastructure, then they provide documentation to the Neustar Network Operations Center to clearly capture the rationale for the decision. They either refer the incident to the Lightweight Process set forth above; or if no abusive practice is discovered, then the incident is closed.

However, if the CERT Team determines there is a reasonable likelihood that the incident warrants immediate action as described above, then a determination may be made to immediately remove the domain from the zone. In such event, Neustar’s Customer Support team would contact the responsible registrar immediately to communicate that there is a domain involved in a security and stability issue. The registrar is provided only the domain name in Question and the broadly stated type of incident. Given the sensitivity of the associated security concerns, it may be important that the registrar not be given explicit or descriptive information in regards to data that has been collected (evidence) or the source of the complaint. This helps to protect the chain of custody for evidence and the source of the data that originated the complaint.

Coordination with Law Enforcement & Industry Groups

One of the reasons for which Neustar was selected to serve as the back-end registry services provider by .jiankang is Neustar’s extensive experience with its industry-leading abusive domain name and malicious monitoring program and its close working relationship with a number of law enforcement agencies, both in the United States and internationally. For example, in the United States, Neustar is in constant communication with the Federal Bureau of Investigation, US CERT, Homeland Security, the Food and Drug Administration, and the National Center for Missing and Exploited Children.

Neustar is also a participant in a number of industry groups aimed at sharing information amongst key industry players about the abusive registration and use of domain names. These groups include the Anti-Phishing Working Group and the Registration Infrastructure Safety Group (where Neustar served for several years on the Board of Directors). Through these organizations and others, Neustar shares information with other registries, registrars, ccTLDs, law enforcement, security professionals, etc. not only on abusive domain name registrations within its own TLDs, but also provides information uncovered with respect to domain names in other registries’ TLDs. Neustar has often found that rarely are abuses found only in the TLDs for which it manages, but also within other TLDs, such as .com and .info. Neustar routinely provides this information to the other registries so that it can take the appropriate action.

With the assistance of Neustar as its back-end registry services provider, .jiankang can meet its obligations under Section 2.8 of the Registry Agreement where required to take reasonable steps to investigate and respond to reports from law enforcement and governmental and quasi-governmental agencies of illegal conduct in connection with the use of its TLD. .jiankang and⁄or Neustar will endeavor to respond to legitimate law enforcement inquiries within one business day from receiving the request. Such response shall include, at a minimum, an acknowledgement of receipt of the request, questions or comments concerning the request, and an outline of the next steps to be taken by .jiankang and⁄or Neustar for rapid resolution of the request.

In the event such request involves any of the activities which can be commercially reasonably validated by .jiankang and⁄or Neustar and involves the type of activity set forth in the Acceptable Use Policy, the sponsoring registrar is then given 12 hours to investigate the activity further and either 1) take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or 2) provide a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), Neustar may place the domain on “serverHold”.
28.3 Measures for Removal of Orphan Glue Records

As the Security and Stability Advisory Committee of ICANN (SSAC) rightly acknowledges, although orphaned glue records may be used for abusive or malicious purposes, the “dominant use of orphaned glue supports the correct and ordinary operation of the DNS.” See http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf.

While orphan glue records often support correct and ordinary operation of the DNS, we understand that such glue records can be used maliciously to point to name servers that host domains used in illegal phishing, bot-nets, malware, and other abusive behaviors. Problems occur when the parent domain of the glue record is deleted but its children glue records still remain in DNS. Therefore, when the Registry has written evidence of actual abuse of orphaned glue, the Registry will take action to remove those records from the zone to mitigate such malicious conduct.

Neustar runs a daily audit of entries in its DNS systems and compares those with its provisioning system. This serves as an umbrella protection to make sure that items in the DNS zone are valid. Any DNS record that shows up in the DNS zone, but not in the provisioning system, will be flagged for investigation and removed if necessary. This daily DNS audit serves to not only prevent orphaned hosts but also other records that should not be in the zone.

In addition, if either .jiankang or Neustar become aware of actual abuse of any orphaned glue record after receiving notification by a third party through its Abuse Contact or through its customer support, then such glue records will be removed from the zone.

28.4 Measures to Promote WHOIS Accuracy

.jiankang acknowledges that ICANN has developed a number of mechanisms over the past decade that are intended to address the issue of inaccurate WHOIS information. .jiankang intends to do more than ICANN’s current minimum requirements, in order to better reflect current and accurate WHOIS information for every .jiankang domain. .jiankang will reserve the right to verify WHOIS and other registrant contact information at any time, by any means it chooses. .jiankang also will offer a mechanism whereby third parties can submit complaints directly to the Registry Operator (as opposed to ICANN or the sponsoring Registrar) about inaccurate or incomplete WHOIS data. Reports about any incorrect contact information may be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Twenty days after forwarding the complaint to the registrar, .jiankang will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, the Registry Operator may suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.

28.4.1 Authentication of Registrant Information

.jiankang intends to authenticate registrant information as complete and accurate at time of registration, and on an ongoing basis in the event our own monitoring or third party reports indicate any inaccuracy. In particular, through our direct sales channel and through participating registrars, .jiankang will screen incoming registration requests for common and current indicia of fraud, through algorithmic technology commonly referred to as a “fraud engine.” This is a step not taken today by many registrars and registries, yet is employed by some of them, and by many other online businesses as a means to reduce fraudulent registrations and other abuse.

In addition, through our direct sales channel and through participating registrars, .jiankang will screen incoming registration requests for common and current indicia of fraud, through algorithmic technology commonly referred to as a “fraud engine.” Again this is a step not taken today by many registrars and registries, yet is employed by some of them, and by many other online businesses as a means to reduce fraudulent registrations and other abuse.

Furthermore, the provision of Searchable WHOIS, as described in Response to Question 26, will allow security researchers, IP professionals and law enforcement to more quickly determine if a known bad actor has also registered names in .jiankang, and thus notify us of false WHOIS information that has been supplied by .jiankang registrants.

28.4.2 Monitoring of Registration Data

.jiankang intends to conduct regular monitoring of registration data for accuracy and completeness, employing authentication methods, and establishing policies and procedures to address domain names with inaccurate or incomplete WHOIS data. .jiankang intends on its own initiative, no less than twice per year, to perform a manual review of a random sampling of .jiankang domain names to test the accuracy of the WHOIS information. This may include manually verifying the actual information in the WHOIS record if there is suspicion of inaccuracy for any reason. jiankang will be examining the WHOIS data for prima facie evidence of inaccuracies, and may take further steps to ensure accuracy, at its discretion. Reports of inaccurate contact information shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Twenty days after forwarding the complaint to the registrar, .jiankang will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, then .jiankang may suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.

Our regular WHOIS audit will occur more often and with more effectiveness than ICANN’s annual WHOIS data verification policy applicable in the existing gTLDs. Specifically, the existing policy does not require affirmative response from the WHOIS email addresses, merely to ensure that they are still valid and monitored. .jiankang’s audit policy will generally require this periodic verification, and may lead to further verification steps at our discretion.

28.4.3 Policies and Procedures Ensuring Compliance

When .jiankang or any .jiankang registrar receives a notice of false WHOIS information or other activity which violates our Acceptable Use Policy, the relevant registrar will be required to promptly acknowledge the notice, conduct a reasonable investigation, and report to the complainant and to .jiankang the results of such investigation – whether appropriate action was taken, whether further information is required in order to evaluate the complaint, or whether the complaint was found invalid.

28.5 Resourcing Plans

Responsibility for abuse mitigation rests with a variety of functional groups. Neustar’s Abuse Monitoring team is primarily responsible for providing analysis and conducting investigations of reports of abuse. Neustar’s customer service team also plays an important role in assisting with the investigations, responded to the registry operator and registrars, and notifying registrars of abusive domains. Finally, Neustar’s Policy⁄Legal team, in conjunction with Registry Operator, is responsible for developing the relevant policies and procedures.

The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:
Customer Support – 12 employees
Policy⁄Legal – 2 employees

These Neustar resources, coupled with .jiankang’s own resources, are more than adequate to support the abuse mitigation procedures of the .jiankang registry.

.jiankang intends to provide dedicated resources also to anti-abuse efforts. At minimum this will include one FTE dedicated to manage the abuse queue as the abuse point of contact, to manage our WHOIS verification policies, and to handle escalated abuse issues from Neustar by coordinating with other internal resources and providing a prompt decision. Other resources will include outside legal counsel to assist with unusual abuse escalations, coordination with law enforcement, and policy development; as well as executive resources designated to implementation of our anti-abuse policies.

29. Rights Protection Mechanisms

29.1. Rights Protection Mechanisms

.jiankang is firmly committed to the protection of Intellectual Property rights and to implementing the mandatory rights protection mechanisms detailed in Specification 7 of the Registry Agreement. .jiankang recognizes that although the New gTLD program includes significant protections beyond those that were mandatory for a number of the current TLDs, a key motivator for .jiankang’s selection of Neustar as its registry services provider is Neustar’s experience in successfully launching a number of TLDs with diverse rights protection mechanisms, including many of those required in the Registry Agreement. More specifically, .jiankang will implement the following rights protection mechanisms in accordance with the Registry Agreement as further described below:

- Trademark Clearinghouse: a one-stop shop so that trademark holders can protect their trademarks with a single registration.

- Sunrise and Trademark Claims processes for the TLD.

- Implementation of the Uniform Dispute Resolution Policy to address domain names that have been registered and used in bad faith in the TLD.

- Uniform Rapid Suspension: A quicker, more efficient and cheaper alternative to the Uniform Dispute Resolution Policy to deal with clear cases of cybersquatting.

Implementation of a Thick WHOIS making it easier for rights holders to identify and locate infringing parties

A. Trademark Clearinghouse Including Sunrise and Trademark Claims

The first mandatory rights protection mechanism (“RPM”) required to be implemented by each new gTLD Registry is support for, and interaction with, the trademark clearinghouse. The trademark clearinghouse is intended to serve as a central repository for information to be authenticated, stored and disseminated pertaining to the rights of trademark holders. The data maintained in the clearinghouse will support and facilitate other RPMs, including the mandatory Sunrise Period and Trademark Claims service. Although many of the details of how the trademark clearinghouse will interact with each registry operator and registrars are yet to be developed, .jiankang is actively monitoring the developments of the Implementation Assistance Group (“IAG”) designed to assist ICANN staff in firming up the rules and procedures associated with the policies and technical requirements for the trademark clearinghouse. In addition, Neustar, .jiankang’s back-end registry services provider is actively participating in the IAG to ensure that the protections afforded by the clearinghouse and associated RPMs are feasible and implementable.

Utilizing the trademark clearinghouse, all operators of new gTLDs must offer: (i) a sunrise registration service for at least 30 days during the pre-launch phase, giving eligible trademark owners an early opportunity to register second-level domains in new gTLDs; and (ii) a trademark claims service for at least the first 60 days that second-level registrations are open for general registration. The trademark claim service is intended to provide “clear noticeʺ to a potential registrant of the rights of a trademark owner whose trademark is registered in the clearinghouse.

.jiankang’s registry service provider, Neustar, has already implemented Sunrise and⁄or Trademark Claims programs for numerous TLDs including .biz, .us, .travel, .tel and .co -- and will implement both of these services on behalf of .jiankang.

B. Neustar’s Experience in Implementing Sunrise and Trademark Claims Processes

In early 2002, Neustar became the first registry operator to launch a successful, authenticated Sunrise process. This process permitted qualified trademark owners to pre-register their trademarks as domain names in the .us TLD space prior to the opening of the space to the general public. Unlike any other “Sunrise” plans implemented (or proposed before that time), Neustar validated the authenticity of Trademark applications and registrations with the United States Patent and Trademark Office (USPTO).

Subsequently, as the back-end registry operator for the .tel gTLD and the .co ccTLD, Neustar launched validated Sunrise programs employing processes very similar to those that are to be employed with respect to the Trademark Clearinghouse for new gTLDs.

Below is a high level overview of the implementation of the .co Sunrise period that demonstrates Neustar’s experience and ability to provide a Sunrise service and an overview of Neustar’s experience in implementing a Trademark Claims program to trademark owners for the launch of .BIZ. Neustar’s experience in each of these rights protection mechanisms will enable it to seamlessly provide these services on behalf of .jiankang as ultimately required by ICANN.

i. Sunrise and .co

The Sunrise process for .co was divided into two sub-phases:

- Local Sunrise giving holders of eligible trademarks that have obtained registered status from the Colombian trademark office the opportunity apply for the .CO domain names corresponding with their marks

- Global Sunrise program giving holders of eligible registered trademarks of national effect, that have obtained a registered status in any country of the world, the opportunity to apply for the .CO domain names corresponding with their marks for a period of time before registration was open to the public at large.

Like the new gTLD process set forth in the Applicant Guidebook, trademark owners had to have their rights validated by a Clearinghouse provider prior to the registration being accepted by the Registry. The Clearinghouse used a defined process for checking the eligibility of the legal rights claimed as the basis of each Sunrise application, using official national trademark databases and submitted documentary evidence.

Applicants and⁄or their designated agents had the option of interacting directly with the Clearinghouse to ensure their applications were accurate and complete prior to submitting them to the Registry pursuant to an optional “Pre-validation Process”. Whether or not an applicant was “pre-validated”, the applicant had to submit its corresponding domain name application through an accredited registrar. When the Applicant was pre-validated through the Clearinghouse, each was given an associated approval number that it had to supply the registry. If they were not pre-validated, applicants were required to submit the required trademark information through their registrar to the Registry.

At the registry level, Neustar, subsequently either delivered the:
- Approval number and domain name registration information to the Clearinghouse; or,
- When there was no approval number, trademark information and the domain name registration information was provided to the Clearinghouse through EPP (as is currently required in the draft Registry Agreement).

Information was then used by the Clearinghouse as either further validation of those pre-validated applications, or initial validation of those that did not go through pre-validation. If the applicant was validated and their trademark matched the domain name applied-for, the Clearinghouse communicated that fact to the Registry via EPP.

When there was only one validated sunrise application, the application proceeded to registration when the .co TLD re-launched. If there were multiple validated applications (recognizing that there could be multiple trademark owners sharing the same trademark), those were included in the .co Sunrise auction process. Neustar tracked all of the information it received and the status of each application and posted that status on a secure Website to enable trademark owners to view the status of its Sunrise application.

Although the exact process for the Sunrise program and its interaction between the trademark owner, Registry, Registrar, and Trademark Clearinghouse is not completely defined in the draft Registry Agreement and is dependent on the current RFI issued by ICANN in its selection of a Trademark Clearinghouse provider, Neustar’s expertise in launching multiple Sunrise processes and its established software will implement a smooth and compliant Sunrise process for .jiankang.

ii. Trademark Claims Service Experience

With Neustar’s biz TLD launched in 2001, Neustar became the first TLD with a Trademark Claims service. Neustar developed the Trademark Claim Service by enabling companies to stake claims to domain names prior to the commencement of live .biz domain registrations.

During the Trademark Claim process, Neustar received over 80,000 Trademark Claims from entities around the world. Recognizing that multiple intellectual property owners could have trademark rights in a particular mark, multiple Trademark Claims for the same string were accepted. All applications were logged into a Trademark Claims database managed by Neustar.


The Trademark Claimant was required to provide various information about their trademark rights, including the:
- Particular trademark or service mark relied on for the trademark Claim
- Date a trademark application on the mark was filed, if any, on the string of the domain name
- Country where the mark was filed, if applicable
- Registration date, if applicable
- Class or classes of goods and services for which the trademark or service mark was registered
- Name of a contact person with whom to discuss the claimed trademark rights.

Once all Trademark Claims and domain name applications were collected, Neustar then compared the claims contained within the Trademark Claims database with its database of collected domain name applications (DNAs). In the event of a match between a Trademark Claim and a domain name application, an e-mail message was sent to the domain name applicant notifying the applicant of the existing Trademark Claim. The e-mail also stressed that if the applicant chose to continue the application process and was ultimately selected as the registrant, the applicant would be subject to Neustar’s dispute proceedings if challenged by the Trademark Claimant for that particular domain name.

The domain name applicant had the option to proceed with the application or cancel the application. Proceeding on an application meant that the applicant wanted to go forward and have the application proceed to registration despite having been notified of an existing Trademark Claim. By choosing to “cancel,” the applicant made a decision in light of an existing Trademark Claim notification to not proceed.

If the applicant did not respond to the e-mail notification from Neustar, or elected to cancel the application, the application was not processed. This resulted in making the applicant ineligible to register the actual domain name. If the applicant affirmatively elected to continue the application process after being notified of the claimant’s (or claimants’) alleged trademark rights to the desired domain name, Neustar processed the application.

This process is very similar to the one ultimately adopted by ICANN and incorporated in the the draft Registry Agreement. Although the collection of Trademark Claims for new gTLDs will be by the Trademark Clearinghouse, many of the aspects of Neustar’s Trademark Claims process in 2001 are similar to those in the Applicant Guidebook. This makes Neustar uniquely qualified to implement the new gTLD Trademark Claims process.
.
B. Uniform Dispute Resolution Policy (UDRP) and Uniform Rapid Suspension (URS)

1. UDRP

The UDRP has been required to be implemented by all domain name registries and registrars since 1999. The UDRP is intended as an alternative dispute resolution process to transfer domain names from those that have registered and used domain names which are 1) confusingly similar to another’s trademark; 2) with no legitimate interest demonstrated by the registrant; and 3) with bad faith intent to profit. Although there is not much of an active role that the domain name registry plays in the implementation of the UDRP, Neustar has closely monitored UDRP decisions that have involved the TLDs for which it supports and ensures that the decisions are implemented by the registrars supporting its TLDs. When alerted by trademark owners of failures to implement UDRP decisions by its registrars, Neustar either proactively implements the decisions itself or reminds the offending registrar of its obligations to implement the decision.

2. URS

In response to complaints by trademark owners that the UDRP was too cost prohibitive and slow, and the fact that more than 70 percent of UDRP cases were “clear cut” cases of cybersquatting, ICANN adopted a requirement that all new gTLD registries be required, pursuant to their contracts with ICANN, to take part in a Uniform Rapid Suspension System (“URS”). The purpose of the URS is to provide a more cost effective and timely mechanism for brand owners than the UDRP, to protect their trademarks and to promote consumer protection on the Internet.

The URS is not meant to address questionable cases of alleged infringement (e.g., use of terms in a generic sense), but rather is intended only for those cases in which there is no genuine contestable issue as to the infringement and abuse that is taking place.

Unlike the UDRP which requires little involvement of gTLD registries, the URS envisages much more of an active role at the registry-level. For example, rather than requiring the registrar to lock down a domain name subject to a UDRP dispute, it is the registry under the URS that must lock the domain within 24 hours of receipt of the complaint from the URS Provider. This will restrict all changes to the registration data, including transfer and deletion of the domain names.

In addition, in the event of a determination in favor of the complainant, the registry is required to suspend the domain name. This suspension remains for the balance of the registration period, during which time the domain name will not resolve the original website. Rather, the nameservers would be redirected to an informational web page provided by the URS Provider about the URS.

Additionally, the WHOIS record for a suspended domain will reflect that the domain name will not be able to be transferred, deleted, or modified for the life of the registration. Finally, there is an option for a successful complainant to extend the registration period for one additional year at commercial rates.

.jiankang is fully aware of each of these requirements and will have the capability to implement these requirements for new gTLDs. In fact, during the IRT’s development of f the URS, Neustar began examining the implications of the URS on its registry operations and provided the IRT with feedback on whether the recommendations from the IRT would be feasible for registries to implement.

Although there have been a few changes to the URS since the IRT recommendations, Neustar continued to participate in the development of the URS by providing comments to ICANN, many of which were adopted. As a result, Neustar is committed to supporting the URS for all of the registries that it provides back-end registry services.

C. Implementation of Thick WHOIS

The .jiankang registry will include a thick WHOIS database as required in Specification 4 of the draft Registry Agreement. A thick WHOIS provides numerous advantages including a centralized location of registrant information, the ability to more easily manage and control the accuracy of data, and a consistent user experience.

D. Policies Handling Complaints Regarding Abuse

In addition to the Rights Protection mechanisms addressed above, .jiankang will implement a number of measures to handle complaints regarding the abusive registration of domain names in its TLD – as more completely described in 〈TLD’s〉 response to Question 28.

Registry Acceptable Use Policy

.jiankang will have an Acceptable Use Policy that clearly delineates the types of activities that constitute “abuse” and the repercussions associated with an abusive domain name registration. The policy must be incorporated into the applicable Registry-Registrar Agreement, and will reserve the right of the registry to take appropriate actions based on the type of abuse. This may include locking down the domain name and thus preventing any changes to the contact and nameserver information associated with the domain name, placing the domain name “on hold” rendering the domain name non-resolvable, transferring to the domain name to another registrar, and⁄or in cases in which the domain name is associated with an existing law enforcement investigation and at the request of such law enforcement entity, substituting name servers to collect information about the DNS queries to assist the investigation. .jiankang’s Acceptable Use Policy, set forth in our response to Question 28, will include prohibitions on phishing, pharming, dissemination of malware, fast flux hosting, hacking, and child pornography. In addition, the policy will include the right of the registry to take action necessary to deny, cancel, suspend, lock, or transfer any registration in violation of the Policy.

Monitoring for Malicious Activity

.jiankang is committed to ensuring that those domain names associated with abuse or malicious conduct in violation of the Acceptable Use Policy are dealt with in a timely and decisive manner. These include taking action against those domain names that are being used to threaten the stability and security of the TLD, or are part of an investigation by law enforcement.

Once a complaint is received from a trusted source, law enforcement entity or other third-party, or malicious activity is detected by the Registry, the Registry will use commercially reasonable efforts to verify the information in the complaint. If that information can be verified to the commercially reasonable satisfaction of the Registry, then the sponsoring registrar will be notified and be given 12 hours to investigate the activity and either 1) take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety, or 2) provide a compelling argument to the Registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), then the Registry may place the domain on “ServerHold”. Although this action removes the domain name from the TLD zone, the domain name record still would appear in the TLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved.

Malware Scan.

In addition to ICANN-required RPMs primarily intended to address intellectual property concerns, .jiankang sees great value in continually monitoring all .jiankang domains for websites or servers that are hosting malware which might infect visitors to such domains. Therefore, .jiankang intends to perform a periodic malware scan of the TLD zone, to analyse all websites hosted within the TLD zone, scan for malware, then determine if there is malicious content that may infect visitors, and report same to the affected registrar and registrant with remediation instructions. We believe this will help mitigate damage from ‘drive by downloads’ that cause a great deal of identity theft and computer system damage today.

29.2 Safeguards against Unqualified Registrations

.jiankang acknowledges that ICANN has developed a number of mechanisms over the past decade that are intended to address the issue of inaccurate WHOIS information. .jiankang intends to do more than ICANN’s current minimum requirements, in order to better reflect current and accurate WHOIS information for every .jiankang domain. .jiankang will offer a mechanism whereby third parties can submit complaints directly to the Registry Operator (as opposed to ICANN or the sponsoring Registrar) about inaccurate or incomplete WHOIS data. Such information shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Twenty days after forwarding the complaint to the registrar, .jiankang will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, the Registry Operator may suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.

In addition, .jiankang intends on its own initiative, no less than twice per year, perform a manual review of a random sampling of [.TLD] domain names to test the accuracy of the WHOIS information. Although this will not include verifying the actual information in the WHOIS record, .jiankang will be examining the WHOIS data for prima facie evidence of inaccuracies. In the event that such evidence exists, it shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Twenty days after forwarding the complaint to the registrar, the Applicant will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, .jiankang may suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.

This audit will occur more often and with more effectiveness than ICANN’s annual WHOIS data verification policy applicable in the existing gTLDs. Specifically, the existing policy does not require affirmative response from the WHOIS email addresses, merely to ensure that they are still valid and monitored. .jiankang’s audit policy will generally require this periodic verification.

Authentication of Registrant Information

As further detailed in response to Q28,.jiankang intends to authenticate registrant information as complete and accurate at time of registration, and on an ongoing basis in the event our own monitoring or third party reports indicate any inaccuracy. jiankang will reserve the right to verify WHOIS and other registrant contact information at any time, by any means it chooses.

In addition, through our direct sales channel and through participating registrars, .jiankang will screen incoming registration requests for common and current indicia of fraud, through algorithmic technology commonly referred to as a “fraud engine.” Again this is a step not taken today by many registrars and registries, yet is employed by some of them, and by many other online businesses as a means to reduce fraudulent registrations and other abuse.

Furthermore, the provision of Searchable WHOIS, as described in Response to Question 26, will allow security researchers, IP professionals and law enforcement to more quickly determine if a known bad actor has also registered names in .jiankang, and thus notify us of false WHOIS information that has been supplied by .jiankang registrants.

Policies and Procedures Ensuring Compliance

When .jiankang or any .jiankang registrar receives a notice of false WHOIS information or other activity which violates our Acceptable Use Policy, the relevant registrar will be required to promptly acknowledge the notice, conduct a reasonable investigation, and report to the complainant and to .jiankang the results of such investigation – whether appropriate action was taken, whether further information is required in order to evaluate the complaint, or whether the complaint was found invalid.

29.3 Resourcing Plans

The rights protection mechanisms described in the response above involve a wide range of tasks, procedures, and systems. The responsibility for each mechanism varies based on the specific requirements. In general the development of applications such as sunrise and IP claims is the responsibility of Neustar’s Engineering team, with guidance from its Product Management team. Neustar’s and .jiankang’s Customer Support, and Legal teams play a critical role in enforcing certain policies such as the rapid suspension processes. These teams have years of experience implementing these or similar processes.

The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:
Development⁄Engineering – 19 employees
Product Management- 4 employees
Customer Support – 12 employees

These resources, coupled with .jiankang’s own resources, are more than adequate to support the rights protection mechanisms of the .jiankang registry.

.jiankang intends to provide dedicated resources also to anti-abuse efforts. At minimum this will include one FTE dedicated to manage the abuse queue as the abuse point of contact, to manage our WHOIS verification policies, and to handle escalated abuse issues from Neustar by coordinating with other internal resources and providing a prompt decision. Other resources will include outside legal counsel to assist with unusual abuse escalations, coordination with law enforcement, and policy development; as well as executive resources designated to implementation of our anti-abuse policies.



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

Stable Tone Limited and our back-end registry services provider, Neustar, recognize the vital need to secure the systems and the integrity of the data in commercial solutions.   The .jiankang registry solution will leverage industry-best security practices including the consideration of physical, network, server, and application elements.   

Neustar’s approach to information security starts with comprehensive information security policies. These are based on the industry best practices for security including SANS (SysAdmin, Audit, Network, Security) Institute, NIST (National Institute of Standards and Technology), and Center for Internet Security (CIS). Policies are reviewed annually by Neustar’s information security team.

The following is a summary of the security policies that will be used in the .jiankang registry, including:
1. Summary of the security policies used in the registry operations
2. Description of independent security assessments
3. Description of security features that are appropriate for .jiankang
4. List of commitments made to registrants regarding security levels


Stable Tone is a newly formed entity to service the .jiankang registry. As per our plans described in 46-50, most staffing and front office services required to operate the registry will be developed during our ramp up period to launching the registry. As such, .jiankang has decided to adopt the applicable security practices of our registry service provider Neustar for the following reasons: Neustarʹs policies and practices are far more extensive than ICANNʹs requirements, these security policies and practices fully envelop and exceed the considerations of registry front-end services, Neustarʹs practices represent registry industry specialization and best of breed practices.



All of the security policies and levels described in this section are appropriate for the .jiankang registry.


30.(a).1 Summary of Security Policies

Neustar, Inc. has developed a comprehensive Information Security Program in order to create effective administrative, technical, and physical safeguards for the protection of its information assets, and to comply with Neustarʹs obligations under applicable law, regulations, and contracts. This Program establishes Neustarʹs policies for accessing, collecting, storing, using, transmitting, and protecting electronic, paper, and other records containing sensitive information.

The Program defines:
- The policies for internal users and our clients to ensure the safe, organized and fair use of information resources.
- The rights that can be expected with that use.
- The standards that must be met to effectively comply with policy.
- The responsibilities of the owners, maintainers, and users of Neustar’s information resources.
- Rules and principles used at Neustar to approach information security issues

The following policies are included in the Program:

1. Acceptable Use Policy
The Acceptable Use Policy provides the “rules of behavior” covering all Neustar Associates for using Neustar resources or accessing sensitive information.
Information Risk Management Policy

2. Information Risk Management Policy
The Information Risk Management Policy describes the requirements for the on-going information security risk management program, including defining roles and responsibilities for conducting and evaluating risk assessments, assessments of technologies used to provide information security and monitoring procedures used to measure policy compliance.

3. Data Protection Policy
The Data Protection Policy provides the requirements for creating, storing, transmitting, disclosing, and disposing of sensitive information, including data classification and labeling requirements, the requirements for data retention. Encryption and related technologies such as digital certificates are also covered under this policy.

4. Third Party Policy
The Third Party Policy provides the requirements for handling service provider contracts, including specifically the vetting process, required contract reviews, and on-going monitoring of service providers for policy compliance.

5. Security Awareness and Training Policy
The Security Awareness and Training Policy provide the requirements for managing the on-going awareness and training program at Neustar. This includes awareness and training activities provided to all Neustar Associates.


6. Incident Response Policy
The Incident Response Policy provides the requirements for reacting to reports of potential security policy violations. This policy defines the necessary steps for identifying and reporting security incidents, remediation of problems, and conducting “lessons learned” post-mortem reviews in order to provide feedback on the effectiveness of this Program. Additionally, this policy contains the requirement for reporting data security breaches to the appropriate authorities and to the public, as required by law, contractual requirements, or regulatory bodies.


7. Physical and Environment Controls Policy
The Physical and Environment Controls Policy provides the requirements for securely storing sensitive information and the supporting information technology equipment and infrastructure. This policy includes details on the storage of paper records as well as access to computer systems and equipment locations by authorized personnel and visitors.

8. Privacy Policy
Neustar supports the right to privacy, including the rights of individuals to control the dissemination and use of personal data that describes them, their personal choices, or life experiences. Neustar supports and complies with domestic and international laws and regulations that seek to protect the privacy rights of such individuals.

9. Identity and Access Management Policy
The Identity and Access Management Policy covers user accounts (login ID naming convention, assignment, authoritative source) as well as ID lifecycle (request, approval, creation, use, suspension, deletion, review), including provisions for system⁄application accounts, shared⁄group accounts, guest⁄public accounts, temporary⁄emergency accounts, administrative access, and remote access. This policy also includes the user password policy requirements.

10. Network Security Policy
The Network Security Policy covers aspects of Neustar network infrastructure and the technical controls in place to prevent and detect security policy violations.


11. Platform Security Policy
The Platform Security Policy covers the requirements for configuration management of servers, shared systems, applications, databases, middle-ware, and desktops and laptops owned or operated by Neustar Associates.

12. Mobile Device Security Policy
The Mobile Device Policy covers the requirements specific to mobile devices with information storage or processing capabilities. This policy includes laptop standards, as well as requirements for PDAs, mobile phones, digital cameras and music players, and any other removable device capable of transmitting, processing or storing information.

13. Vulnerability and Threat Management Policy
The Vulnerability and Threat Management Policy provides the requirements for patch management, vulnerability scanning, penetration testing, threat management (modeling and monitoring) and the appropriate ties to the Risk Management Policy.

14. Monitoring and Audit Policy
The Monitoring and Audit Policy covers the details regarding which types of computer events to record, how to maintain the logs, and the roles and responsibilities for how to review, monitor, and respond to log information. This policy also includes the requirements for backup, archival, reporting, forensics use, and retention of audit logs.

15. Project and System Development and Maintenance Policy
The System Development and Maintenance Policy covers the minimum security requirements for all software, application, and system development performed by or on behalf of Neustar and the minimum security requirements for maintaining information systems.


30. (a).2 Independent Assessment Reports

Neustar IT Operations is subject to yearly Sarbanes-Oxley (SOX), Statement on Auditing Standards #70 (SAS70) and ISO audits. Testing of controls implemented by Neustar management in the areas of access to programs and data, change management and IT Operations are subject to testing by both internal and external SOX and SAS70 audit groups. Audit Findings are communicated to process owners, Quality Management Group and Executive Management. Actions are taken to make process adjustments where required and remediation of issues is monitored by internal audit and QM groups.

External Penetration Test is conducted by a third party on a yearly basis. As authorized by Neustar, the third party performs an external Penetration Test to review potential security weaknesses of network devices and hosts and demonstrate the impact to the environment. The assessment is conducted remotely from the Internet with testing divided into four phases:
- A network survey is performed in order to gain a better knowledge of the network that was being tested
- Vulnerability scanning is initiated with all the hosts that are discovered in the previous phase
- Identification of key systems for further exploitation is conducted
- Exploitation of the identified systems is attempted.

Each phase of the audit is supported by detailed documentation of audit procedures and results. Identified vulnerabilities are classified as high, medium and low risk to facilitate management’s prioritization of remediation efforts. Tactical and strategic recommendations are provided to management supported by reference to industry best practices.


30.(a).3 Augmented Security Levels and Capabilities

There are no increased security levels specific for .jiankang. However, Neustar will provide the same high level of security provided across all of the registries it manages.

A key to Neustar’s Operational success is Neustar’s highly structured operations practices. The standards and governance of these processes:
- Include annual independent review of information security practices
- Include annual external penetration tests by a third party
- Conform to the ISO 9001 standard (Part of Neustar’s ISO-based Quality Management System)
- Are aligned to Information Technology Infrastructure Library (ITIL) and CoBIT best practices
- Are aligned with all aspects of ISO IEC 17799
- Are in compliance with Sarbanes-Oxley (SOX) requirements (audited annually)
- Are focused on continuous process improvement (metrics driven with product scorecards reviewed monthly).

A summary view to Neustar’s security policy in alignment with ISO 17799 can be found in section 30.(a).4 below.


30.(a).4 Commitments and Security Levels

The .jiankang registry commits to high security levels that are consistent with the needs of the TLD. These commitments include:

Compliance with High Security Standards
- Security procedures and practices that are in alignment with ISO 17799
- Annual SOC 2 Audits on all critical registry systems
- Annual 3rd Party Penetration Tests
- Annual Sarbanes Oxley Audits

Highly Developed and Documented Security Policies
- Compliance with all provisions described in section 30.(a).4 below and in the attached security policy document.
- Resources necessary for providing information security
- Fully documented security policies
- Annual security training for all operations personnel

High Levels of Registry Security
- Multiple redundant data centers
- High Availability Design
- Architecture that includes multiple layers of security
- Diversified firewall and networking hardware vendors
- Multi-factor authentication for accessing registry systems
- Physical security access controls
- A 24x7 manned Network Operations Center that monitors all systems and applications
- A 24x7 manned Security Operations Center that monitors and mitigates DDoS attacks
- DDoS mitigation using traffic scrubbing technologies



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