KPMG International Cooperative (KPMG International Genossenschaft)
Laan van Langerhuize 1
Amstelveen 1186 DS
+ 31 20 656 6858
+ 31 20 656 6777
Mr. David Green
Head of Global Digital Marketing
+1 416 777 8061
+1 416 777 8450
+44 207 421 8250
+44 870 011 8187
Canton of Zug, Switzerland
|Alan Arthur Buckle||Deputy Chairman|
|Andrew John Alexander Cranston||Global Board member|
|Brian Ambrose||Chief Operating Officer|
|Domenico Fumagalli||Global Board member|
|Dr. Hans-Jürg Schürmann||Member of the Administration|
|Dr. Teddy Svatopluk Stojan||Member of the Administration|
|Frantisek Dostalek||Global Board member|
|Gregory Gilbert Wiebe||Global Head of Tax|
|Guillermo Garcia-Naranjo Alvarez||Global Board member|
|Helen Braidwood Spice||Chief Finance Officer|
|Helene Birgitta Willberg||Global Board member|
|Herman Hendrik Johan Dijkhuizen||Global Board and Global Executive Team member|
|Hideyo Uchiyama||Chairman of the Asia Pacific (“ASPAC”) region|
|Hubert Emil Markus Achermann||Global Board member and Lead Director|
|Jean-Luc Gerard Jacques Decornoy||Global Board and Global Executive Team member|
|Jean-Paul Thill||EMA Chief Executive Officer|
|Jesper Koefoed||Global Board member|
|Joachim Schindler||Global Head of Audit|
|John Graham Dickinson||Authorised signatory|
|John Brady Veihmeyer||Chairman of the Americas region|
|John Guthrie Griffith-Jones||Global Board and Global Executive Team member|
|John Maclean Scott||Global Board member|
|Ken Young-Gak Yun||Global Board member|
|Larry Antonio Leva||Global Vice Chair – Quality and Risk Management|
|Mark Alan Goodburn||Global Head of Advisory|
|Michael John Andrew||Chairman|
|Pedro Augusto de Melo||Global Board member|
|Peter Stanley Nash||Global Board and Global Executive Team member|
|Raboijane Moses Kgosana||Global Board member|
|Rachel Mary Campbell||Global Head of People, Performance and Culture|
|Rolf Eberhard Nonnenmacher||Chairman of the Europe, Middle East and Africa (“EMA”) region|
|Russell Ivan Parera||Global Board member|
|Sai Choy Tham||Global Board member|
|Sean Timothy Kelly||Americas Chief Operating Officer|
|Stephen Kin Wah Yiu||Global Board and Global Executive Team member|
|Terence Francis O’Rourke||Global Board and Global Executive Team member|
|Thomas Owen Gilbert Wethered||General Counsel|
|William Bruce Thomas||Global Board and Global Executive Team member|
|Yap Chee Meng||ASPAC Chief Operating Officer|
As the applied-for gTLD string is not an IDN and is consistent with the requirements of the Applicant Guidebook Section 188.8.131.52.2 (String Requirements), KPMG does not believe there are any known operational or rendering problems concerning the string.
KPMG is a global network of professional firms providing Audit, Tax and Advisory services. We operate in 153 countries and have 145,000 people working in member firms around the world. The independent member firms of the KPMG network are affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. Each KPMG member firm is a legally distinct and separate entity and describes itself as such.
We contribute to the effective functioning of international capital markets. We support reforms that strengthen the markets’ credibility and their social responsibility. We believe that similar reform must extend to the professional realm.
We aim to respond to the complex business challenges facing clients and adopt a global approach spanning professional disciplines, industry sectors and national borders.
Member firmsʹ clients include business corporations, governments and public sector agencies and not-for-profit organizations. They look to KPMG for a consistent standard of service based on high order professional capabilities, industry insight and local knowledge.
At KPMG, we try to create sustainable, long-term economic growth, not just for our member firms and their clients but for broader society, too. We seek to be a good corporate citizen, making a real difference to the communities in which we operate.
Combined revenues for KPMG member firms totalled US$22.7 billion for the fiscal year ending September 30, 2011, a 10.1 percent increase in U.S. dollars, or 6.2 percent in local currency terms, on the previous year.
The .KPMG registry will be a standard, not a community-based, registry. Its purpose will be:
• To provide a platform for the delivery of secure digital material for industry professionals.
• To protect KPMG’s intellectual property and ensure that the integrity of our brand is enhanced at the highest possible level in the domain name system. We have a portfolio of registered intellectual property rights around the world and securing the term .KPMG, will enable us to harmonise our current brand protection policies.
• To ensure KPMG remains at the forefront of innovation by keeping pace with internet technology developments, enabling us to be well positioned to exploit future benefits.
• To contribute to the development of the new gTLD programme.
The success of the .KPMG registry will be determined by the enhancement in the equity of the KPMG brand and in terms of the security and stability it brings to our communications.
Before launching this TLD, KPMG will develop and publish its policies and guidelines, setting out full details of how the registry will implement its vision and purpose as set out in this answer. KPMG may adapt its policies and proposed use of the gTLD in a manner consistent with the purpose, to reflect changes in its business and the adoption of new gTLDs by the community.
The registry will be strictly for the use of KPMG firms only, but it is predicted that it will also benefit others:
• Our clients: a new .KPMG registry will benefit them because it will provide an authenticated and more secure communication channel.
• Our existing and future employees: a new gTLD will demonstrate that KPMG is at the forefront of developments in internet technology as well as reinforcing our brand worldwide and providing a more secure communication channel.
• Internet users: the branded .KPMG gTLD will act as a clear signpost for internet users to genuine KPMG domains and associated content. It will therefore increase consumer and client trust and reduce the possibility of malicious conduct. It may also allow us to engage with internet users in their native language creating a more positive user experience.
What is the goal of your proposed gTLD in terms of areas of specialty, service levels or reputation?
The integrity of our brand is of paramount importance to us and this will be reflected in the treatment of the new gTLD. Our goal is to position ourselves so that we can exploit the latest internet advances in order to enhance our brand and reputation still further and to exploit future technological benefits as they arise. The new registry will be designed so that it is 100% ICANN compliant.
What do you anticipate your proposed gTLD will add to the current space in terms of competition, differentiation or innovation?
We are eager to operate a registry with shorter domain names that are universally applicable across the globe. We feel a new gTLD also offers clarity, enabling clients and internet users in general to place their trust in our registry. Most importantly, the new gTLD will also provide opportunities for enhanced, secure communication and reduced risk.
There are currently no gTLD registries dedicated to brand owners and we look forward to being among the first to apply. We believe that .KPMG offers potential for innovation and a point of differentiation between us and our competitors.
We look forward to utilising our new registry in conjunction with our current domains and will market under the term .KPMG if the new gTLD process proves to be a success as is anticipated. It enables us to leave behind complex naming hierarchies inherent in country code extensions.
We hope that our member firms’ clients, wherever they may be geographically based, know they are in a trusted and authentic destination once they arrive at a .KPMG domain name. We want them to be confident that they will receive accurate information and that their highly sensitive personal details will be securely protected. We believe that it will also offer an easy and more memorable reference point for our customers, as well as the opportunity for us to interact with them in their native languages.
Provide a complete description of the applicant’s intended registration policies in support of the goals above
KPMG International Cooperative is the operator of the .KPMG registry. The KPMG Domain Name Management team is responsible for the development, maintenance and enforcement of the KPMG Domain Management Policy. This policy defines the rules associated with eligibility and domain name allocation, sets out the terms governing the use of a .KPMG domain name and describes the dispute resolution policies for the KPMG gTLD. The policy will be updated and revised regularly to reflect KPMG’s commercial and strategic interests and, where appropriate, ICANN consensus and temporary policies.
Registration of a .KPMG domain name will be undertaken in four steps: Eligibility Confirmation, Naming Convention Check, Acceptable Use Review, and finally Registration. All domains in the .KPMG registry will remain the property of KPMG.
Each applied for A-Label character string must conform to the .KPMG rules of eligibility and must:
• Be at least 3 characters and no more than 63 characters long
• Not contain a hyphen on the 3rd and 4th position (except for IDNs)
• Contain only letters (a-z), numbers (0-9) and hyphens or a combination of these
• Start and end with an alphanumeric character, not a hyphen
• Not match any character strings reserved by ICANN
• Not match any protected country names or geographical terms.
Internationalized domain names (IDN) will be supported in the .KPMG registry at the second level. KPMG will ensure that no variants will be used.
.KPMG domains must be used solely for purposes that enhance KPMG’s strategic or commercial interests.
The .KPMG registry will respect (i) third party intellectual property rights, and (ii) the sensitivities regarding terms with national, cultural, geographic and religious significance.
.KPMG names may not be delegated or assigned to or used by third party organizations, institutions, or individuals.
All .KPMG domains will carry complete, accurate and up to date registration records.
The KPMG Domain Name Management Team may revoke a .KPMG domain name at any time in line with KPMG’s corporate and strategic interests.
The KPMG registry will be ICANN compliant: the registry will interface with the Trademark Clearinghouse, operate a Sunrise and IP Claims Service and all registrants must comply with the UDRP and the URS.
Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users?
As a global network of firms regularly involved in handling highly confidential client data, we take our responsibility to protect the private information of our clients and staff very seriously.
The .KPMG registry will continue our policy of protecting confidential information to the highest possible levels in accordance with relevant national and international laws and regulations. KPMG will comply with the Personal Data obligations of the ICANN Registry Agreement as set forth in Section 2.10 of Registry Agreement. Approved representatives will be registered as data handlers and trained to ensure compliance with ICANN’s requirements.
• Document policies and procedures for all aspects of the gTLD including protecting privacy and confidential information including an escalation process
• Use appropriate levels of encryption and physical security
• Train key staff on the use and operation of .KPMG and ensure responsibilities are understood and documented in rules of conduct
• Limit access to records only to those employees or service providers who need access for the performance of their job duties
• Test procedures relating to .KPMG
• Monitor best practice and ICANN’s mandated and recommended policies
• Audit the work of the Registry Services Provider and the escrow provider and check registry data before sending to ICANN.
• Report any attempts to gain unauthorised access to the gTLD systems to appropriate enforcement authorities as required by law.
Describe whether and in what ways outreach and communications will help to achieve your projected benefits?
We will produce and publish guidelines for internal use. These are intended to provide clarity on who can apply for a .KPMG domain and how it is to be used. This is a standard registry closed to third parties so these guidelines should ensure that .KPMG domains are registered in accordance with KPMG’s policies by authorised KPMG representatives only. We will create a home page for the registry, using clear and straightforward messaging for the benefit of internal users so that our policy is understood and complied with.
In the longer term, it is hoped that these measures will contribute to assisting internet users beyond KPMG to understand that .KPMG domains are genuine and are trusted signposts to authentic and secure information or services. To that end, over time we will also take measures to promote .KPMG as the address for all KPMG web properties. We will also participate in the ICANN Registry Operators Constituency.
As previously stated, the .KPMG registry will be a standard registry closed to third parties and will be used only by KPMG member firms. There should not be any social costs or negative consequences on consumers. Rather, .KPMG should benefit consumers and internet users as described above. We will use the Trademark Clearing House and other dispute resolution mechanisms to ensure that third party intellectual property rights are protected.
How will multiple applications for a particular domain be resolved, for example, by auction or on a first come first served basis?
There will be no market in .KPMG domains. We will not receive multiple applications for a particular domain and, therefore, there will be no need for any resolution.
Explain any cost benefits for registrants you intend to implement (e.g. advantageous pricing, introductory discounts, bulk registration discounts).
.KPMG domain names will be registered to KPMG only. As there will be no registration fee, the issue of cost benefits for registrants does not arise.
The Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than 10 years. Additionally the Registry Agreement requires advance written notice of price increases. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation?
The KPMG Domain Name Management Team will set the period of registration for .KPMG domains. We are applying for .KPMG to support our strategic goals and to protect our IP not to generate revenues from selling domains. Therefore it will not be necessary to consider contractual commitments nor issues around pricing including price escalation though we will comply with the provisions of Section 2.10 of the Registry Agreement.
KPMG is committed to running .kpmg in compliance with applicable laws, consensus policies, best practice guidelines, RFCs and the Specifications of the Registry Agreement. In accordance with GAC advice and Specification 5, KPMG will block from initial registration (at no charge) country and territory names contained in the following lists:
• The short form (in English) of country and territory names contained on the ISO 3166-1 list, as updated from time to time, including the European Union; and
• 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; and
• The list of United Nations member states in 6 official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names.
The process for reserving these names, and hence blocking them from registration, will be agreed with our technical service provider, Neustar, who have indicated their ability and willingness to comply with GAC and other requirements.
We envisage that, over time, there will be demand from brand TLDs leading to the development of a standardised process for reaching agreement with the applicable government and requesting GAC review and ICANN approval for the release of country and territory names for registration by the Registry Operator when the registry is a single entity registry. When such a process is in place, KPMG expects to apply for the release of country and territory names within .kpmg.
KPMG has elected to partner with Neustar, Inc to provide back-end services for the .KPMG registry. In making this decision, KPMG 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. Their existing registry services will be leveraged for the .KPMG 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. KPMG will use Neustar’s Registry Services platform to deploy the .KPMG registry, by providing the following Registry Services (none of these services are offered in a manner that is unique to .KPMG.
Registry-Registrar Shared Registration Service (SRS)
Extensible Provisioning Protocol (EPP)
Domain Name System (DNS)
Dissemination of Zone Files using Dynamic Updates
Access to Bulk Zone Files
Dynamic WHOIS Updates
Rights Protection Mechanisms
Internationalized Domain Names (IDN).
The following is a description of each of the services.
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.
The .KPMG 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 TLDs implementations, Neustar has extensive experience building EPP-based registries. Additional discussion on the EPP approach is presented in the response to Question 25.
KPMG 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.
Neustar’s existing standard WHOIS solution will be used for the .KPMG. 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)
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 DS 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 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
KPMG 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.
The .KPMG 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
KPMG will provide all ICANN required Rights Mechanisms, including:
Trademark Claims Service
Trademark Post-Delegation Dispute Resolution Procedure (PDDRP)
Registration Restriction Dispute Resolution Procedure (RRDRP)
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
KPMG will not be offering services that are unique to .KPMG.
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.
KPMG has partnered with Neustar, Inc, an experienced TLD registry operator, for the operation of the .KPMG Registry. KPMG 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 .KPMG 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 new gTLD Application Guidebook. The infrastructure for the registry is in place and operational today and no additional hardware or scaling will be required for the .KPMG registry. As described in more detail in the response to Q32, the registry has been architected to have a capacity in excess of three times projected volumes. As volumes increase, capacity is added as needed.
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, KPMG 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 on are a critical element to providing a high quality of service. If the systems are of poor quality, if they are difficult to maintain and operate, or if the registry personnel are unfamiliar with them, the registry will be prone to outages. 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 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
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 KPMG, to produce a complete history of changes for any domain name.
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:
Business Policy Layer
Each of the layers is described below.
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, persists 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.
The database is the third core components 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.
Data Center⁄Hosting Facilities
The SRS is hosted in multiple redundant data centers. Neustar owns and operates the primary data center in Sterling, VA. The secondary data center in Charlotte, NC is co-located in a facility owned by Peak 10; however Neustar owns all the equipment and is responsible for all aspects of the operations. Each data center includes multiple ISP connections, redundant power supplies, and other features found in Tier 3 facilities. A full description of the data center facilities can be found in the response to Question 32 Architecture.
Figure 24-1 depicts the overall SRS architecture including network components. This diagram depicts the configuration at one of the data centers. Each data center is configured identically.
Number of Servers
As depicted in the SRS architecture diagram 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 .KPMG registry, the SRS will operate with 8 protocol servers and 6 policy engine servers. These servers are shared with other TLDs. They easily 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:
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 .KPMG.
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 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.
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 requirement. 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 .KPMG 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 verifiable 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 .KPMG Registry. The following section describes Neustar’s experience and its capabilities to meet the requirements in the new 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.
Their 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 technical and operational teams, including:
Additionally, if customization or modifications are required, the Product Management and Quality Assurance teams will be involved in the design and testing. Finally, the 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 .KPMG 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 .KPMG registry.
KPMG’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 KPMG is provided with an unparalleled EPP based registry. The following discussion explains the EPP interface which will be used for the .KPMG 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 GUI provides a web implementation of all EPP transactions. The primary use of the Registry Administration Tool is for performing administrative or customer support tasks. The administrative tool is secured using RSA SecureID tokens.
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.
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.
25.4 Proprietary EPP Extensions
The .KPMG 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 .KPMG 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 .KPMG registry is attached in the document titled “EPP Schema.”
25.5 Resourcing Plans
The development and support of EPP is largely the responsibility of the Development⁄Engineering and Quality Assurance teams. As an experience 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 teams:
Development⁄Engineering – 19 employees
Quality Assurance - 7 employees.
These resources are more than adequate to support any EPP modification needs of the .KPMG registry.
KPMG recognizes the importance of an accurate, reliable, and up-to-date WHOIS database to governments, law enforcement, intellectual property holders and the public as a whole and is firmly committed to complying with all of the applicable WHOIS specifications for data objects, bulk access, and lookups as defined in Specifications 4 and 10 to the Registry Agreement. .KPMG’s back-end registry services provider, Neustar, has extensive experience providing ICANN and RFC-compliant WHOIS services for each of the TLDs that it operates both as a Registry Operator for gTLDs, ccTLDs and back-end registry services provider. As one of the first “thick” registry operators in the gTLD space, Neustar’s WHOIS service has been designed from the ground up to display as much information as required by a TLD and respond to a very stringent availability and performance requirement.
Some of the key features of .KPMG’s solution include:
Fully compliant with all relevant RFCs including 3912
Production proven, highly flexible, and scalable with a track record of 100% availability over the past 10 years
Exceeds current and proposed performance specifications
Supports dynamic updates with the capability of doing bulk updates
Geographically distributed sites to provide greater stability and performance
In addition, .KPMG’s thick-WHOIS solution also provides for additional search capabilities and mechanisms to mitigate potential forms of abuse as discussed below. (e.g., IDN, registrant data).
26.2 Software Components
The WHOIS architecture comprises the following components:
An in-memory database local to each WHOIS node: To provide for the performance needs, the WHOIS data is served from an in-memory database indexed by searchable keys.
Redundant servers: To provide for redundancy, the WHOIS updates are propagated to a cluster of WHOIS servers that maintain an independent copy of the database.
Attack resistant: To ensure that the WHOIS system cannot be abused using malicious queries or DOS attacks, the WHOIS server is only allowed to query the local database and rate limits on queries based on IPs and IP ranges can be readily applied.
Accuracy auditor: To ensure the accuracy of the information served by the WHOIS servers, a daily audit is done between the SRS information and the WHOIS responses for the domain names which are updated during the last 24-hour period. Any discrepancies are resolved proactively.
Modular design: The WHOIS system allows for filtering and translation of data elements between the SRS and the WHOIS database to allow for customizations.
Scalable architecture: The WHOIS system is scalable and has a very small footprint. Depending on the query volume, the deployment size can grow and shrink quickly.
Flexible: It is flexible enough to accommodate thin, thick, or modified thick models and can accommodate any future ICANN policy, such as different information display levels based on user categorization.
SRS master database: The SRS database is the main persistent store of the Registry information. The Update Agent computes what WHOIS updates need to be pushed out. A publish-subscribe mechanism then takes these incremental updates and pushes to all the WHOIS slaves that answer queries.
26.3 Compliance with RFC and Specifications 4 and 10
Neustar has been running thick-WHOIS Services for over 10+ years in full compliance with RFC 3912 and with Specifications 4 and 10 of the Registry Agreement.RFC 3912 is a simple text based protocol over TCP that describes the interaction between the server and client on port 43. Neustar built a home-grown solution for this service. It processes millions of WHOIS queries per day.
Table 26-1 describes Neustar’s compliance with Specifications 4 and 10.
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 WHOIS. 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.
26.4 High-level WHOIS System Description
26.4.1 WHOIS Service (port 43)
The WHOIS service is responsible for handling port 43 queries. Our WHOIS is optimized for speed using an in-memory database and master-slave architecture between the SRS and WHOIS slaves.
The WHOIS service also has built-in support for IDN. If the domain name being queried is an IDN, the returned results include the language of the domain name, the domain name’s UTF-8 encoded representation along with the Unicode code page.
26.4.2 Web Page for WHOIS queries
In addition to the WHOIS Service on port 43, Neustar provides a web based WHOIS application (www.whois.KPMG). It is an intuitive and easy to use application for the general public to use. WHOIS web application provides all of the features available in the port 43 WHOIS. This includes full and partial search on:
Registrant, Technical and Administrative Contacts
It also provides features not available on the port 43 service. These include:
1. Redemption Grace Period calculation: Based on the registry’s policy, domains in pendingDelete can be restorable or scheduled for release depending on the date⁄time the domain went into pendingDelete. For these domains, the web based WHOIS displays “Restorable” or “Scheduled for Release” to clearly show this additional status to the user.
2. Extensive support for international domain names (IDN)
3. Ability to perform WHOIS lookups on the actual Unicode IDN
4. Display of the actual Unicode IDN in addition to the ACE-encoded name
5. A Unicode to Punycode and Punycode to Unicode translator
6. An extensive FAQ
7. A list of upcoming domain deletions
26.5 IT and Infrastructure Resources
As described above the WHOIS architecture uses a workflow that decouples the update process from the SRS. This ensures SRS performance is not adversely affected by the load requirements of dynamic updates. It is also decoupled from the WHOIS lookup agent to ensure the WHOIS service is always available and performing well for users. Each of Neustar’s geographically diverse WHOIS sites use:
Firewalls, to protect this sensitive data
Dedicated servers for MQ Series, to ensure guaranteed delivery of WHOIS updates
Packetshaper for source IP address-based bandwidth limiting
Load balancers to distribute query load
Multiple WHOIS servers for maximizing the performance of WHOIS service.
The WHOIS service uses HP BL 460C servers, each with 2 X Quad Core CPU and a 64GB of RAM. The existing infrastructure has 6 servers, but is designed to be easily scaled with additional servers should it be needed.
Figure 26-1 depicts the different components of the WHOIS architecture.
26.6 Interconnectivity with Other Registry System
As described in Question 24 about the SRS and further in response to Question 31, “Technical Overview”, when an update is made by a registrar that impacts WHOIS data, a trigger is sent to the WHOIS system by the external notifier layer. The update agent processes these updates, transforms the data if necessary and then uses messaging oriented middleware to publish all updates to each WHOIS slave. The local update agent accepts the update and applies it to the local in-memory database. A separate auditor compares the data in WHOIS and the SRS daily and monthly to ensure accuracy of the published data.
26.7 Frequency of Synchronization between Servers
Updates from the SRS, through the external notifiers, to the constellation of independent WHOIS slaves happens in real-time via an asynchronous publish⁄subscribe messaging architecture. The updates are guaranteed to be updated in each slave within the required SLA of 95% ≤ 60 minutes. Please note that Neustar’s current architecture is built towards the stricter SLAs (95% ≤ 15 minutes) of .BIZ. The vast majority of updates tend to happen within 2-3 minutes.
26.8 Provision for Searchable WHOIS Capabilities
Neustar will create a new web-based service to address the new search features based on requirements specified in Specification 4 Section 1.8. The application will enable users to search the WHOIS directory using any one or more of the following fields:
Contacts and registrant’s name
Contact and registrant’s postal address, including all the sub-fields described in EPP (e.g., street, city, state or province, etc.)
The system will also allow search using non-Latin character sets which are compliant with IDNA specification.
The user will choose one or more search criteria, combine them by Boolean operators (AND, OR, NOT) and provide partial or exact match regular expressions for each of the criterion name-value pairs. The domain names matching the search criteria will be returned to the user.
Figure 26-2 shows an architectural depiction of the new service.
To mitigate the risk of this powerful search service being abused by unscrupulous data miners, a layer of security will be built around the query engine which will allow the registry to identify rogue activities and then take appropriate measures. Potential abuses include, but are not limited to:
• Data Mining
• Unauthorized Access
• Excessive Querying
• Denial of Service Attacks
To mitigate the abuses noted above, Neustar will implement any or all of these mechanisms as appropriate:
Username-password based authentication
Certificate based authentication
CAPTCHA mechanism to prevent robo invocation of Web query
Fee-based advanced query capabilities for premium customers.
The searchable WHOIS application will adhere to all privacy laws and policies of the .KPMG registry.
26.9 Resourcing Plans
As with the SRS, the development, customization, and on-going support of the WHOIS service is the responsibility of a combination of technical and operational teams. The primary groups responsible for managing the service include:
Development⁄Engineering – 19 employees
Database Administration – 10 employees
Systems Administration – 24 employees
Network Engineering – 5 employees
Additionally, if customization or modifications are required, the Product Management and Quality Assurance teams will also be involved. Finally, the 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 available resources described in detail in the response to Question 31. Neustar’s WHOIS implementation is very mature, and has been in production for over 10 years. As such, very little new development will be required to support the implementation of the .KPMG registry. The resources are more than adequate to support the WHOIS needs of all the TLDs operated by Neustar, including the .KPMG registry.
27.1 Registration Life Cycle
.KPMG 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 .KPMG.
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 will be used in the .KPMG registry per the defined .KPMG 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 .KPMG 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 .KPMG 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 .KPMG 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 described in the response to Question 18 above. 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 anytime 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 .KPMG registry will implement a standard domain lifecycle found in most gTLD registries today. There are five possible domain states:
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.
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.
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.
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, 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 the 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 the last 5-days guarantee that the domain will be purged from the Registry Database and available to public pool for registration on a first come, first serve basis.
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.
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:
Administrative Contact ID
Billing Contact ID
Technical Contact ID
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.
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.
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. Unlike with the Renew operation, the Registry will not reject a transfer operation.
A domain may be deleted from the SRS using the EPP Delete operation. The Delete operation will result in either 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 is immediately removed from the database. A deletion at any other time will 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.
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 will 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 will enter the RGP. A deletion of domain after a transfer is not the 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 will 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. All domains enter the RGP except those deleted during the AGP.
The RGP period is 30 days, during which time the domain may be restored using the EPP RenewDomain command as described below. Following the 30day RGP period the domain will remain in pendingDelete status for an additional five days, during which time the domain may NOT be restored. 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.
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 with KPMG 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 case development is not required to support business rule changes.
The .KPMG 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 .KPMG registry.
28.1 Abuse Prevention and Mitigation
Strong abuse prevention of a new gTLD is an important benefit to the Internet community. .KPMG and its registry operator, KPMG, and back-end registry services provider, Neustar, agree that a registry must not only aim for the highest standards of technical and operational competence, but also needs to act as a steward of the space on behalf of the Internet community and ICANN in promoting the public interest. Neustar brings extensive experience establishing and implementing registration policies. This experience will be leveraged to help .KPMG combat abusive and malicious domain activity within the new gTLD space.
One of those public interest functions for a responsible domain name registry includes working towards the eradication of abusive domain name registrations and use, including, but not limited to, those resulting from:
• Illegal or fraudulent actions
• Distribution of malware
• Fast flux hosting
• Distribution of child pornography
• Online sale, or distribution of, illegal pharmaceuticals.
More specifically, although traditionally botnets have used Internet Relay Chat (IRC) servers to control registry 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, KPMG’s partner, 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 KPMG’s registry provider, Neustar is at the forefront of the prevention of such abusive practices and has 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, even in a private brand registry, should not be entered into lightly. KPMG 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 or is otherwise illegal or abusive as described in section 28.2 below.
Abuse Point of Contact
As required by the Registry Agreement, KPMG will establish and publish on its website a single abuse point of contact responsible for addressing inquiries, for example from law enforcement and the public, related to malicious and abusive conduct. The Abuse Point of Contact email and telephone number will be monitored 24⁄7. A response will be supplied to 99.9% of on-line reports of malicious or abusive behavior within one minute of reporting with the subsequent investigations starting the next working day when verification of malicious activity and the process to remove infections will be commenced. The aim will be to conclude a response within 24 hours if this is technically possible. KPMG 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 and mailing address for the primary contact who will handle the complaint. We will ensure that this information is 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
One of the key policies each new gTLD registry will need to have is an Acceptable Use Policy that clearly delineates the types of activities that constitute “abuse” and the repercussions associated with an abusive domain name registration
.KPMG will be a single entity registry, with all domains registered to KPMG for use only in pursuit of the network’s commercial and strategic goals. There will be no re-sellers in .KPMG and there will be no market in .KPMG domains. KPMG will strictly control the use of .KPMG domains. Opportunities for bad faith use or abusive registration are therefore restricted.
However, KPMG will adopt an Acceptable Use Policy that clearly defines the types of activities that will not be permitted in the TLD and reserves the rights of the registry to take appropriate action based on the type of abuse involved. These actions include locking down the domain name 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, taking ownership of the domain names, cancelling or taking down the domain name and⁄or, in cases in which the domain name is associated with an existing law enforcement investigation, substituting name servers to collect information about the DNS queries to assist the investigation. The policy will also allow the Registry, where and when appropriate, to share information with law enforcement. The policy will be incorporated into the applicable Registry-Registrar Agreement.
Below is the Registry’s initial Acceptable Use Policy that we will use in connection with the .KPMG.
It is important to note that .KPMG will be managed as a single entity registry, whose sole registrants will be internal stakeholders of KPMG or KPMG’s affiliates. Therefore, the potential for abusive registrations and other activities that have a negative impact on Internet users is minimal. In the unlikely event that such abuse should occur, KPMG with its registry operator, Neustar, will implement the following policies and processes to manage such activities.
.KPMG Acceptable Use Policy
This Acceptable Use Policy gives the Registry the ability to quickly lock, place on hold, cancel, transfer or take ownership of any .KPMG domain name, either temporarily or permanently, if the domain name is being registered or 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 and⁄or is illegal or otherwise abusive. The process also allows the Registry to take preventive measures to avoid any 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 partners. In all cases, the Registry or its designees will alert Registry’s registrar partners about any identified threats, and will work closely with them to bring offending sites into compliance.
The following are some (but not all) activities that will be considered abusive:
• Phishing: the attempt to acquire personally identifiable information by masquerading as a website other than .KPMG’s own.
• 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.
• Other forms of abuse including defamatory content, invasions of privacy, IP abuses, fraud
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 and subsidiaries and any of their sub-contractors, agents, 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. Registry may, in its sole discretion, share information with law enforcement. In cases in which a domain name is associated with a law enforcement investigation, registry may substitute name servers to collect information about the DNS queries to assist the investigation.
Taking Action Against Abusive and⁄or Malicious Activity
The Registry 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 is part of a real-time investigation by law enforcement.
Once a complaint is received from a trusted source, third-party, or 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 best of the ability of the Registry, the sponsoring registrar will be notified and be given 12 hours to investigate the activity and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing 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), the Registry will place the domain on “ServerHold”. (This is unlikely to be necessary, as KPMG will be using a single, gateway registrar with whom it has a contract reflecting these policies). 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. If further enquiries are required to come to a final decision on the alleged abuse (and consequent actions to be taken), they will be made.
Co-ordination with Law Enforcement
With the assistance of Neustar as its back-end registry services provider, KPMG 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. The Registry will 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 KPMG for rapid resolution of the request. The aim will be to suspend or cancel any domains, if this is required, within 24 hours
In the event such request involves any of the activities which can be validated by the Registry 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 take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing 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), the Registry will place the domain on “serverHold”. Again, if further enquiries are required to come to a final decision on the alleged abuse (and consequent actions to be taken), they will be made.
KPMG is aware that Neustar provides additional monitoring for malicious activity upon request. Following Reveal Day, 2 May 2012, KPMG will be talking to Neustar with the intention of determining how the following services and policies can be introduced.
Monitoring for Malicious Activity
KPMG’s Registry Services Provider, Neustar is at the forefront of the prevention of abusive DNS practices. Neustar has developed and implemented an active “domain takedown” policy in which the registry itself takes down abusive domain names.
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 from the consumer outweighs any potential damage to the registrar⁄registrant relationship. This is very unlikely to be required in KPMG’s registry as it has rules of eligibility that exclude third parties beyond KPMG from registering .KPMG domains and it will only be using one registrar with which it has a close contractual relationship with requirements to co-operate in stemming abusive behaviours.
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 before they can impart harm, not only to the domain name registrant, but also to millions of unsuspecting Internet users.
Rapid Takedown Process
Since implementing the 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 unusual 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 a real-time investigation by law enforcement or security researchers. These processes are described below:
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 the 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 Infrastructure Safety Group and others. Each of these sources is a well-known security organization that has 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, third-party, or 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 take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing 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 Neustar’s period (i.e., is unresponsive to the request or refuses to take action), Neustar places 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.
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 a real-time 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, they provide documentation to the Neustar Network Operations Center to clearly capture the rationale for the decision and refer the incident to the Lightweight process set forth above. If no abusive practice is discovered, the incident is closed.
However, if the CERT TEAM determines there is a reasonable likelihood that the incident warrants immediate action as described above, a determination is made to immediately remove the domain from the zone. As such, Customer Support will contact KPMG’s 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. The need for security is to fully protect the chain of custody for evidence and the source of the data that originated the complaint.
Coordination with Law Enforcement & Industry Groups
Neustar has extensive experience of dealing with abusive and malicious domain name incidents. It has a 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 as 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, KPMG can meet its obligations under Section 2.8 of the Registry Agreement where it is 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. KPMG and⁄or Neustar will 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 KPMG and⁄or Neustar for rapid resolution of the request.
In the event such request involves any of the activities which can be validated by KPMG 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 take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing 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 places the domain on “serverHold”.
KPMG have systems and experts in place to combat malicious behaviors targeted at kpmg.com and other KPMG internet assets. These will be made available to ensure the security and stability of the new .kpmg registry. The metrics that these experts currently collate and analyse for example in relation to viruses, malware, DDOS attacks etc. will be enhanced with metrics measuring the resilience of the .kpmg registry and incidents of malicious behavior.
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 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 run 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. Neustar will run a daily audit and take appropriate action with respect to .KPMG
In addition, if either KPMG or Neustar become aware of actual abuse on orphaned glue after receiving written notification by a third party through its Abuse Contact or through its customer support, such glue records will be removed from the zone.
28.4 Measures to Promote WHOIS Accuracy
The KPMG registry will implement several measures to promote Whois accuracy in compliance with the Registry Agreement and relevant Consensus and Temporary Policies. These will be undertaken by KPMG directly and by KPMG’s registrar via requirements in the Registry-Registrar Agreement.
Whois service for KPMG will operate as follows: all basic contact details for each domain name will be kept in a unique internal system by the registry, which facilitates the access to the domain information. In addition, KPMG will perform internal monitoring checks and procedures which will only allow accurate Whois information and remove outdated data.
28.4.1. Authentication of Registrant Information
As a single entity registry, the only registrant in .KPMG will be KPMG. However, KPMG will guarantee the adequate authentication of registrant data, ensuring the highest levels of accuracy and diligence when dealing with Whois data. In doing so, KPMG’s solid internal system will undertake the following authentication measures, among others: running checks against Whois internal records and regular verification of all contact details and other relevant registrant information. KPMG’s registrar will also be charged with regularly checking Whois accuracy.
KPMG will have a well-defined registration policy that will include a requirement that complete and accurate registrant details are provided by the requestor for a domain. These details will be validated by the KPMG registrar which will have a contractual duty to comply with KPMG’s registration policy. The full details of every domain requestor will be kept in KPMG’s on-line registry management dashboard which can be accessed by the KPMG Domain Management Team at any time.
28.4.2. Regular Monitoring of Registration Data
KPMG is strongly committed to implementing specific policies and procedures to guarantee the adequate compliance with ICANN’s Whois requirements. Among other measures, KPMG will regularly remind its internal personnel to meet the standards of ICANN’s Whois information Policy. It will also conduct regular checks of Whois data against internal and other records. As third parties external to KPMG will not be able to register in the KPMG registry, fraudulent Whois data is very unlikely but nonetheless, checks will be undertaken and the requestors of domains will be reminded at regular intervals of the need to abide by Acceptable Use policies etc. Whois details will be kept up to date this way.
28.4.3. Policies and Procedures ensuring compliance
Only KPMG and its Affiliates will be permitted to register and use KPMG domain names. Accordingly, the duties of KPMG’s registrar will be very limited and closely defined. However, as part of the RRA (Registry Registrar Agreement), KPMG will require the registrar to take steps necessary to ensure Whois data is complete and accurate and to implement the KPMG registration policies. This will include taking steps to rectify any incorrect data identified.
28.5 Resourcing Plans
Responsibility for abuse mitigation rests with a variety of functional groups within Neustar and KPMG. The Neustar Abuse Monitoring team is primarily responsible for providing analysis and conducting investigations of reports of abuse. The customer service team also plays an important role in assisting with the investigations, responding to customers, and notifying registrars of abusive domains. Finally, the Policy⁄Legal team 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
The resources are more than adequate to support the abuse mitigation procedures of the .KPMG registry.
Furthermore, KPMG dedicates significant financial and personnel resources to combating malicious and abusive behavior in the DNSKPMG will extend these resources to encompass the designation and maintenance of the unique abuse point of contact, regular monitoring of potential abusive and malicious activities with support from dedicated technical staff, analysis of reported abuse and malicious activity, and action to address such reported activity. This team will also assist with the collation and analysis of metrics.
The designated abuse prevention staff will be subject to regular evaluations, receive adequate training and work under expert supervision. The abuse prevention resources will comprise both internal staff and external abuse prevention experts who would give extra advice and support when necessary. KPMG will make it a condition of the agreement with its GateWay Registrar that the registrar provide a minimum of one legal manager and four operational experts to support KPMG with its abuse prevention initiatives.
29.1. Rights Protection Mechanisms
KPMG is firmly committed to the protection of Intellectual Property rights and to implementing the mandatory rights protection mechanisms contained in the Applicant Guidebook and detailed in Specification 7 of the Registry Agreement. KPMG 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 KPMG’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 Applicant Guidebook. More specifically, .KPMG will operate as a single entity registry with strict rules of eligibility and will therefore implement the following rights protection mechanisms where relevant in accordance with the Applicant Guidebook 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 cut 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 the registry operator and registrar are as yet unknown, KPMG 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, KPMG’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. The trademark claim service is intended to provide clear notice to a potential registrant of the rights of a trademark owner whose trademark is registered in the clearinghouse.
KPMG’s registry service provider, Neustar, has already implemented Sunrise and⁄or Trademark Claims programs for numerous TLDs including .biz, .us, .travel, .tel and .co (see below) and will implement both of these services on behalf of .KPMG.
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. These programs are very similar to those that are to be employed by the Trademark Clearinghouse for new gTLDs.
KPMG will benefit from Neustarʹs experience. As .KPMG will be a private brand registry with eligibility requirements and rules of registration that restrict third parties, which are not members or affiliates of KPMG, from registering domains, abusive behaviours will be limited. The .KPMG sunrise will last thirty days. As all domains in .KPMG will be registered to KPMG for its own exclusive use, applications from third parties are not anticipated. However, KPMG will ensure that its sunrise, like all its RPMs, is operated fairly, transparently and in accordance with ICANN’s policies.
The anticipated Rollout Schedule for the Sunrise Period can be found in Section 29.4 below.
Although the exact process for the Sunrise program and its interaction between the trademark owner, Registry, Registrar, and IP Clearinghouse is not completely defined in the Applicant Guidebook 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 ensure a smooth and compliant Sunrise process for KPMG.
a) 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.
This process is very similar to the one ultimately adopted by ICANN and incorporated in the latest version of the Applicant Guidebook. 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. Applicants will benefit from this expertise, even though third parties will be ineligible to register domains as all domains in the .KPMG registry will be owned by KPMG.
KPMG will comply with the procedures laid down by ICANN for the Trade Mark Claims process. We will send a notice to any registrant attempting to register a name identical to that in the Clearinghouse in the form required by ICANN and that the domain will only be registered if the representation set out in the Following registration, we will notify the holder of the trademark in the form required by ICANN.
B. Uniform Dispute Resolution Policy (UDRP) and Uniform Rapid Suspension (URS)
The UDRP is intended as an alternative dispute resolution process to transfer domain names from those that have registered and used domain names in bad faith. 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, giving the registrar a period of time in which to comply, failing which Neustar implements the decision.
KPMG will therefore have the ability to implement UDRP decisions. It will impose obligations on its registrar to ensure compliance with the UDRP and any decisions issued under it. It will also ensure that (where Neustar becomes aware that a registrar has failed to implement a decision) Neustar will itself implement that decision, As .KPMG is a single entity registry, the only remedy will be the cancellation of domains as the only permitted registrant will be KPMG.
In response to complaints by trademark owners that the UDRP was too costly and slow, and the fact that more than 70 percent of UDRP cases were “clear cut” cases of cybersquatting, ICANN adopted the IRT’s recommendation 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) or for anti-competitive purposes or denial of free speech, but rather 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 to 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 and would 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 reflects 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.
KPMG is fully aware of each of these requirements and will have the capability to implement these requirements, even though it is a single entity registry. KPMG and Neustar are committed to supporting the UDRP and the URS.
C The Post Delegation Dispute Resolution Procedure (PDDRP)
The PDDRP is an administrative (court alternative) option for trademark owners to file an objection against a registry whose “affirmative conduct” in its operation or use of its gTLD is alleged to cause or materially contribute to trademark abuse. In this way, the PDDRP is intended to act as a higher-level enforcement tool to assist ICANN compliance activities, where rights holders may not be able to continue to turn solely to lower-level multijurisdictional enforcement options in a vastly expanded DNS.
The PDDRP involves a number of procedural layers, such as an administrative compliance review, appointment of a “threshold review panel,” an expert determination as to liability under the procedure (with implementation of any remedies at ICANN’s discretion), a possible de novo appeal and further appeal to arbitration under ICANN’s registry terms. The PDDRP requires specific bad-faith conduct including profit from encouraging infringement in addition to “the typical registration fee.”
As set out in the Applicant Guidebook in the appendix summarizing the PDDRP, the grounds for a complaint on a second level registration are that , “(a) there is a substantial pattern or practice of specific bad faith intent by the registry operator to profit from the sale of trademark infringing domain names; and (b) the registry operator’s bad faith intent to profit from the systematic registration of domain names within the gTLD that are identical or confusingly similar to the complainant’s mark, which: (i) takes unfair advantage of the distinctive character or the reputation of the complainantʹs mark; or (ii) impairs the distinctive character or the reputation of the complainantʹs mark, or(iii) creates a likelihood of confusion with the complainantʹs mark.”.
Whilst we will co-operate with any complaints made under the PDDRP, we think it is highly improbable that any PDDRP complaints will succeed because the grounds set out above cannot be satisfied as domains in the .kpmg registry will not be for sale and cannot be transferred to third parties.
D. Implementation of Thick WHOIS
The .KPMG registry will include a thick WHOIS database as required in Specification 4 of the 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.
E. Policies Handling Complaints Regarding Abuse
In addition the Rights Protection mechanisms addressed above, KPMG will implement a number of measures to handle complaints regarding the abusive registration or use of domain names in its TLD as described in KPMG’s response to Question 28, even though, as a single entity private brand registry, it does not anticipate registrant abuse because all domains will be registered to KPMG.
Registry Acceptable Use Policy
One of the key policies each new gTLD registry will need is to have is an Acceptable Use Policy that clearly delineates the types of activities that constitute “abuse” and the repercussions associated with abusive domain name registration or use. KPMG’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, among other things. 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
KPMG 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 a real-time investigation by law enforcement.
Once a complaint is received from a trusted source, third-party, or detected by the Registry, the Registry will use best efforts to verify the information in the complaint. If that information can be verified to the best of the ability of the Registry, the sponsoring registrar will be notified and be given 12 hours to investigate the activity and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing 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), the Registry will 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.
29.2 Safeguards against Unqualified Registrations
All domains in .KPMG will be registered to KPMG for its own exclusive use and possibly for use by affiliates and KPMG will appear as the owner in all WHOIS records. KPMG may grant to affiliates a non-exclusive, non-transferable, worldwide limited license to use the domain names for a period of no less than one (1) year and no more than ten (10) years, commencing on the date on which the registration request was submitted by the approved registrar. KPMG will reserve the right to reject a registration request, or delete, revoke, suspend, cancel or transfer the licence to use .KPMG domain name at any time without notice at its sole discretion.
According to the registration policy of .KPMG, the domain names will have to be used in an acceptable manner and KPMG will undertake checks to ensure that the intended use of each domain conforms to the registration policy. According to the registration policy:
• Domains must be used solely for purposes that enhance the strategic or commercial interests of KPMG.
• Domain names must not be registered or used in a way that knowingly infringes any third party intellectual property rights.
• A domain name registration must be an acceptable term that will not give rise to any moral or public order questions or in any way damage the strategic interests or reputation of KPMG.
• Domains must not be delegated or assigned to external organisations, institutions, or individuals.
• If the registrant ceases to be a member of KPMG, then the registrant must cancel registration of that domain name within 14 days of ceasing to be a member.
KPMG’s registrar will have a contractual duty to under checks to validate the credentials of a requestor of a second level domain to ensure eligibility and acceptable use. KPMG will audit the work of the registrar at least twice a year.
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 will be the responsibility of the Engineering team, with guidance from the Product Management team. Customer Support and Legal will play a critical role in enforcing certain policies such as the rapid suspension process. 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 Neustar’s teams:
Development⁄Engineering – 19 employees
Product Management- 4 employees
Customer Support – 12 employees
The resources are more than adequate to support the rights protection mechanisms of the .KPMG registry. KPMG’s registrar will also be supporting KPMG by validating the eligibility of registration requests and helping with ICANN compliance and regulation of any abusive behaviors. The registrar will be dedicating the services of a Legal Manager and up to four operational experts to support KPMG.
29.4 Implementation Plans
We plan to introduce our Sunrise and IP Claims service to the following timetable:
Day One: Announcement of Registry Launch and publication of registry website with details of the Sunrise and TMCS
Day 30: Sunrise opens for 30 days
Day 60: Sunrise closes
Day 61: Publication of all domains applied for in our Thick Whois
Day 62: Registry Open, domains applied for in the Sunrise registered and TMCS (Trademark Claim Service) begins for 60 days
Day 122: TMCS ends; normal operations continue.
Our systems to support the implementation of complaints under the UDRP, the URS, and the PDDRP will be available from Day 30, as will Thick Whois.
The Implementation Team will create a formal Registry Launch plan by 1 December 2012. This will set out the exact process for the launch of the .KPMG registry and will define responsibilities and budgets. The KPMG Registry website, which is budgeted for in the three year plans provided in our answers to question 46 will be built within 30 days of pre-delegation testing starting. It will feature Rules of Registration, Rules of Eligibility, Terms & Conditions of Registration, Acceptable Use Policies as well as the Rules of the Sunrise, the Rules of the Sunrise Dispute Resolution Policy and the Rules of the Trademark Claims Service.
The registry website will promote the contact details of our Abuse Point of Contact which will be available 24⁄7.
We will comply with all requests from courts, law enforcement, and governmental bodies, and any decisions⁄judgments from UDRP and URS panels.
Technical implementation between the registry and the Trademark Clearinghouse will be undertaken by NeuStar as soon as practical after the Trademark Clearinghouse is operational and announces its integration process.
As demonstrated in our financial answers, a budget has been set aside to pay fees charged by the Trademark Clearinghouse Operator for this integration.
The contract we have with our registrar (the RAA) will require that the registrar adheres to the Terms & Conditions of the TMCH and will prohibit the registrar from filing domains in our registry on its own behalf or utilizing any data from the TMCH except in the provision of its duties as our registrar.
When processing TMCS claims, our registrar will be required to use the specific form of notice provided by ICANN in the Applicant Guidebook’.
We will also require our registrar to implement appropriate privacy policies reflecting the high standards that we set. See http:⁄⁄www.kpmg.com⁄Global⁄en⁄Pages⁄privacy.aspx.
29.5 Additional Mechanism that exceed requirements
Rights protection is at the core of KPMG’s objective in applying for this registry. Therefore we are committed to providing the following additional mechanisms:
Rights Protection Help Desk
We will maintain a Rights Protection Help Desk. Enquirers will be allocated a Case Number and the following details will be captured:
The contact details of the complainant
The domain name that is the subject of the complaint or query
The registered right, if any, that is associated with the request
An explanation of the issues such as why the complainant believes that its mark has been infringed
An initial response to a query or complaint will be made within 24 hours. The Rights Protection Help Desk will be in place on Day One of the registry. The cost of the Rights Help Desk is reflected in the Projections Templates provided at Q46 as part of on-going registry maintenance costs.
The aim of the Rights Protection Help Desk is to assist third parties in understanding the mission and purpose of our registry and to see if a resolution can be found that is quicker and easier than the filing of a UDRP or URS complaint.
Twice Yearly Registrar Accreditation & Audits
We will audit the performance of our registrar every six months and re-validate our Registry-registrar Agreements annually. Our audits will include site visits to ensure the security of data etc.
All requests for registration will be verified by our registrar to ensure that they come from a legitimate representative of KPMG. A record of the request will be kept in our on-line domain management console including the requestor’s email address and other contact information.
KPMG and our back-end operator, Neustar, recognize the vital need to secure the systems and the integrity of the data in commercial solutions. The .KPMG 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 .KPMG 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 .KPMG
4. List of commitments made to registrants regarding security levels
All of the security policies and levels described in this section are appropriate for the .KPMG 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.
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 Environmental 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.
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 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 .KPMG. 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 .KPMG 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 Document 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