Intuit Administrative Services, Inc.
2700 Coast Ave
Mountain View CA 94043
+1 650 944 6000
+1 650 944 5656
Mr. Christopher Niemi
Domain Operations Supervisor, MarkMonitor Inc.
+1 208 685 1857
+1 208 389 5771
Mr. Matthew Serlin
Vice President, Domain Management, MarkMonitor Inc.
+1 208 685 1864
+1 208 389 5771
Intuit Administrative Services, Inc. is a corporation under the laws of the state of Delaware in the United States pursuant to title 8 of the Delaware Code. The applicable sections may be found on the Internet at http:⁄⁄delcode.delaware.gov⁄title8⁄c001⁄index.shtml.
Intuit Inc. (NASDAQ: INTU; a Delaware Corporation)
|Jeffrey P. Hank||Director|
|Jeffrey P. Hank||Vice President, CFO & Treasurer|
|Jerome Natoli||President and CEO|
Applicant has consulted with its registry service operator regarding any potential rendering or operational problems with the applied-for gTLD. Because the applied-for TLD uses standard characters under The American Standard Code for Information Interchange (ASCII) standard, the registry service operator has ensured us that there are no known or likely operational or rendering problems.
Incorporated in Delaware in 1997, and headquartered in Mountain View, California, Intuit Administrative Services, Inc. (“Applicant”) is a wholly-owned subsidiary of Intuit Inc. (“Intuit”)—which has grown from a small start-up company that provided a simple version of personal financial software, starting in 1983, to a global software and services company with over 7,000 employees and world-renowned flagship software and internet-based services that, to-date, have been utilized by over fifty (50) million people in North America, Europe, India, Singapore, Australia, New Zealand and other countries.
Applicant will operate the proposed .INTUIT gTLD (“the TLD”) on behalf of and for the benefit of its parent company, Intuit, headquartered in Mountain View, California. Applicant’s parent company has been publicly traded on the NASDAQ stock exchange in the U.S. since 1993, with annual net revenue that now exceeds $3.8 billion USD, is a part of the NASDAQ 100 and S&P 500 Stock Indexes, and was recently named the “World’s Most Admired Software Company” for 2012 by Fortune Magazine.
Applicant and Intuit are committed to simplifying the business of life – by providing new and easier ways for consumers and businesses around the world to successfully manage their productivity challenges. Accordingly, Intuit—both directly and through its various subsidiaries—continually strives to foster innovation in the delivery of productivity software and services. Indeed, to that end, Intuit and its subsidiaries now offer such software and services in a host of different ways—including through various mobile applications and devices, and through cloud-based platforms.
Applicant recognizes that as boundaries blur among PCs, mobile devices and platforms, with rapidly changing technological advances, the TLD offers Applicant and its parent the ability and opportunity to expand Intuit’s web presences, its existing suite of services and solutions and its long history of innovation, all into a new and exciting Internet space.
One mission of Applicant is to assist its parent to be a premier innovator and leader in mobile and web-based productivity and business solutions—with solutions that are so profoundly easy and useful that people who use them can’t imagine going back to the old way of doing things.
The TLD will enable Applicant and its parent to further the goal of adapting and evolving to ever-changing trends and opportunities in delivering, hosting and marketing these products and services.
Upon delegation of the TLD, and in keeping with Intuit’s mission to be a premier innovator in the financial and business software and services space, Applicant will initially conduct consumer-related research, such as marketing and⁄or technical research and testing, to determine the most effective and safest way for Applicant and its parent to market and provide its software and services to its consumers through the new TLD.
During this initial research period, Applicant and its parent will evaluate how best to use the TLD to provide information or services to the public, to prospects and to existing customers, but proposes to reserve the right to use the TLD for internal registrants and purposes, including the creation of the parent’s and its subsidiaries’ own test offerings and their own online marketing (for external viewing). Applicant will also research consumer- and security-based testing of the TLD for possible later public use. After the research is completed, Applicant proposes to either reserve the right to continue limiting its TLD use to internal registrants, as described herein, or, if an adequately-secure public use is requested by consumers and proven viable, to expand its use of the TLD accordingly to match Applicant’s customers’, third-party partners’ and Affiliates’ expectations.
Applicant recognizes that it is vital for every small business to have a website. In fact, Applicant’s sister business unit within Intuit—the “Grow Your Business” division—makes this process easy by providing the website creation and hosting services small businesses need to establish their Internet presences, including: domain name registration (through a strategic channel sales relationship with Tucows.com Inc., an ICANN-Accredited Registrar); self-service tools for building a professional-looking website; ecommerce and payments tools for selling products online; and web hosting. This “Grow Your Business” division takes pride in making it simple for both consumers and small businesses alike to create a website in minutes, regardless of technical skills or design experience. At present, hundreds of thousands of customers rely on these website services for their Internet websites and domain names. Applicant is willing to supply ICANN with additional information about the Grow Your Business division’s reseller relationship with Tucows.com Inc. upon request.
Currently, there is no top-level domain dedicated to personal and small business productivity applications and services, and no top-level domain dedicated to Intuit’s brand. The goal of the TLD, in terms of specialty, is to securely provide a top-level domain dedicated to providing products to Internet users and customers around the globe under Intuit’s famous and trusted brand.
Allowing Applicant to control its own Internet space for its parent’s famous brand gives it the ability to customize domain and website names for Intuit’s and fellow subsidiaries’ offerings and signal to the general population of Internet users that websites within the TLD will indeed be securely controlled by Applicant without having to incorporate traditional unrelated gTLD terms such as 〈.com〉, 〈.net〉, or 〈.biz〉. In addition, the TLD will permit Intuit, Applicant and Applicant’s other Affiliates to send a consistent and focused branding image to web users across the globe, without the registration and operation impediments that can be inherent in ccTLDs. This specialty will benefit Internet users seeking a secure, authenticated online avenue to utilize Applicant’s software products or services without the worry that they will become the next phishing or counterfeiting victim. This is particularly and uniquely important in the areas of personal and business financial software and services.
This specialization simultaneously makes it easier for Internet users who are looking for Applicant or parent-related information—and personal⁄business productivity information—to locate this information more efficiently. The TLD’s appendage indicates to users what they can expect to find at all websites under the TLD—namely, premier and authentic software and online services offered by the Applicant’s parent and Affiliates and the reputable Intuit Brand. The INTUIT brand stands for simplicity, quality, security, and value in a critically important segment of the technology sector where billions of dollars flow through Intuit solutions to enable everything from credit card processing to small business payroll.
It also presents another added benefit in that web addresses can become shorter. One impact of a dearth of “good”, short web addresses has been for them to become lengthier and more complex over time. Using the TLD not only means Applicant’s sites can benefit from having an important keyword in their web addresses, but it will also be easier and faster to type in addresses. Built into a wider process of web optimization and marketing, the TLD’s inclusion as a consistent keyword into domain names will likely have positive implications for specialty, security, and global promotional purposes – not only for Applicant, its parent and Affiliates, but for those who collaborate with them – like end-user customers (through Intuit’s online communities), members of Intuit’s accounting professionals networks and third-party software developers (whose complementary products and services are promoted via Intuit sites). Applicant anticipates that the TLD will increase traffic to Affiliates’ and these other constituents’ websites and facilitate consumer use and trust.
Customer satisfaction is paramount to the Intuit brand’s success and Applicant, Intuit and Intuit’s other subsidiaries seek to establish long-term relationships with customers and partners based on trust and responsiveness. Indeed, all of Intuit’s companies’ success depends upon meeting the companies’ commitments to outstanding customer relations as well as extremely careful Affiliate selection, as defined below in Section IV.
Accordingly, if made public, the goal of the TLD will be to ensure that the highest level of security, quality, and customer service is provided to Applicant’s and its Affiliates’ customers, for whom security and quality is a high-priority concern—especially in the financial, tax and business services realms. Initially, this entails ensuring that only Applicant and its Affiliates are able to register and control the second-level domain names in the TLD. Regarding the technical and operational aspects of service levels, this entails contracting with and using industry experts to provide the highest possible quality in registry and registrar services so as to operate the TLD smoothly and protect the security and quality of any information that Applicant will receive or provide through the TLD.
Applicant and its Affiliates will further endeavor, as they do with current websites, to provide—for any outwardly-facing domain name and website in the TLD—fast and responsive customer service contact options available in English during normal business hours by email or chat, or in certain cases telephone, seven (7) days per week, to help any customer attempting to learn about, purchase or obtain support for Applicant’s Affiliates’ software products and services. Similarly, Applicant or its Affiliates will provide a high level of service to trademark and other legal rights owners by providing an easily accessible point-of-contact on all outwardly-facing domain names and websites.
Applicant will ensure that it is providing an exceptional specialized user experience within the TLD. To do this, Applicant will employ testing to discern what user expectations are for an Intuit-branded TLD, and related Web experience, and then tailor the TLD to those expectations. For example, when designing its current websites or adding a new look to its homepage, Applicant’s Affiliates ensure that such sites will ultimately serve the Internet user, rather than merely its own internal goals or bottom line. The homepage interface in the TLD will be clear and simple, with pages loading quickly. Affiliate’s software products and services will be provided through secure websites and networks at high speeds. Applicant and its Affiliates will continue to operate under this principle when designing websites and providing access to high-quality financial and productivity software and services through the TLD.
As web-based financial and productivity platforms are among the most targeted by cyberattacks and attempted fraud, one TLD goal is to further assist Applicant in providing its parent and other sister subsidiaries with another means to ensure even greater quality, authentication and security—through a uniquely technologically secure and advanced online environment. The TLD will provide an environment in which customers around the world can learn about and access the software products and services provided by Applicant’s parent and sister subsidiaries with certainty—by readily seeing the domain and knowing that they are interacting with the highly-reputable Intuit Brand.
Applicant, in conjunction with its parent and its other Affiliates, represents a brand that already has a reputation for excellence and superior quality in the software industry, including online through its Affiliates’ current websites and domain names. Indeed, the type of financial software products and services involved are among the most targeted by attempted phishing, counterfeiting and other attempted fraudulent online activity, and Applicant seeks, through the operation of the TLD, to maintain a reputation for providing a secure online environment for all Internet users to access financial, business management and even healthcare-related software and content more efficiently. Applicant, through its affiliates, also has a reputation for enhanced creative capabilities and innovation in the software industry. A primary goal of the TLD, if made public, will be to continue to promote Applicant’s reputation for excellence, creativity and innovation.
The Registry will initially be known for ensuring only Applicant and Applicant’s Affiliates register domain names in the TLD, that those domain names are used for Applicant-related purposes at the direction of Applicant, that the WHOIS is thick and reliable, and that the Registry is responsive to legal rights owners. Indeed, when Internet users visit a website within the TLD, they should know that Applicant and its parent Intuit will be the entities standing behind Intuit’s world-renowned software products and services, and that they can expect the highest level of online service and security. In all, Applicant will strive to continue to be known as an exemplary and model domain name services citizen through the use of the TLD.
The TLD will enhance competition in Applicant’s Affiliates’ existing and new markets by allowing Applicant and Intuit the additional space and flexibility to further innovate and create new online goods and services, and to reach new geographic areas with a consistent branding message—the latter being something that is presently hampered by variances in ccTLD registration and operation policies.
The TLD will also enhance Applicant’s and Affiliates’ ability to create innovative approaches to marketing their high-quality products and services online through the use of unique, new and shorter second-level domains that delight consumers. Applicant further believes that these innovations and consistencies in how the Applicant and Affiliates will provide and market high-quality software products and services online will also incentivize other technology and online services companies that operate on existing and new top-level domains to improve the security and quality of their own online offerings and storefronts and to accelerate the introduction of new goods and services in order to continue attracting new customers. Thus, the entry of the TLD will benefit consumers by increasing the likelihood of the successful introduction of new and innovative online goods and services from both Applicant’s Affiliates and also from the software and online services industry as a whole.
The TLD will be differentiated from all other top-level domains currently available in the marketplace. Applicant’s Affiliates will be able to affix the famous Intuit brand to a broad set of second-level domains and indicate to Internet users the source of the TLD. Indeed, no other existing top-level domain is similar in appearance to the TLD, none is used exclusively for high-quality financial and business management software and services (including mobile and software-as-a-service offerings), and none exclusively serves Applicant’s current and prospective customers. Finally, unlike in existing top-level domains, initially only Applicant and Applicant’s Affiliates will be allowed to register or operate domain names within the TLD, allowing the TLD to become unique in that customers will not have to fear fraudulent sites, malware, security issues, spam, phishing, counterfeit products or information that is false or inaccurate, emanating from the domain.
Applicant’s parent company, Intuit, is already a recognized leader in innovation. Indeed, Forbes recently named Intuit number 84 in the “World’s Most Innovative Companies” List for 2011. Technological innovation is a critical element of Intuit’s strategies, and is at the forefront of all Affiliates’ online software and service presences. Moreover, Intuit, and its subsidiaries strive to create an innovation culture among their employees. This is perhaps best evidenced by recognition that Intuit, for the last ten (10) consecutive years, has been recognized as one of “Americaʹs 100 Best U.S. Companies to Work for” by Fortune Magazine. This award incorporates direct feedback from employees about their ability to innovate and focus on customer delight.
Most importantly, Applicant believes that the TLD will open up significant new opportunities and permit Applicant to more easily enable the testing and launch an increasing number of new innovations. With the TLD, Applicant can test new applications and platforms with consumers to facilitate their desired Web and mobile experiences. The Applicant will have the capacity to allow its Affiliates to explore marketing and branding strategies that incorporate the new TLD and discover new ways to rapidly test consumer reaction to marketing, discounts, user interface differences, and other customized offerings that are valuable to them. This innovation will promote competition on the Internet and provide more innovations and higher levels of service to the Affiliates’ users and customers. Moreover, the TLD will be innovative in that—for the first time—it will allow more people to have greater access to a dedicated and secure top-level domain for Applicant’s broad set of cutting-edge software products and services. The TLD will also allow Applicant to securely host its own platforms and infrastructure in new ways.
iii. Similar to how it operates its current domain names and websites in third-party top-level domains, Applicant will strive to test, develop, and implement the TLD and its websites to satisfy its customers’ and prospects’ expectations in the most secure and user-friendly manner possible. In doing so, Applicant will take great care to ensure that domain names in the TLD will ultimately serve the Internet user, not just its or its Affiliates own internal infrastructure goals or bottom line.
Accordingly, Applicant will rely on its consumer- and security-driven testing to provide the best user experience possible—which will be enabled by the ability to use multiple second-level domains within the TLD to provide different experiences to different consumers and test their preferences—all in order to improve their experience with Applicant’s Affiliates’ offerings. Because users will know that Applicant will own and operate all domain names in the TLD, Applicant anticipates that the TLD will provide an enhanced and more-secure online experience for those interested in obtaining information about and access to Applicant’s products and services. The TLD will differentiate Applicant from other providers of financial and business productivity software and online services and create a more stable, competitive, expansive and active marketplace in the industry.
iv. In order to support the goals listed above, only Applicant through its parent’s authorized employees will be able to register domain names within the TLD. Thus, the general public will not be allowed to register, buy, or sell domain names in the TLD. Applicant, however, reserves the right to sell, distribute, or transfer control or use of any registrations in the TLD to any third party that is an Affiliate of Applicant (under the control of Applicant or its parent company) for uses as specified by Applicant. Affiliate will be defined for the purpose of this application as a person or entity that, directly or indirectly, through one or more intermediaries, controls, is controlled by, or is under common control with, the person or entity specified (i.e., Applicant). Control (including the terms “controlled by” and “under common control with”) means the possession, directly or indirectly, of the power to direct or cause the direction of the management or policies of a person or entity, whether through the ownership of securities, as trustee or executor, by serving as an employee or a member of a board of directors or equivalent governing body, by contract, by credit arrangement or otherwise.
As stated above, Applicant intends to operate a closed registry in order to enable its parent to offer the software-based products and services it currently offers on its existing websites in existing top-level domains, together with new innovations and offerings Applicant and⁄or its Affiliates plan to develop. Accordingly, TLD policies and decisions for domain name registration and use will continue to be provided through an internal team consisting of Applicant’s or its parent’s existing business, marketing and technical decision-makers, utilizing existing well-established internal processes. As a publicly-traded company, Applicant’s parent has extensive controls already in place to ensure legal and operational compliance.
The TLD’s domain name policies will be limited by its abuse prevention and rights protection policies discussed further herein, and Applicant will strive to avoid registering domain names that are confusingly similar to third-parties’ trademarks and related rights. Obscene, explicit, and offensive domain names will be precluded from registration.
v. Keeping customer information secure and private is of crucial importance to providers of financial-related software and online services—especially Applicant’s parent and other Affiliates. That said, initially, Applicant intends to operate a registry as a closed TLD, with access limited to Applicant’s and Affiliates’ authorized employees. As Applicant’s use may expand, Applicant will take commercially reasonable steps to maintain the security and privacy of the information collected therein, and will remain in compliance with confidentiality and security regulations in relevant jurisdictions.
Applicant’s parent, Intuit, already has well-established Privacy Policies in the U.S. and global jurisdictions to safeguard its customers’ information, which Applicant will also adopt. Intuit also works closely with third-party privacy standards bodies. See e.g. Intuit, Privacy Highlights, available at http:⁄⁄security.intuit.com⁄privacy⁄ (Feb. 10, 2010).
If the TLD becomes publicly visible such that external users are interacting with content and information about software products and services accessed through the TLD, Applicant or its Affiliates will, at a minimum, provide similar security and privacy policies and measures that clearly outline how Applicant or its Affiliates protect the privacy and confidentiality of visitors and users, and provide users with industry-leading clarity and choice options with respect to how their data is used, according to then-current Applicant and Affiliate policies and the relevant laws in the appropriate jurisdictions.
vi. In the event that the TLD is publicly used, outreach and communication will be among Applicant’s and Intuit’s important goals in connection with the TLD. Given Applicant’s and its Affiliates’ intent to use the TLD to expand the Affiliates’ offerings, testing and marketing, Applicant will certainly institute marketing and outreach efforts to inform the public about new SLDs within the TLD in order to draw consumers to such new offerings, tests and marketing materials—including the applications, services, content and information hosted therein.
Applicant’s parent already uses several different outreach and communications methods and venues to get its mission and messages to the public about the value of using its offerings, including but not limited to: press releases; social media engagement tools, blogs, YouTube videos, Twitter, and Facebook pages; various global news feeds; and paid advertising, including television, print publications, and search. If the TLD is expanded to enable use and registration of second-level domains by the general Internet public, Applicant or its Affiliates will be able to incorporate the outreach and communication regarding the TLD into its current branding, public relations and marketing channels and efforts to ensure that as many prospective customers and users as possible understand the new resources available and how to interact with them.
i. How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first-serve basis?
Members of the public will not be able to register domain names in the TLD. Registration will be tightly controlled by Applicant, and initially only designated Applicant or Affiliate personnel will be able to register domain names for purposes relating solely to Applicant or Affiliates after approval by Applicant’s designated existing business, marketing and technical decision-making channels. Therefore, there will not be multiple applications for a particular domain name.
ii. Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).
Members of the public will be unable to register domain names in the TLD. Applicant will tightly control registration, and initially only designated Applicant or Affiliate personnel will be able to register domain names for purposes relating to Applicant or Affiliates after approval by Applicant’s existing business, marketing and technical decision-making channels. Therefore, because Applicant will not sell the domain names in the TLD, there are no cost benefits for registrants to implement.
iii. Note that 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 ten 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? If so, please describe your plans.
Members of the public will be unable to register domain names in the TLD. Applicant will tightly control registration, and initially only designated Applicant personnel will be able to register domain names for purposes relating to Applicant after approval by Applicant’s existing business, marketing and technical decision-making channels. Therefore, because Applicant will not sell the domain names in the TLD, contractual commitments to registrants regarding price escalation are not relevant to Applicant’s mission or TLD goals in the foreseeable future.
As specified throughout this application, Applicant plans to operate the applied-for TLD as a closed registry and shall not permit any third party to register any second-level domain names within the TLD. Applicant will thus primarily protect against the abusive registration of geographic names at the second and other levels in the applied-for gTLD by only allowing Applicant to register and Applicant or its Affiliates (as defined in its registration policy) to use any domains throughout the life of the TLD.
Applicant has thoroughly reviewed Specification 5 of the Registry Agreement, the Government Advisory Committee’s (GAC) “Principles regarding New gTLDs”, and the .INFO methodology for reservation and release of country names. Accordingly, Applicant will, in connection with its registry services operator and registrar, initially reserve and hold back from registration by any party names with national or geographic significance at the second level and all other levels within the TLD during the TLD’s Sunrise Period and Trademark Claims Period.
The names with national or geographic significance (“geographic names”) that will be initially blocked are those specified in Specification 5 of the New gTLD Registry Agreement, namely:
1. the short form (in English) of all country and territory names contained on the ISO 3166-1 list, as updated from time to time, including the European Union, which is exceptionally reserved on the ISO 3166-1 list, and its scope extended in August 1999 to any application needing to represent the name European Union;
2. 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
3. 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.
After working with Applicant’s registry services provider to initially block the above-identified geographic names during any Sunrise Period and Trademark Claims Period, Applicant may allow the reservation of domain names identical to the above-identified geographic names by only Applicant itself. Thereafter, Applicant will ensure through internal guidelines and strict internal process governance and⁄or by contract that the geographic names will be used only by Applicant and⁄or its Affiliates for promoting, providing information about, and⁄or offering Applicant’s goods and services directly to the customers or potential customers from the relevant country or territory indicated by the domain name. At all times, Applicant will ensure through internal guidelines and strict internal process governance that all reasonable efforts will be made to reduce and minimize user confusion regarding the source or affiliation of any geographic domain name, and that security measures will be taken to protect confidential third-party information in accordance with that geographic area’s data and financial privacy laws. Additionally, since Applicant will be the only registrant of domains within the TLD, users around the world will understand that only Applicant and its affiliates will be the source of domain names within the TLD.
Intuit Administrative Services, Inc. has elected to partner with Neustar, Inc, to provide back-end services for the .intuit registry. In making this decision, Intuit Administrative Services, Inc. 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. These existing registry services will be leveraged for the .intuit 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. Intuit Administrative Services, Inc. will use Neustar’s Registry Services platform to deploy the .intuit registry, by providing the following Registry Services (none of these services are offered in a manner that is unique to .intuit):
- Registry-Registrar Shared Registration Service (SRS)
- Extensible Provisioning Protocol (EPP)
- Domain Name System (DNS)
- Data Escrow
- Dissemination of Zone Files using Dynamic Updates
- Access to Bulk Zone Files
- Dynamic WHOIS Updates
- IPv6 Support
- 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 .intuit 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.
Intuit Administrative Services, Inc. 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 .intuit. The service provides support for near real-time dynamic updates. The design and construction is agnostic with regard to data display policy and 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.
23.2.6 Data Escrow
Data escrow will be performed in compliance with all ICANN requirements in conjunction with an approved data escrow provider. The data escrow service will:
- Protect against data loss
- Follow industry best practices
- Ensure easy, accurate, and timely retrieval and restore capability in the event of a hardware failure
- Minimizes the impact of software or business failure.
Additional information on the Data Escrow service is provided in the response to Question 38.
23.2.7 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.
23.2.8 Access to Bulk Zone Files
Intuit Administrative Services, Inc. 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.
23.2.9 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.
23.2.10 IPv6 Support
The .intuit 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.
23.2.11 Required Rights Protection Mechanisms
Intuit Administrative Services, Inc., will provide all ICANN required Rights Mechanisms, including:
- Trademark Claims Service
- Trademark Post-Delegation Dispute Resolution Procedure (PDDRP)
- Registration Restriction Dispute Resolution Procedure (RRDRP)
- Sunrise service.
More information is presented in the response to Question 29.
23.2.12 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
Intuit Administrative Services, Inc. will not be offering services that are unique to .intuit.
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.
Intuit Administrative Services, Inc. has partnered with Neustar, Inc, an experienced TLD registry operator, for the operation of the .intuit Registry. The applicant is confident that the plan in place for the operation of a robust and reliable Shared Registration System (SRS) as currently provided by Neustar will satisfy the criterion established by ICANN.
Neustar built its SRS from the ground up as an EPP based platform and has been operating it reliably and at scale since 2001. The software currently provides registry services to five TLDs (.BIZ, .US, TEL, .CO and .TRAVEL) and is used to provide gateway services to the .CN and .TW registries. Neustar’s state of the art registry has a proven track record of being secure, stable, and robust. It manages more than 6 million domains, and has over 300 registrars connected today.
The following describes a detailed plan for a robust and reliable SRS that meets all ICANN requirements including compliance with Specifications 6 and 10.
24.2 The Plan for Operation of a Robust and Reliable SRS
24.2.1 High-level SRS System Description
The SRS to be used for .intuit 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 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, Intuit Administrative Services, Inc. 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).
24.2.2 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
- Transaction Details
- Processing Time.
In addition to logging of each and every transaction with the SRS, Neustar maintains audit records, in the database, of all transformational transactions. These audit records allow the Registry, in support of the applicant, to produce a complete history of changes for any domain name.
24.2.3 SRS Design
The SRS incorporates a multi-layer architecture that is designed to mitigate risks and easily scale as volumes increase. The three layers of the SRS are:
- Protocol Layer
- Business Policy Layer
Each of the layers is described below.
24.2.4 Protocol Layer
The first layer is the protocol layer, which includes the EPP interface to registrars. It consists of a high availability farm of load-balanced EPP servers. The servers are designed to be fast processors of transactions. The servers perform basic validations and then feed information to the business policy engines as described below. The protocol layer is horizontally scalable as dictated by volume.
The EPP servers authenticate against a series of security controls before granting service, as follows:
- The registrar’s host exchanges keys to initiates a TLS handshake session with the EPP server.
- The registrar’s host must provide credentials to determine proper access levels.
- The registrar’s IP address must be preregistered in the network firewalls and traffic-shapers.
24.2.5 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.
Figure 24-1 depicts the overall SRS architecture including network components.
24.2.7 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 .intuit registry, the SRS will operate with 8 protocol servers and 6 policy engine servers. These expand horizontally as volume increases due to additional TLDs, increased load, and through organic growth. In addition to the SRS servers described above, there are multiple backend servers for services such as DNS and WHOIS. These are discussed in detail within those respective response sections.
24.2.8 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 .intuit.
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:
24.2.9 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.
24.2.10 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.
24.2.11 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.
24.2.12 Data Warehouse
The data warehouse is responsible for managing reporting services, including registrar reports, business intelligence dashboards, and the processing of data escrow files. The Reporting Database is used to create both internal and external reports, primarily to support registrar billing and contractual reporting requirement. The data warehouse databases are updated on a daily basis with full copies of the production SRS data.
24.2.13 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.
24.2.14 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.
24.2.15 Compliance with Specification 6 Section 1.2
The SRS implementation for .intuit 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.
24.2.16 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 .intuit 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:
- Database Administration
- Systems Administration
- Network Engineering.
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 .intuit 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 .intuit registry.
Intuit Administrative Services, Inc.’s back-end registry operator, Neustar, Inc, 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 Intuit Administrative Services, Inc. is provided with an unparalleled EPP based registry. The following discussion explains the EPP interface which will be used for the .intuit registry. This interface exists within the protocol farm layer as described in Question 24 and is depicted in Figure 25-1.
25.2 EPP Interface
Registrars are provided with two different interfaces for interacting with the registry. Both are EPP based, and both contain all the functionality necessary to provision and manage domain names. The primary mechanism is an EPP interface to connect directly with the registry. This is the interface registrars will use for most of their interactions with the registry.
However, an alternative web GUI (Registry Administration Tool) that can also be used to perform EPP transactions will be provided. The primary use of the Registry Administration Tool is for performing administrative or customer support tasks.
The main features of the EPP implementation are:
- Standards Compliance: The EPP XML interface is compliant to the EPP RFCs. As future EPP RFCs are published or existing RFCs are updated, Neustar makes changes to the implementation keeping in mind of any backward compatibility issues.
- Scalability: The system is deployed keeping in mind that it may be required to grow and shrink the footprint of the Registry system for a particular TLD.
- Fault-tolerance: The EPP servers are deployed in two geographically separate data centers to provide for quick failover capability in case of a major outage in a particular data center. The EPP servers adhere to strict availability requirements defined in the SLAs.
- Configurability: The EPP extensions are built in a way that they can be easily configured to turn on or off for a particular TLD.
- Extensibility: The software is built ground up using object oriented design. This allows for easy extensibility of the software without risking the possibility of the change rippling through the whole application.
- Auditable: The system stores detailed information about EPP transactions from provisioning to DNS and WHOIS publishing. In case of a dispute regarding a name registration, the Registry can provide comprehensive audit information on EPP transactions.
- Security: The system provides IP address based access control, client credential-based authorization test, digital certificate exchange, and connection limiting to the protocol layer.
25.3 Compliance with RFCs and Specifications
The registry-registrar model is described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. As shown in Table 25-1, EPP is defined by the core set of RFCs that standardize the interface that registrars use to provision domains with the SRS. As a core component of the SRS architecture, the implementation is fully compliant with all EPP RFCs.
Neustar ensures compliance with all RFCs through a variety of processes and procedures. Members from the engineering and standards teams actively monitor and participate in the development of RFCs that impact the registry services, including those related to EPP. When new RFCs are introduced or existing ones are updated, the team performs a full compliance review of each system impacted by the change. Furthermore, all code releases include a full regression test that includes specific test cases to verify RFC compliance.
Neustar has a long history of providing exceptional service that exceeds all performance specifications. The SRS and EPP interface have been designed to exceed the EPP specifications defined in Specification 10 of the Registry Agreement and profiled in Table 25-2. Evidence of Neustar’s ability to perform at these levels can be found in the .biz monthly progress reports found on the ICANN website.
25.3.1 EPP Toolkits
Toolkits, under open source licensing, are freely provided to registrars for interfacing with the SRS. Both Java and C++ toolkits will be provided, along with the accompanying documentation. The Registrar Tool Kit (RTK) is a software development kit (SDK) that supports the development of a registrar software system for registering domain names in the registry using EPP. The SDK consists of software and documentation as described below.
The software consists of working Java and C++ EPP common APIs and samples that implement the EPP core functions and EPP extensions used to communicate between the registry and registrar. The RTK illustrates how XML requests (registration events) can be assembled and forwarded to the registry for processing. The software provides the registrar with the basis for a reference implementation that conforms to the EPP registry-registrar protocol. The software component of the SDK also includes XML schema definition files for all Registry EPP objects and EPP object extensions. The RTK also includes a “dummy” server to aid in the testing of EPP clients.
The accompanying documentation describes the EPP software package hierarchy, the object data model, and the defined objects and methods (including calling parameter lists and expected response behavior). New versions of the RTK are made available from time to time to provide support for additional features as they become available and support for other platforms and languages.
25.4 Proprietary EPP Extensions
The .intuit 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 .intuit 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 .intuit 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 .intuit registry.
Intuit Administrative Services, Inc. (“Applicant”) 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 and relevant RFCs for its proposed gTLD (“the TLD”).
Applicant’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, the WHOIS service provided by Applicant’s registry services provider has been designed from the ground up to display as much information as required by ICANN and respond to a very stringent availability and performance requirement.
Some of the key features of Applicant’s WHOIS services will include:
• Fully compliant with all relevant RFCs including 3912;
• Production proven, highly flexible, and scalable (applicant’s back-end registry services provider has a track record of 100% availability over the past ten (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; and
• Search capabilities (e.g., IDN, registrant data) that mitigate potential forms of abuse as discussed below.
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.
Applicant’s registry services operator will provide thick WHOIS services that are fully compliant with RFC 3912 and with Specifications 4 and 10 of the Registry Agreement. 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.
Applicant’s WHOIS service will support port 43 queries, and will be optimized for speed using an in-memory database and a master-slave architecture between SRS and WHOIS slaves. RFC 3912 is a simple text based protocol over TCP that describes the interaction between the server and client on port 43. Applicant’s registry services operator built a home-grown solution for this service. It currently processes millions of WHOIS queries per day.
In addition to the WHOIS Service on port 43, Applicant will provide a Web-based WHOIS application, which will be located at Applicant’s website. This WHOIS Web application will be an intuitive and easy to use application for the general public to use. The
WHOIS Web application provides all of the features available in the port 43 WHOIS. This includes full and partial search on:
• Domain names
• Registrant, Technical and Administrative Contacts
The WHOIS web application will also provide features not available on the port 43 service. These include:
• 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.
• Extensive support for international domain names (IDN)
• Ability to perform WHOIS lookups on the actual Unicode IDN
• Display of the actual Unicode IDN in addition to the ACE-encoded name
• A Unicode to Punycode and Punycode to Unicode translator
• An extensive FAQ
• A list of upcoming domain deletions
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.
Applicant will also provide 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 to find exact or partial matches using any one or more of the following fields:
• Domain name
• 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.)
• Registrar ID
• Name server name and IP address
• Internet Protocol addresses
• The system will also allow search using non-Latin character sets which are compliant with IDNA specification
Figure 26-2 shows an architectural depiction of the new service.
The WHOIS user will be able to 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 and their WHOIS information will quickly be returned to the user.
In order to reduce abuse for this feature, only authorized users will have access to the Whois search features after providing a username and password. To further 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
• Data encryption
• 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 Applicant’s registry.
Applicant will also provide ICANN and any emergency operators with up-to-date Registration Data on a weekly basis (the day to be designated by ICANN). Data will include data committed as of 00:00:00 UTC on the day previous to the one designated for retrieval by ICANN. The file(s) will be made available for download by SFTP, unless ICANN requests other means in the future.
Applicant’s Registry Services Liaison(s) will regular monitor the registry service provider to ensure that they are providing the services as described above. This will entail random monthly testing of the WHOIS port 43 and Web-based services to ensure that they meet the ICANN Specifications and RFCs as outlined above, if not, to follow up with the registry services provider to ensure that they do. As the relevant WHOIS will only contain Applicant’s information, Applicant’s WHOIS services will necessarily be in compliance with any applicable privacy laws or policies.
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 TLD. The resources are more than adequate to support the WHOIS needs of all the TLDs operated by Neustar, including Applicant’s TLD.
27.1 Registration Life Cycle
.intuit will follow the lifecycle and business rules found in the majority of gTLDs today. Intuit Administrative Services, Inc.’s selected back-end operator for .intuit, Neustar, Inc, 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 use for .intuit.
27.1.2 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 .intuit registry per the defined .intuit 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 .intuit 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 .intuit 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 .intuit 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.
27.2 Registration States
27.2.1 Domain Lifecycle – Registration States
As described above the .intuit registry will implement a standard domain lifecycle found in most gTLD registries today. There are five possible domain states:
- Pending Transfer
- Pending Delete.
All domains are always in either an Active or Inactive state, and throughout the course of the lifecycle may also be in a Locked, Pending Transfer, and Pending Delete state. Specific conditions such as applied EPP policies and registry business rules will determine whether a domain can be transitioned between states. Additionally, within each state, domains may be subject to various timed events such as grace periods, and notification periods.
27.2.2 Active State
The active state is the normal state of a domain and indicates that delegation data has been provided and the delegation information is published in the zone. A domain in an Active state may also be in the Locked or Pending Transfer states.
27.2.3 Inactive State
The Inactive state indicates that a domain has not been delegated or that the delegation data has not been published to the zone. A domain in an Inactive state may also be in the Locked or Pending Transfer states. By default all domain in the Pending Delete state are also in the Inactive state.
27.2.4 Locked State
The Locked state indicates that certain specified EPP transactions may not be performed to the domain. A domain is considered to be in a Locked state if at least one restriction has been placed on the domain; however up to eight restrictions may be applied simultaneously. Domains in the Locked state will also be in the Active or Inactive, and under certain conditions may also be in the Pending Transfer or Pending Delete states.
27.2.5 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.
27.2.6 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.
27.3 Typical Registration Lifecycle Activities
27.3.1 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.
27.3.2 Update Process
Registry objects may be updated (modified) using the EPP Modify operation. The Update transaction updates the attributes of the object.
For example, the Update operation on a domain name will only allow the following attributes to be updated:
- Domain statuses
- Registrant ID
- Administrative Contact ID
- Billing Contact ID
- Technical Contact ID
- 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.
27.3.4 Renew Process
The term of a domain may be extended using the EPP Renew operation. ICANN policy general establishes the maximum term of a domain name to be 10 years, and Neustar recommends not deviating from this policy. A domain may be renewed⁄extended at any point time, even immediately following the initial registration. The only stipulation is that the overall term of the domain name may not exceed 10 years. If a Renew operation is performed with a term value will extend the domain beyond the 10 year limit, the Registry will reject the transaction entirely.
27.3.5 Transfer Process
The EPP Transfer command is used for several domain transfer related operations:
- Initiate a domain transfer
- Cancel a domain transfer
- Approve a domain transfer
- Reject a domain transfer.
To transfer a domain from one Registrar to another the following process is followed:
1. The gaining (new) Registrar submits a Transfer command, which includes the AuthInfo code of the domain name.
2. If the AuthInfo code is valid and the domain is not in a status that does not allow transfers the domain is placed into pendingTransfer status
3. A poll message notifying the losing Registrar of the pending transfer is sent to the Registrar’s message queue
4. The domain remains in pendingTransfer status for up to 120 hours, or until the losing (current) Registrar Acks (approves) or Nack (rejects) the transfer request
5. If the losing Registrar has not Acked or Nacked the transfer request within the 120 hour timeframe, the Registry auto-approves the transfer
6. The requesting Registrar may cancel the original request up until the transfer has been completed.
A transfer adds an additional year to the term of the domain. In the event that a transfer will cause the domain to exceed the 10 year maximum term, the Registry will add a partial term up to the 10 year limit. Unlike with the Renew operation, the Registry will not reject a transfer operation.
27.3.6 Deletion Process
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.
27.4 Applicable Time Elements
The following section explains the time elements that are involved.
27.4.1 Grace Periods
There are six grace periods:
- Add-Delete Grace Period (AGP)
- Renew-Delete Grace Period
- Transfer-Delete Grace Period
- Auto-Renew-Delete Grace Period
- Auto-Renew Grace Period
- Redemption Grace Period (RGP).
The first four grace periods listed above are designed to provide the Registrar with the ability to cancel a revenue transaction (add, renew, or transfer) within a certain period of time and receive a credit for the original transaction.
The following describes each of these grace periods in detail.
27.4.2 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.
27.4.3 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).
27.4.4 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.
27.4.5 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.
27.4.6 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.
27.4.7 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.
27.5 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.
27.5.1 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 Applicant to determine the precise rules that meet the requirements of the TLD. Implementation of the lifecycle rules will be the responsibility of Development⁄Engineering team, with testing performed by the Quality Assurance team. Neustar’s SRS implementation is very flexible and configurable, and in many case development is not required to support business rule changes.
The .intuit 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 .intuit registry.
Abuse within the TLD will not be tolerated. Intuit Administrative Services, Inc. (“Applicant”) will implement very strict policies and procedures to minimize abusive registrations and other activities that have a negative impact on Internet users.
One of Applicant’s primary abuse prevention and mitigation strategies is to ensure that only Applicant registers and Applicant and⁄or its Affiliates (as defined in Applicant’s registration policy) use domain names in the TLD under strict guidelines and controls as set by Applicant. In order to ensure that Applicant does not register abusive domain names, Applicant has appointed a single group of employees as authorized to register, acquire, and⁄or monitor domain names in the TLD.
As stated elsewhere, Applicant will not allow the registration of any domain names, except for those required by ICANN and for internal business or testing purposes, for likely one (1) to five (5) years while it conducts marketing and technical studies on how to best operate the TLD. For example, Applicant will initially register and use only two (2) domain names, namely, NIC.WHOIS.INTUIT and a single “home page” domain to provide access to the TLD’s WHOIS database.
Applicant will implement in its internal policies, and its Registrar, Registry and Registration agreements will ensure that all registered domain names in the TLD will be subject to a Domain Name Anti-Abuse Policy (“Abuse Policy”).
The Abuse Policy will provide Applicant with broad power to suspend, cancel, or transfer domain names that violate the Abuse Policy. Applicant will publish the Abuse Policy on its home website and clearly provide Applicant’s Abuse Point of Contact (“Abuse Contact”) and its contact information. This information shall consist of, at a minimum, a valid e-mail address dedicated solely to the handling of abuse complaints, and a telephone number and mailing address for the Abuse Contact. Applicant will ensure that this information will be kept accurate and up to date and will be provided to ICANN if and when changes are made. In addition, with respect to inquiries from ICANN-Accredited registrars, Applicant’s registry services provider, Neustar, shall have an additional point of contact to handle requests by registrars related to abusive domain name practices.
Inquiries addressed to the Abuse Contact will be automatically copied and forwarded to the Registry Services Liaison(s), who will review and, if applicable, remedy any Complaint regarding an alleged violation of the Abuse Policy as described in more detail below.
The Abuse Policy will state, at a minimum, that Applicant 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 Applicant, as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement or any agreement Applicant has with any party; (5) to correct mistakes made by the Applicant, registry services provider, or any registrar in connection with a domain name registration; (6) during resolution of any dispute regarding the domain; and (7) if a registrant’s pre-authorization or payment fails.
The Abuse Policy will define the abusive use of domain names to include, but not be limited to, the following activities:
• Illegal or fraudulent actions: use of the Applicant’s or Registrarʹs services to violate the laws or regulations of any country, state, or other applicable jurisdiction, or in a manner that adversely affects the legal rights of any other person;
• Spam: use of electronic messaging systems from email addresses from domains in the TLD to send unsolicited bulk messages in violation of applicable laws. The term applies to e-mail spam and similar abuses such as instant messaging spam, mobile messaging spam, and the spamming of Web sites and Internet forums;
• Phishing: use of counterfeit Web pages within the TLD that are designed to trick recipients into divulging sensitive data such as usernames, passwords, or financial data;
• Pharming: redirecting of unknowing users to fraudulent Web sites or services, typically through DNS hijacking or poisoning;
• Willful distribution of malware: dissemination of software designed to infiltrate or damage a third-party computer system without the ownerʹs consent. Examples include, without limitation, computer viruses, worms, keyloggers, and trojan horses.
• Fast flux hosting: use of fast-flux techniques to disguise the location of Web sites or other Internet services, or to avoid detection and mitigation efforts, or to host illegal activities. Fast-flux techniques use DNS to frequently change the location on the Internet to which the domain name of an Internet host or name server resolves. Fast flux hosting may be used only with prior permission of PIR;
• Botnet command and control: services run on a domain name that are used to control a collection of compromised computers or ʺzombies,ʺ or to direct denial-of-service attacks (DDoS attacks);
• Illegal Access to Other Computers or Networks: illegally accessing computers, accounts, or networks belonging to another party, or attempting to penetrate security measures of another individualʹs system (often known as ʺhackingʺ). Also, any activity that might be used as a precursor to an attempted system penetration (e.g., port scan, stealth scan, or other information gathering activity);
• Distribution of Pornography;
• Online Sale or Distribution of Illegal Pharmaceuticals;
• Non-intended Use: use of the domain name other than that which was stated during the registration, without a change of intended use accepted by Applicant;
• Cybersquatting: registration of a domain name confusingly similar to a third party’s name or trademark without any legitimate interest in the name and in bad faith;
• Domain Kiting⁄Tasting: registration of domain names to test their commercial viability before returning them during a Grace Period;
• Non-intended Use: use of the domain name other than that which was stated during the registration, without a change of intended use accepted by Applicant;
• Reselling Domain Names: since Applicant will be the only registrant for the foreseeable future, resale of a domain name will not be accepted by Applicant or any registrar.
Domain Anti-Abuse Procedure
Applicant will provide a domain name anti-abuse procedure (“Abuse Procedure”) modeled after the U.S. Digital Millennium Copyright Act’s notice-and-takedown procedure.
At all times, Applicant will publish on its home website the Abuse Policy and Abuse Procedure and the contact information for the Abuse Contact. Inquiries addressed to the Abuse Contact will be addressed to and received by Applicant’s Registry Services Liaison(s) who will review and, if applicable, remedy any Complaint regarding an alleged violation of the Abuse Policy.
Applicant’s Registry Services Liaison(s) will first review the Complaint and make an initial evaluation to see if the Complaint reasonably falls within an abusive use as defined by the Abuse Policy. If not, the Abuse Contact will write a timely correspondence to Complainant stating that the subject of the complaint clearly does not fall within one of the delineated abusive uses as defined by the Abuse Policy and that Applicant considers the matter closed (understanding that a revised Complaint, with material information that shows it to fall within the scope of the policy, may be resubmitted).
If the initial evaluation does not resolve the matter, the Registry Services Liaison(s) will timely give the Complaint a full review. If an abusive use is determined, the Abuse Contact will alert the registry services provider to immediately suspend the resolution of the domain name. The Registry Services Liaison(s) will then immediately notify the registrant of the suspension of the domain name, the nature of the complaint, and provide the registrant with the option to respond within a timely fashion or the domain name will be canceled.
If the registrant responds within a timely period, its response will be further reviewed by the Registry Services Liaison(s), along with Applicant’s or its parent’s legal counsel, if necessary or advisable. If the Registry Services Liaison(s) is satisfied by the registrant’s response that the use is not abusive, the Registry Services Liaison(s) will submit a timely request to the registry services provider to unsuspend the domain name. The Abuse Contact will then timely notify the Complainant that its complaint was ultimately denied and provide the reasons for the denial. If the registrant does not respond within a timely fashion, the Abuse Contact will notify the registry services provider to cancel the abusive domain name.
This Abuse Procedure will not prejudice either party’s election to pursue another dispute mechanism, such as URS or UDRP.
With the assistance of its back-end registry services provider, Applicant will meet its obligations under Section 2.8 of the Registry Agreement 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. Accordingly, Applicant will timely respond to legitimate law enforcement inquiries. Any such response shall include, at a minimum, a timely acknowledgement of receipt of the request, questions or comments concerning the request, and an outline of the next steps to be taken by Applicant for a timely resolution of the request.
In the event such request involves any of the activities which can be validated by Applicant’s Registry Services Liaison(s) and involves the type of activity set forth in the Abuse Policy, Abuse Contact will timely notify the registry services provider to either suspend or cancel the domain name. If the Registry Services Liaison(s) determines that it is not an abusive activity, Abuse Contact will timely provide the relevant law enforcement, governmental and⁄or quasi-governmental agency that information, along with a compelling and clear explanation and argument to keep the name in the zone.
Orphan Glue Removal
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 supports correct and ordinary operation of the DNS, Applicant 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 Applicant has written evidence of actual abuse of orphaned glue, Applicant will take prompt action to remove those records from the zone to mitigate such malicious conduct.
Applicant’s registry service operator will 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.
In addition, if either Applicant or its registry services operator becomes aware of actual abuse from orphaned glue on its own, such glue records will be timely removed from the zone.
Applicant will provide WHOIS accessibility in a reliable, consistent, and predictable fashion in order to promote Whois accuracy. The Registry will adhere to port 43 WHOIS Service Level Agreements (SLAs), which require that port 43 WHOIS service be highly accessible and fast.
Applicant will offer thick WHOIS services, in which all authoritative WHOIS data—including contact data—is maintained at the registry. Through Applicant’s registrar and registry services operators, Applicant will maintain timely, unrestricted, and public access to accurate and complete WHOIS information, including all data objects as specified in Specification 4. Moreover, prior to the release of any domain names, Applicant’s registrar will provide Applicant with an authorization code to verify eligible registrants, and Applicant will provide registrar with proper registrant contact information. Upon registration, registrar will verify the authorization code and contact information before the prospective registrant is allowed to proceed.
In order to further promote WHOIS accuracy, Applicant will offer a mechanism whereby third parties can submit complaints directly to the Applicant’s Registry Services Liaison(s) (as opposed to ICANN or the sponsoring registrar, MarkMonitor) about inaccurate or incomplete WHOIS data. Such information shall be forwarded to the registrar, who shall be required to address those complaints with registrants. Within a reasonable time period after forwarding the complaint to the registrar, Applicant’s Registry Service Liaison(s) will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the registrar has failed to take any action, or it is clear that the registrant was either unwilling or unable to correct the inaccuracies, Applicant reserves the right to suspend the applicable domain name(s) until such time as the registrant is able to cure the deficiencies.
In addition, Applicant’s Registry Services Liaison(s) will, at least twice per year, perform a manual review of a random sampling of domain names within the applied-for TLD to test the accuracy of the WHOIS information. Through this review, the Registry Services Liaison(s) will examine the WHOIS data for evidence of inaccurate or incomplete WHOIS information. In the event that such errors or missing information exists, it shall be forwarded to the registrar, who shall be required to address such deficiencies with registrants. Within a reasonable time period, the Registry Services Liaison(s) will examine the current WHOIS data for names that were alleged to be inaccurate or incomplete to determine if the information was corrected, the domain name was deleted, or there was some other appropriate disposition. If the registrar has failed to take any action, or it is clear that the registrant was either unwilling or unable to correct the inaccuracies, Applicant reserves the right to suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.
Abuse Prevention and Mitigation – Domain Name Access
All domain name registrants will have adequate controls to ensure proper access to domain functions.
In addition to the above, all domain name registrants in the applied-for TLD will be required to name at least two (2) unique points of contact that are authorized to request and⁄or approve update, transfer, and deletion requests. The points of contact will establish strong passwords with the registrar that must be authenticated before a point of contact will be allowed to process updates, transfer, and deletion requests. Once a process update, transfer, or deletion request is entered, the points of contact will automatically be notified when a domain has been updated, transferred, or deleted through an automated system run by Applicant’s registrar.
Use of domain names that infringe upon the legal rights of others in the proposed TLD (“the TLD”) will not be tolerated and preventing abusive registrations is a core objective of Intuit Administrative Services, Inc. (“Applicant”). The nature of such uses creates security and stability issues for the registry, registrars, and registrants, as well as for users of the Internet in general. Primarily, Applicant will prevent abusive registrations by allowing only Applicant to register and Applicant and⁄or its Affiliates (as defined in Applicant’s Registration Policy) to use domain names in the registry under strict internal registration, anti-abuse and rights protection guidelines as defined in its Abuse Policy.
In order to identify and address the abusive use of registered names on an ongoing basis, Applicant promises to additionally incorporate and abide by the following Rights Protection Mechanisms and all other rights protection mechanisms as specified in Specification 7 of the Registry Agreement and as adopted by the ICANN Board of Directors as ICANN Consensus Policies.
For a detailed description of the Anti-Abuse Policy Applicant intends to implement in its TLD, please see Applicant’s response to Question 28.
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, all of which Applicant will support. Although many of the details of how the Trademark Clearinghouse will interact with each registry operator and registrars are still being developed by ICANN, Applicant is actively monitoring the developments of the Implementation Assistance Group (“IAG”) designed to assist ICANN staff in refining and finalizing the rules and procedures associated with the policies and technical requirements for the Trademark Clearinghouse. In addition, Applicant’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 Claims 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.
Applicant’s registry service provider, Neustar, has already implemented Sunrise and⁄or Trademark Claims programs for numerous TLDs including .biz, .us, .travel, .tel and .co and will implement both of these services on Applicant’s behalf.
All domain names registered during the Sunrise Period will be subject to Applicant’s domain name registration policy, namely, that all registrants be Applicant. Notwithstanding this limitation to one (1) registrant, Applicant will offer a Sunrise Period of sixty (60) days for owners of trademarks listed in the Trademark Clearinghouse who also meet applicant’s domain name registration requirements to register domain names that consist of an identical match of their listed trademarks. Applicant’s Registry Services Liaison(s) will receive and authenticate all Sunrise Registrations.
Applicant’s registrar will ensure that all Sunrise Registrants meet sunrise eligibility requirements (SERs), which will be verified by Clearinghouse data. The proposed SERs include: (i) ownership of a mark that is (a) nationally or regionally registered and for which proof of use, such as a declaration and a single specimen of current use – was submitted to, and validated by, the Trademark Clearinghouse; or (b) that have been court-validated; or (c) that are specifically protected by a statute or treaty currently in effect and that was in effect on or before 26 June 2008, (ii) optional registry-elected requirements re: international class of goods or services covered by registration; (iii) representation that all provided information is true and correct; and (iv) provision of data sufficient to document rights in the trademark.
Upon submission of all of the required information and documentation, registrar will forward the information to Applicant’s Registry Services Liaison(s) for authentication. The Registry Services Liaison(s) will review the information and documentation and verify the trademark information and registration eligibility, and notify the potential registrant of any deficiencies. If a registrant does not cure any deficiencies and⁄or respond by the means listed within a timely matter, Applicant’s Registry Services Liaison(s) will notify its registrar and the domain name will be released for registration.
Applicant will incorporate a Sunrise Dispute Resolution Policy (SDRP). The SRDP will allow challenges to Sunrise Registrations by third parties for a ten-day period after acceptance of the registration based on the following four grounds: (i) at time the challenged domain name was registered, the registrant did not hold a trademark registration of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; (ii) the domain name is not identical to the mark on which the registrant based its Sunrise registration; (iii) the trademark registration on which the registrant based its Sunrise registration is not of national or regional effect or the trademark had not been court-validated or protected by statute or treaty; or (iv) the trademark registration on which the domain name registrant based its Sunrise registration did not issue on or before the effective date of the Registry Agreement and was not applied for on or before ICANN announced the applications received.
After receiving a Sunrise Complaint, the Registry Services Liaison(s) will review the Complaint to see if the Complaint reasonably asserts a legitimate challenge as defined by the SDRP. If not, the Registry Services Liaison(s) will timely send an email to the Complainant that the subject of the complaint clearly does not fall within one of the delineated grounds as defined by the SDRP and that Applicant considers the matter closed.
If the domain name is not found to have adequately met the SERs, the Registry Services Liaison(s) will alert the registrar and registry services provider to immediately suspend the resolution of the domain name. Thereafter, the Registry Services Liaison(s) will immediately notify the Sunrise Registrant of the suspension of the domain name, the nature of the complaint, and provide the registrant with the option to timely cure the SER deficiencies or the domain name will be canceled.
If the registrant timely responds, its response will be further reviewed by Registry Services Liaison(s) to determine if the SERs are met. If the Registry Services Liaison(s) is satisfied by the registrant’s response, the Registry Services Liaison(s) will timely submit a request to the registrar and the registry services provider to unsuspend the domain name. If registrant does not timely respond, the Registry Services Liaison(s) will then timely notify the Complainant that its complaint was ultimately denied and provide the reasons for the denial.
Trademark Claims Service
Applicant will offer a Trademark Claims Service during the first one hundred and twenty (120) days of general registration. The Trademark Claims Service will be monitored by the Registry Services Liaison(s). Applicant’s registrar will be required to review all domain names requested to be registered during the Trademark Claims period to determine if they are an identical match of a trademark that has been filed with the Trademark Clearinghouse and they meet Applicant’s domain name registration requirements for the TLD. A domain name will be considered an identical match when the domain name consists of the complete and identical textual elements of the mark, and includes domain names where (a) spaces contained within a mark that are either replaced by hyphens (and vice versa) or omitted; (b) certain special characters contained within a trademark are spelled out with appropriate words describing it (e.g., @ and &); and (c) punctuation or special characters contained within a mark that are unable to be used in a second-level domain name are either (i) omitted or (ii) replaced by spaces, hyphens or underscores. Domain names that are plural forms of a mark or that merely contain a mark will not qualify as an identical match.
If the registrar determines that a prospective domain name registration is identical to a mark registered in the Trademark Clearinghouse, the registrar will be required to ensure that a “Trademark Claims Notice” (“Notice”) in English is sent to the prospective registrant of the domain name, and will blind copy the Registry Services Liaison(s) on all such correspondence. The Notice will provide the prospective registrant information regarding the trademark referenced in the Trademark Claims Notice to enhance understanding of the Trademark rights being claimed by the trademark holder. The Notice will be provided in real time without cost to the prospective registrant.
After sending the Notice, the registrar will be required to mandate that the prospective registrant specifically warrant within five (5) days that: (i) the prospective registrant has received notification that the mark(s) is included in the Clearinghouse; (ii) the prospective registrant has received and understood the notice; and (iii) to the best of the prospective registrant’s knowledge the registration and use of the requested domain name will not infringe on the rights that are the subject of the notice. If the warranty satisfies these requirements, the registrar will be required to effectuate the registration and notify the Registry Services Liaison(s).
After the effectuation of a registration that is identical to a mark listed in the Trademark Clearinghouse, the registrar will be required to then ensure that a clear notice to the trademark owner of the trademark consisting of the domain name that has been registered and will blind copy the Registry Services Liaison(s) confirming that it has done so. The trademark owner then has the option of filing a Complaint under the Uniform Domain Name Dispute Resolution Policy (UDRP) and the Uniform Rapid Suspension System (URS) against the domain name, as the Applicant will require in its domain name registration agreements that the registry, registrar, and registrant all submit to the Uniform Domain Name Dispute Resolution Policy (UDRP) and the Uniform Rapid Suspension (URS) system. Applicant will require its registrar and registry service operators to abide by decisions rendered under the UDRP and URS in a timely and ongoing basis.
Uniform Rapid Suspension System (URS)
Applicant will specify in its Registry-Registrar and Registration Agreements used in connection with the TLD that all parties will timely abide by all decisions made by panels in accordance with the Uniform Rapid Suspension System (URS). On Applicant’s website, Applicant will designate a Rights Protection Contact (“Rights Contact”) that will receive all URS Complaints verified by the URS Provider and provide its contact information. This information shall consist of, at a minimum, a valid e-mail address dedicated solely to the handling of rights protection complaints, and a telephone number and mailing address for the Rights Contact. Applicant will ensure that this information will be kept accurate and up to date and will be provided to ICANN if and when changes are made.
Within 24 hours of receipt of the Notice of Complaint from the URS Provider, the Rights Contact shall notify its registry operator to “lock” the domain, meaning the registry shall restrict all changes to the registration data, including transfer and deletion of the domain names, but the name will continue to resolve. The Rights Contact will notify the URS Provider immediately upon locking the domain name (”Notice of Lock”).
Immediately upon receipt of a Determination in the Complainant’s favor, Rights Contact will notify the registry operator to suspend the domain name, which shall remain suspended for the balance of the registration period and will not resolve to the original web site. The nameservers shall be redirected to an informational web page provided by the URS Provider about the URS. The Whois for the domain name shall continue to display all of the information of the original Registrant except for the redirection of the nameservers. In addition, the Whois shall reflect that the domain name will not be able to be transferred, deleted or modified for the life of the registration. Finally, Applicant will be sure to abide by any timely requests by Complainant to extend the registration period for one additional year at commercial rates.
Immediately upon receipt of a Determination in registrant’s favor, Rights Contact will notify the registry operator to unlock the domain name.
Uniform Domain Name Dispute Resolution Policy (UDRP)
In parallel with the above, Applicant will specify in its Registry-Registrar and Registration Agreements used in connection with the TLD that all parties will timely abide by all decisions made by panels in accordance with the Uniform Domain Name Dispute Resolution Policy (UDRP). Applicant’s Rights Contact will receive all UDRP Complaints and decisions, temporarily lock any domain names as required, and will notify its registrar to timely cancel or transfer all registrations determined to by a UDRP panel to be infringing.
Trademark Post-Delegation Dispute Resolution Procedure (Trademark PDDRP)
Applicant will participate in all post-delegation procedures, including the Trademark Post-Delegation Dispute Resolution Procedure (Trademark PDDRP), and will timely abide by any Determinations of any PDDRP Provider after exhaustion of all appeals and⁄or times to appeal or other determination challenges.
Registry Restrictions Dispute Resolution Procedure (RRDRP)
Because the application is not community-based, Applicant is not required to participate in the RRDRP and will not be bound by any Determinations of a RRDRP Provider.
Applicant intends that only Applicant will be permitted to register domain names in the TLD for its own exclusive use. Hence, Applicant is exempt from the Registry Operator Code of Conduct (“ROCC”) as detailed in Specification 9 of the Registry Agreement with ICANN. Thus, as Applicant is not required to grant access to the TLD to all registrars, and in order to reduce abusive registrations and other activities that affect the legal rights of others, Applicant will only contract with one ICANN-accredited registrar that has proven capable of providing adequate defenses against abusive registrations and superior response capabilities. The registrar, according to the Registry-Registrar agreement, will not be able to register any domain names, thus eliminating the possibility of front-running. The Registrar will also agree not to submit fake renewal notices. Any evidence of abusive behavior on the part of the Registrar will be promptly reported to ICANN Compliance.
Pre-Authorization and Authentication
Prior to the release of any domain names, Applicant will designate that only designated employees will be authorized to register domain names within the TLD under strict domain name registration guidelines. Also, Applicant’s registrar will verify the authenticity of the registrant for each domain name. Additionally, prior to registration, registrar will validate the prospective registrant’s contact information and identity before the prospective registrant is allowed to proceed.
A variety of automated and manual procedures may be utilized for verification by the registrar as specified below:
• Applicant’s registrar’s automated authentication process will authenticate that the prospective registrant authenticity;
• Applicant’s registrar will authenticate that the registrant’s email is Applicant based and contained on a list of pre-approved email extensions from authorized related companies;
• If authenticated, the registrant will be allowed to submit and complete registrations;
• If the registrant cannot be verified by the registrar, the registrar will contact the registry to determine eligibility;
• Registrant must represent and warrant that neither the registration of the desired domain name, nor the manner in which the registration will be used, infringes the legal rights of third parties.
In addition, Applicant’s Registry Services Liaison(s) will at least twice per year perform a manual review of a random sampling of domain names within the applied-for TLD to test the accuracy and authenticity of the WHOIS information. Through this review, Registry Services Liaison(s) will examine the WHOIS data for evidence of inaccurate or incomplete WHOIS information. In the event that such errors or missing information exists, it shall be forwarded to the registrar, who shall be required to address such deficiencies with their registrants. Within a reasonable time period, Registry Services Liaison(s) will examine the current WHOIS data for names that were alleged to be inaccurate or incomplete to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the registrar has failed to take any action, or it is clear that the registrant was either unwilling or unable to correct the inaccuracies, Applicant reserves the right to suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.
Applicant 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.
Applicant will provide a Rights Protection Takedown Procedure (“Takedown Procedure”) modeled after the U.S. Digital Millennium Copyright Act’s notice-and-takedown procedure.
At all times, Applicant will publish on its home website contact information for receiving rights protection complaints (Complaints) from rightsholders. At all times, Applicant will publish on its website the Takedown Procedure and the contact information for the Rights Contact.
Inquiries addressed to the Rights Contact will be forwarded to Applicant’s Registry Services Liaison(s) who will remedy or deny any Complaint regarding an alleged violation of the rights of the Complainant. During the review of any Complaint, Registry Services Liaison(s) will first give the Complaint an initial evaluation to see if the Complaint reasonably alleges the infringement of any legal right. If not, the Rights Contact will write a timely correspondence to Complainant stating that the subject of the complaint clearly does not violate its rights or that there is insufficient information in the Complaint to determine the existence or location of the alleged infringing material and⁄or domain.
If the initial evaluation does not resolve the matter, the Registry Services Liaison(s) will timely give the Complaint a full review, in compliance with applicable and jurisdictional law, as well as Applicant’s terms and policies. If a rights infringement is determined (or a properly alleged infringement is identified), the Rights Contact will alert the registry services provider to take appropriate action based on applicable and jurisdictional law and regulations, which may include, if appropriate and⁄or required by law or policy, immediately suspending the resolution of the domain name. If the domain name is suspended, the Registry Services Liaison(s) will immediately notify the registrant of the domain name suspension, the nature of the complaint, and provide the registrant with the option to respond, take down the infringing content within a timely fashion or, if appropriate and⁄or required by law or policy, cancel the domain name.
If the registrant responds within a timely period, its response will be further reviewed by Registry Services Liaison(s), who may also seek the advice of Applicant’s legal counsel. If the Registry Services Liaison(s) is⁄are satisfied by the registrant’s response that no rights have been infringed, Registry Services Liaison(s) will submit a timely request to the registry services provider to unsuspend or avoid suspension of the domain name. The Rights Contact will then timely notify the Complainant that its complaint was ultimately denied and provide the reasons for the denial. If the registrant does not respond within a timely fashion, the Rights Contact will notify the registry services provider to cancel the alleged-abusive domain name.
This Takedown Procedure will not prejudice either party’s election to pursue another dispute mechanism, such as URS or UDRP, or, for example, a civil suit in an appropriate jurisdiction.
With the assistance of its back-end registry services provider, Applicant will meet its obligations under Section 2.8 of the Registry Agreement 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. Applicant will accordingly timely respond to legitimate law enforcement inquiries. Any 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 Applicant for a timely resolution of the request.
In the event such request involves any infringing activity which can be validated by Applicant’s Registry Services Liaison(s), the Rights Contact will timely notify the registry services provider to either suspend the domain name until the infringing activity is cured or cancel the domain name, thus allowing for any due process required by applicable law. If the Registry Services Liaison(s) determines that the alleged activity does not infringe on any third party’s rights, the Rights Contact will timely provide the relevant law enforcement, governmental and⁄or quasi-governmental agency with information regarding such determination (including a compelling argument or information why the domain name should be kept in the zone) and will work cooperatively with such agency to determine the appropriate and lawful resolution.
30.(a).1 Security Policies
Intuit Administrative Services, Inc. and its back-end operator, Neustar, Inc, recognize the vital need to secure the systems and the integrity of the data in commercial solutions. The .intuit 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 .intuit 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 .intuit
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 .intuit registry.
30.(a).2 Summary of Security Policies
Neustar 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).3 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).4 Augmented Security Levels and Capabilities
There are no increased security levels specific for .intuit. 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).5 Commitments and Security Levels
The .intuit 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
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