GE GTLD Holdings LLC
Corporation Trust Center
1209 Orange Street
Wilmington DE 19801
+1 203 373 3328
+1 203 373 2181
Mr. Brad Newberg
+1 703 641 4272
+1 703 641 4340
Mr. Sean Patrick Merrill
+1 203 373 3328
+1 203 373 2181
Limited Liability Company
Delaware Limited Liability Company Act (6 Del. C. 18-101 et seq.) http:⁄⁄delcode.delaware.gov⁄title6⁄c018⁄index.shtml
|Sean Patrick Merrill||Sole Officer|
|General Electric Company||Not Applicable|
Applicant anticipates the introduction of this TLD without operational or rendering problems. Based on a decade of experience launching and operating new TLDs, Afilias, the back-end provider of registry services for this TLD, is confident the launch and operation of this TLD presents no known challenges. The rationale for this opinion includes: - The string is not complex and is represented in standard ASCII characters and follows relevant technical, operational and policy standards; - The string length is within lengths currently supported in the root and by ubiquitous Internet programs such as web browsers and mail applications; - There are no new standards required for the introduction of this TLD; - No onerous requirements are being made on registrars, registrants or Internet users, and; - The existing secure, stable and reliable Afilias SRS, DNS, WHOIS and supporting systems and staff are amply provisioned and prepared to meet the needs of this TLD
Summary of Answer to Question 18
GE GTLD Holdings LLC (“GEGTLD”), a wholly-owned subsidiary of General Electric Company (“General Electric” or “GE”), is applying for .GECOMPANY (and .通用电气公司 in a separate application) both as a defensive measure to protect and strengthen the GE trademarks and brands, and also to coalesce GE’s current domain names and allow GE’s customers and partners to have a recognized top level domain, housing the most up-to-date and complete information about General Electric as a company as well as GE’s goods and services. .GECOMPANY (with .通用电气公司) will examine the market once delegation and launch of .GECOMPANY occurs, and examine whether .GECOMPANY can act as a cornerstone of GEGTLD’s and General Electric’s future online strategic initiative, by providing a trusted and intuitive namespace for consumers of General Electric’s goods and services and a source of information for others, including employees, jobseekers and investors. The .GECOMPANY gTLD will be a specialized gTLD with no public registration market and no revenue streams.
General Electric is one of the top companies in the entire world, with hundreds of businesses and thousands of brands, including the core brand of General Electric itself. The value of the GE brands is incalculable, but in sum total would certainly be worth billions of dollars. The preservation and enhancement of this brand is of the utmost importance to General Electric in all aspects of its operations, including and especially on the Internet. In the new Internet environment, it is important that the users and consumers of GE’s goods and services and GE’s many partners, suppliers, and retailers know exactly where to go for all information regarding General Electric and its many related entities.
The creation of the .GECOMPANY gTLD will better enable General Electric to protect its core brands and the corporate General Electric brand. It will also benefit the general public by assuring Internet users that they will be getting the most up-to-date and accurate information about GE’s products and services, the best customer service experience possible, and a place free from worries of pirates, cybersquatters, typosquatters, and similar wrongdoers. It will also allow the creation of short, memorable domain name addresses to make it easier for the public to find exactly what they are looking for concerning General Electric.
Finally, General Electric will use .GECOMPANY so as to focus its online marketing to the new .GECOMPANY and .通用电气公司 gTLDs so that there will be a consistent message to the public regarding General Electric products and services as well as information about the company itself. GE will examine the marketplace to see if it can use the efficiencies created by this new system and put saved resources into other initiatives to benefit both General Electric and the public at large.
GEGTLD will be allowing registration at the second level on a closed-platform, limited domain name, basis and only for GE divisions and affiliates and possibly for GE partners and suppliers as time goes on.
The online presence of General Electric serves several functions. It informs the public about GE. It provides information about GE’s products and services, and about its partners and affiliates. It provides relevant information to investors and others interested in the financial profile of the company and to job seekers who are interested in career information. It also provides access to certain sites that are only available to the GE community, such as human resources and other corporate policies.
GEGTLD is seeking to apply for .GECOMPANY as a defensive measure to insure the safety of GE’s trademarks and also as a way to coalesce GE’s current domain names and increase the strength of the GE brands. This new gTLD will provide a trusted and intuitive namespace for consumers of General Electric’s goods and services, and will have internal and informational uses such as for human resources and corporate⁄investor information. .GECOMPANY will be a specialized gTLD with no public registration market and no revenue streams. It will be 100% owned by GEGTLD, which is a wholly-owned subsidiary of General Electric. The preservation and protection of the GE brands is of paramount importance to General Electric in all aspects of its operations, including and especially on the Internet. Operating the GE brand as a gTLD will be an important part of GE’s digital strategy in the future.
The entire set of General Electric’s brands, especially the corporate General Electric⁄GE name, is a core asset of GE and the promotion and development of that asset is critical to General Electric’s long-term business and strategic interests. The business strategy for the .GECOMPANY gTLD is centered on the unification of intellectual property rights, promotion, marketing and customer relations across General Electric and all of its brands.
18(a) What is the Mission and Purpose of .GECOMPANY?
GE is a diversified infrastructure, finance and media company taking on the worldʹs toughest challenges. From aircraft engines and power generation to financial services, medical imaging, and television programming, GE operates in more than 100 countries and employs about 300,000 people worldwide.
GE has a strong set of global businesses in infrastructure, finance and media aligned to meet todayʹs needs, including the demand for global infrastructure; growing and changing demographics that need access to healthcare, finance, and information and entertainment; and, environmental technologies.
GE traces its beginnings to Thomas A. Edison, who established Edison Electric Light Company in 1878. In 1892, a merger of Edison General Electric Company and Thomson-Houston Electric Company created General Electric Company. GE is the only company listed in the Dow Jones Industrial Index today that was also included in the original index in 1896.
The mission and purpose of the .GECOMPANY gTLD is to act defensively to protect the GE brands and also to strengthen those brands as a trusted and intuitive namespace provided by General Electric, for General Electric customers, partners, affiliates, employees and others seeking information about General Electric, its companies, and its goods and services.
General Electric and GEGTLD will use the .GECOMPANY gTLD in an effort to help GE provide the best possible customer service and the most accurate and up-to-date information about GE’s goods and services, as well as the many entities affiliated with General Electric. Domain names may be specialized and formatted in an innovative fashion to enhance the General Electric name and all of GE’s brands. .GECOMPANY will help increase consumer association with the GE brands, and hopefully, give GE the opportunity to retain more control over its reputation and brands and market those brands accordingly. In theory, the .GECOMPANY gTLD will function as one giant house in which to explore all of GE’s brands, products and services, and consumers will be able to trust that they are getting the best and most recent information from the official General Electric entity associated with each second-level domain name within the .GECOMPANY closed gTLD.
How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?
While GEGTLD is applying for .GECOMPANY to help GE protect the GE brands as a defensive measure, General Electric will use the .GECOMPANY gTLD with the intent of establishing and offering the following benefits to Internet users and consumers:
• Establish a trusted source of information for the millions of consumers who purchase GE’s goods and services or the goods and services of GE’s partners and affiliates as General Electric will be able to provide consistent and up-to-date information in one place.
• Establish a trusted source of information regarding General Electric for investors and third parties seeking information, and for the general Internet user population;
• Provide General Electric and its partners with short and memorable Internet addresses;
• Facilitate navigation to products, services, advertising campaigns, public interest content, public awareness initiatives, etc;
• Reduce consumer confusion and associated transaction costs associated with locating websites, information, goods and services;
• Lower consumer incidences of encountering phishing and malware often associated with mistypes of domain names in the .COM space that are owned by cybersquatters—typosquatting will be less relevant since every second-level domain name within the .GECOMPANY space will either resolve to an official GE or GE-partner web page or none at all; and,
• Develop a potential platform for the secure access to, purchase of, and distribution of General Electric products and services and be a trusted place free from any chance of finding counterfeit or infringing goods and services.
General Electric owns and operates thousands of different brand names. This requires GE to register thousands of unaffiliated and unrelated domain names in the .com space and other gTLDs, making it harder for GE to control its brands and associate them cohesively, prevent infringement, and authenticate itself to customers. In addition to the main defensive reasons for applying for .GECOMPANY, General Electric will examine the marketplace to see whether the .GECOMPANY gTLD can provide a single-source in the online world for all things related to GE for all of GE’s customers around the world.
What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?
The primary mission and purpose of the .GECOMPANY gTLD is to protect and defend, as well as strengthen, General Electric’s trademarks and brands. A secondary goal of this gTLD is to provide a trusted and intuitive online marketplace to deliver information about General Electric, its brands, products, services, partners, and affiliates, as well as about the corporation itself. As General Electric continues to expand, the company will continue to pursue and develop opportunities to market online to consumers, in the U.S. and internationally, and on various platforms, including the Internet and mobile devices. The .GECOMPANY gTLD will provide an avenue to information about General Electric brands, products, services, partners, and affiliates that will expand GE’s relationship with its consumers and maximize its ability to give individualized offerings and customer service to each consumer. Every second-level domain name will be registered by General Electric and operated by General Electric or a General Electric affiliate or partner. This will enable GE to maximize its service to the consumer and send consistent messages across its online marketing platform. In addition, the consistent message and safe haven that is supplied by .GECOMPANY may increase the reputation of GE and of the quality and authenticity of its goods and services in the marketplace.
Through the .GECOMPANY gTLD, General Electric will be able to provide access to information about General Electric, its brands, products, services, partners, and affiliates, as well as about the corporation itself in a space void of piracy, cybersquatting and other malicious activities. Providing consumers with a trusted experience is paramount to General Electric and a .GECOMPANY gTLD will be used to further that goal. A .GECOMPANY gTLD potentially offers consumers a safe and intuitive means of accessing authorized content from General Electric and its partners and affiliates.
Establishment of a .GECOMPANY gTLD will help prevent cybersquatting, fraud, phishing and other malicious activities within the .GECOMPANY gTLD since all domain names will be operated or controlled by General Electric. Maintaining the highest standards within the .GECOMPANY gTLD will give General Electric the opportunity to take a proactive approach to protecting intellectual property rights and fostering a safer online experience for all Internet users.
What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?
As a branded gTLD, the primary driving factors of a .GECOMPANY gTLD are the defense, protection, and strengthening of the General Electric trademarks and brands. General Electric also wants to provide the best online user experience for the millions of GE customers and potential customers. The success of the gTLD will be measured not by the number of domain names registered—since General Electric will be fully in control of that amount and will actually seek to limit the number of domain names registered so as to make the .GECOMPANY gTLD easy to navigate and to make the domain names within the gTLD easy to remember—but rather by the level of consumer recognition and trust that is placed in the .GECOMPANY gTLD and General Electric’s ability to defend and protect its marks. It is the hope of GEGTLD and GE that the recognition and use of .GECOMPANY and its second-level domain names will allow customers to know that they can find all the information they need at domain names associated with .GECOMPANY. This will also allow GE to create an innovative and consistently branded space where customer service will thrive. GE will also allow its employees and partners to maximize innovation and try new ways of enhancing the GE brands and customer experience within the .GECOMPANY space.
The .GECOMPANY gTLD will provide a single trusted space for the millions of consumers world-wide who purchase the company’s products and services, as well as those who seek information about General Electric, including investors, employees (or prospective employees), and members of the press. Consumers will know that domains and content on .GECOMPANY are owned and controlled by GEGTLD and General Electric and are thus more likely to be protected from infringing, pirated, or harmful content or by entities seeking to illicitly capture private information or engage in fraud.
The initial use of the .GECOMPANY gTLD will involve an examination of the marketplace of similar launching gTLDs so that General Electric can best use the .GECOMPANY space to its advantage and the advantage of the public at large. General Electric will then register a limited number of second-level domain names to test the system internally, figure out the best ways to market the second-level domain names to the public, and start slowly transitioning from General Electric’s domain names in the .COM and other spaces. General Electric will likely begin by allocating domain names for internal corporate use and may redirect new .GECOMPANY domain names to pre-existing content and vice-versa. This phased rollout will likely take place over an extended period, subject to change depending upon a range of external factors.
General Electric wants its consumers to always feel safe and secure and to come away from interactions with General Electric feeling good about the company, its brands, and its goods and services. The consistency of the message that .GECOMPANY will allow GE and GEGTLD to provide may enhance the experience of those who browse the .GECOMPANY space and create a stronger link between GE and its customers and potential customers.
General Electric’s strategy has been set up to maximize the user experience and give Internet users the most accurate information, the safest websites to explore, and the best customer service. It is expected that once various General Electric websites start being transferred to the .GECOMPANY space, customers, potential customers, and those seeking accurate information about General Electric will find an Internet space where they can get the most up-to-date and accurate information and have no worries about cybersquatting, typosquatting, pirated or infringing goods, phishing, inconsistent branding and information, or many of the other negative aspects of the general Internet space currently in existence.
Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.
GEGTLD currently intends for the .GECOMPANY gTLD to be used exclusively by General Electric, its affiliates, suppliers, and partners. Because of this condition, and the protection of General Electric and all its marks and brands is paramount to the company, General Electric intends to address registration and use requirements in its partner⁄affiliate agreements to the extent that any domain names are given to those entities, rather than in a domain name registration agreement. General Electric will make all second-level domain name decisions with an eye towards enhancing GE’s brands, maximizing the customer experience, and providing the safest atmosphere with the most up-to-date information. The initial second-level domain names will all be controlled and maintained by General Electric so that the most consistent space possible can be created. Therefore, General Electric’s registration policies will not affect the public at large, since this will be a closed platform with no opportunity for non-General Electric entities to register second-level domain names.
To the extent second-level domain names are ever given to General Electric partners and affiliates that are not owned by GE, General Electric will require strict adherence to trademark guidelines and GEGTLD will have the flexibility to terminate second level registrants that conduct themselves in a manner that degrades the GE brands. Of course, the second level registration agreements will incorporate all required ICANN consensus policies and other legal⁄policy requirements imposed on new gTLD applicants into the terms and conditions of the domain name registration agreement that each partner will execute. To be clear, however, it is anticipated that all registrations will be owned and operated by General Electric, so that the chances of actions being taken not in support of the goals listed above are almost non-existent.
Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users? If so, please describe any such measures.
As a global retail company, General Electric respects the privacy of its customers and the general public. The company employs a variety of physical, electronic, contractual, and managerial safeguards to protect personal and confidential information in its stores and on its websites. General Electric will take similar precautions to protect registrant and user data associated with the .GECOMPANY gTLD. In terms of registrants, given that every domain name will be registered to General Electric or a partner, General Electric has a vested interest in ensuring that accurate and current domain name information is readily available in connection with each .GECOMPANY domain name.
Describe whether and in what ways outreach and communications will help to achieve your projected benefits.
General Electric spends many millions of dollars each year in marketing the GE brands and a higher percentage of these marketing dollars are in the online space each year. The .GECOMPANY gTLD may therefore play a large role in the company’s future online strategy. General Electric will use large portions of its marketing budget to speed up the process of customer recognition and adoption of .GECOMPANY. General Electric will do whatever is necessary to make sure that the public feels as if the .GECOMPANY gTLD is the place to go for consistent information about GE and all its brands, good, services, partners, and affiliates and that it will be the safest place they can go on the Internet to get such information.
What operating rules will you adopt to eliminate or minimize social costs (e.g., time or financial resource costs, as well as various types of consumer vulnerabilities)?
GEGTLD’s and General Electric’s proposed operating rules to limit registration to General Electric and its partners and affiliates within a very small amount of domain names will provide a trusted online environment for consumers and others looking for information about GE, its brands, and its products and services. By its very nature, this will minimize social costs. The .GECOMPANY gTLD will provide consumers with a single trusted source for General Electric information with a substantially lower risk of fraud, scams, or counterfeit or infringing products or services. No cybersquatters or typosquatters will be allowed in this new space, so there will be fewer social costs in this sort of closed gTLD system, unlike an open system where many brand owners may need to register second level domain names defensively or where consumers have to worry about how carefully they type in a domain name address. The application for .GECOMPANY accomplishes some of these defensive needs globally through its closed-platform brand model.
What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?
GEGTLD believes that the proposed operation of the .GECOMPANY gTLD as set forth in this application will have no known negative consequences or cost implications to consumers. On the contrary, the proposed operation of this registry will likely lead to direct benefits to consumers as explained in other areas of the Answer to this Question 18.
How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first-serve basis?
Because General Electric will control the distribution of all domain names so as to accomplish the goals listed throughout the Answer to this Question 18, there will never be multiple applicants for the same domain name.
Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).
GEGTLD does not anticipate any such cost differences for domain names or any costs at all for the purchase of a second level domain. Because General Electric will control the distribution of all domain names so as to accomplish the goals listed throughout the Answer to this Question 18, there will never be outsiders looking to register bulk domain names and so forth. It is the current intention of GEGTLD to provide domain name registrations to General Electric (and possibly, eventually, to GE’s partners) at no cost; any change to this policy would likely only adopt a transfer price environment where General Electric or its partners or affiliates will handle the minimal cost established.
Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.
As stated above, GEGTLD does not anticipate any price increases for domain names or any costs to the registrants of domain names at all. Because General Electric will control the distribution of all domain names so as to accomplish the goals listed throughout the Answer to this Question 18, there will never be outsiders looking to register bulk domain names and so forth It is the current intention of GEGTLD to provide domain name registrations to General Electric (and possibly, eventually, to GE’s partners) at no cost; any change to this policy would likely only adopt a transfer price environment where General Electric or its partners or affiliates will handle the minimal cost established. It would not be in General Electric’s best interest to charge itself or its partners for domain names and then escalate those prices unreasonably. Therefore, the plan is to keep the price to registrants at zero for the indefinite future.
GE GTLD Holdings LLC (“GEGTLD”), a wholly owned subsidiary of General Electric (ʺGeneral Electricʺ or “GE”), is applying for .GECOMPANY (and .通用电气公司 in a separate application) as a defensive measure to protect the General Electric brands as well as to potentially coalesce its current domain names and increase the strength of the GE brand. Although the primary use of the .GECOMPANY gTLD will be to protect GE’s brands, GEGTLD and General Electric will use the new gTLDs so as to allow GE’s customers and partners to have a recognized top level domain, housing the most up-to-date and complete information about General Electric as a company as well as about GE’s goods and services. .GECOMPANY (with .通用电气公司) may eventually be a cornerstone of GEGTLD’s and General Electric’s future online strategic initiative, by providing a trusted and intuitive namespace for consumers of General Electric’s goods and services and a source of information for others, including employees, jobseekers and investors. The .GECOMPANY gTLD will be a specialized, closed-platform gTLD with no public registration market and no revenue streams.
GEGTLD will reserve use of geographic names at the second level as required by ICANN and applicable law. To the extent not prohibited, GEGTLD will allow use of fair and non-misleading geographic identifiers. GEGTLD will not allow any misleading geographic domain names to be registered and will have policies in place to remove any domain names registered that are later found to be misleading from a geographic or non-geographic perspective.
GEGTLD and General Electric are keenly aware of the sensitivity of national governments in connection with protecting country and territory identifiers in the Domain Name System (DNS). In preparation for answering this question, GEGTLD reviewed the following relevant background material regarding the protection of geographic names in the DNS:
• ICANN Board Resolution 01-92 regarding the methodology developed for the reservation and release of country names in the .INFO top-level domain, http:⁄⁄www.icann.org⁄en⁄minutes⁄minutes-10sep01.htm;
• ICANN’s Proposed Action Plan on .INFO Country Names, see http:⁄⁄www.icann.org⁄en⁄meetings⁄montevideo⁄action-plan-country-names-09oct01.htm;
• Second WIPO Internet Domain Name Process – The Recognition and Rights and the Use of Names in the Internet Domain Name System, Section 6, Geographical Identifiers, see http:⁄⁄www.wipo.int⁄amc⁄en⁄processes⁄process2⁄report⁄html⁄report.html;
• The GAC Principles Regarding New gTLDs, see https:⁄⁄gacweb.icann.org⁄download⁄attachments⁄1540128⁄gTLD_principles_0.pdf?version=1&modificationDate=1312358178000;
• ICANN’s Generic Names Supporting Organization Reserved Names Working Group – Final Report, see http:⁄⁄gnso.icann.org⁄issues⁄new-gtlds⁄final-report-rn-wg-23may07.htm.
GEGTLD will protect names with national or geographic significance by reserving the country and territory names at the second level and at all other levels within the TLD, as per the requirements in the New TLD Registry Agreement (Specification 5, paragraph 5). GEGTLD will employ a series of rules to translate the geographical names required to be reserved by Specification 5, paragraph 5 to a form consistent with the ʺhost namesʺ format used in domain names. These domains will be blocked, at no cost to governments, public authorities, or IGOs, before the TLD is introduced, so that no parties may apply for them. GEGTLD will publish a list of these names before Sunrise, so the public can be aware that these names are reserved.
GEGTLD will define a procedure for governments to request the above reserved domain(s) and ask to take possession of them. This procedure will be based on existing methodology developed for the release of country names in the .INFO TLD.
As defined by Specification 5, paragraph 5, such geographic domains may be released to the extent that the Registry Operator reaches agreement with the applicable government(s). The Registry operator will work with respective GAC representatives of the country’s relevant Ministry of Department to obtain the release of the names to the Registry Operator.
GEGTLD will also reserve the IDN versions of the country names in the relevant script(s) if and before IDNs become available to the public. If GEGTLD finds it advisable and practical, GEGTLD will confer with relevant language authorities so that GEGTLD can reserve the IDN domains properly along with their variants.
Regarding GAC advice regarding second-level domains not specified via Specification 5, paragraph 5: All domains awarded to registrants are subject to the Uniform Domain Name Dispute Resolution Policy (UDRP), and to any properly-situated court proceeding. GEGTLD will ensure appropriate procedures to allow governments, public authorities or IGO’s to challenge abuses of names with national or geographic significance at the second level and there will be provisions to suspend domains names in the event of a dispute. GEGTLD may exercise that right in the case of a dispute over a geographic name. GEGTLD notes that the only planned registrant for any domain names in this closed-platform branded system is General Electric and those domain names will only be used by GE and potentially its affiliates and partners to promote and protect the GE brands.
Initial Reservation of Country and Territory Names
GEGTLD and General Electric are committed to initially reserving the country and territory names contained in the internationally recognized lists described in Article 5 of Specification 5 attached to the New gTLD Applicant Guidebook at the second level and at all other levels within the .GECOMPANY gTLD. Specifically, GEGTLD will reserve:
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, see http:⁄⁄www.iso.org⁄iso⁄support⁄country_codes⁄iso_3166_code_lists⁄iso-3166- 1_decoding_table.htm - EU;
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 six official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names.
Fair & Non-Misleading Use of Geographical Identifiers
General Electric is a leading global manufacture of many types of goods, has thousands of different brands, and markets hundreds, if not thousands of services, all around the world. General Electric web content is available through hundreds of domain names in the .COM TLD, but also through various other TLDs and ccTLDs.
Because General Electric is a world-wide company offering goods and services throughout the globe, GEGTLD and General Electric may eventually look into the use, within the .GECOMPANY gTLD, of geographical identifiers as second level domain names. As ICANN has largely premised this new gTLD round on promoting innovation, GEGTLD and General Electric will look into determining if this type of use of second level domain names within a TLD could provide increased consumer functionality.
There are various different examples of fair and non-misleading use of geographical identifiers used in the existing gTLD domain name space. These uses include AUSTRALIA.COOP, UK.COOP, NZ.COOP, USA.JOBS, MALDIVIAN.AERO, TEXAS.JOBS, BOISE.COOP, BROOKLYN.COOP, HYDERABAD.AERO, and SACRAMENTO.AERO. GEGTLD will look into these models to see how to best use geographic identifiers in the fairest and least misleading ways.
Legal Protection of Geographical Identifiers
The World Intellectual Property Organization (WIPO) authored an authoritative resource on the current state of the law in connection with the protection of geographical identifiers, its 2001 Report of the Second WIPO Internet Domain Name Process: The Recognition of Rights and the Use of Names in the Internet Domain Name System (“WIPO Report”). Chapter six of the WIPO Report was devoted exclusively to the protection of Geographical Identifiers.
In its analysis, WIPO identified the following two elements for the protection of geographical identifiers: (i) a prohibition of false descriptions of the geographical source of goods; and (ii) a more extensive set of rules prohibiting the misuse of one class of geographical source indicators, known as geographical indications. See WIPO Report (Paragraphs 206 and 210). Neither of these elements is present in GEGTLD’s planned or possible use of geographical identifiers.
Notwithstanding WIPO’s observation that the protection of geographical identifiers is “a difficult area on which views are not only divided, but also ardently held” (Paragraph 237), national governments within the ICANN Government Advisory Committee (GAC) and other international fora have continued to advocate for increased safeguards to protect against the misuse of geographical identifiers within the DNS.
GEGTLD and General Electric, acting as a responsible global business, seek to avoid business practices that could potentially mislead consumers. GEGTLD and General Electric will be looking to adapt and promote policies such that geographical identifiers will only be used in a fair use and non-misleading manner, and only if such use can benefit Internet users and consumers as proposed in GEGTLD’s business model provided in the Answer to Question 18.
Protection of Regional and Local Geographic Names for Misleading Use
GEGTLD and General Electric will consider using non-reserved geographic identifiers in a fair and non-misleading manner to help consumers navigate the .GECOMPANY gTLD. GEGTLD is committed to operating the .GECOMPANY gTLD in a manner that minimizes potential consumer confusion, and will actively work with others in the ICANN community regarding any future policy development in this area. To the extent any government entity has an issue with the domain names being registered by General Electric through GEGTLD, GEGTLD will act expeditiously and conservatively to eliminate any issues that the government authority might have.
Potential Future Release of Initially Reserved Names
GEGTLD looks forward to collaborating with other new gTLD registry operators in working with the GAC to explore processes that could permit the release of initially reserved country names (including ISO-3166 two characters). GEGTLD may explore other Registry Service Evaluation Processes (RSEP) that have been filed by existing gTLD registry operators in releasing previously reserved domain names.
GEGTLD does not anticipate any disputes with governments or public authorities arising in connection with the registration and use of geographic names within the .GECOMPANY gTLD based upon its proposed use set forth in Answer 18 above. GEGTLD is committed to working with governments, public authorities, or IGOs to quickly resolve any such potential disputes. GEGTLD’s plan is to err on the side of caution and be extremely conservative, thereby eliminating the vast majority, if not all names, with which any governmental authority has an issue.
Should the need arise for the updating of the policies regarding this class of domain names, GEGTLD will act in an open and transparent manner to develop such a policy and⁄or recommendation.
GEGTLD is also committed to the ongoing review and updating of these lists to prevent misleading use of geographical identifiers. Consistent with this commitment, GEGTLD intends to participate in any ICANN policy discussion regarding the protection of geographic names within the DNS.
Throughout the technical portion (#23 - #44) of this application, answers are provided directly from Afilias, the back-end provider of registry services for this TLD. Applicant chose Afilias as its back-end provider because Afilias has more experience successfully applying to ICANN and launching new TLDs than any other provider. Afilias is the ICANN-contracted registry operator of the .INFO and .MOBI TLDs, and Afilias is the back-end registry services provider for other ICANN TLDs including .ORG, .ASIA, .AERO, and .XXX.
Registry services for this TLD will be performed by Afilias in the same responsible manner used to support 16 top level domains today. Afilias supports more ICANN-contracted TLDs (6) than any other provider currently. Afilias’ primary corporate mission is to deliver secure, stable and reliable registry services. This TLD will utilize an existing, proven team and platform for registry services with:
• A stable and secure, state-of-the-art, EPP-based SRS with ample storage capacity, data security provisions and scalability that is proven with registrars who account for over 95% of all gTLD domain name registration activity (over 375 registrars);
• A reliable, 100% available DNS service (zone file generation, publication and dissemination) tested to withstand severe DDoS attacks and dramatic growth in Internet use;
• A WHOIS service that is flexible and standards compliant, with search capabilities to address both registrar and end-user needs; includes consideration for evolving standards, such as RESTful, or draft-kucherawy-wierds;
• Experience introducing IDNs in the following languages: German (DE), Spanish (ES), Polish (PL), Swedish (SV), Danish (DA), Hungarian (HU), Icelandic (IS), Latvian (LV), Lithuanian (LT), Korean (KO), Simplified and Traditional Chinese (CN), Devanagari (HI-DEVA), Russian (RU), Belarusian (BE), Ukrainian (UK), Bosnian (BS), Serbian (SR), Macedonian (MK) and Bulgarian (BG) across the TLDs it serves;
• A registry platform that is both IPv6 and DNSSEC enabled;
• An experienced, respected team of professionals active in standards development of innovative services such as DNSSEC and IDN support;
• Methods to limit domain abuse, remove outdated and inaccurate data, and ensure the integrity of the SRS, and;
• Customer support and reporting capabilities to meet financial and administrative needs, e.g., 24x7 call center support, integration support, billing, and daily, weekly, and monthly reporting.
Afilias, leveraging a proven registry infrastructure that is fully operational, staffed with professionals, massively provisioned, and immediately ready to launch and maintain this TLD, will support this TLD in accordance with the specific policies and procedures of the registry operator, the Applicant, and its registry operations and compliance support provider, CSC Corporate Domains, Inc. (CSC). Throughout this application, registry operator includes the administration and management services for this TLD by CSC.
The Applicant chose CSC to provide extensive support for the operations and compliance of this new TLD. During the set-up of registry operator services, CSC will assist the Applicant with:
• Configuring client specific inventory, billing, specialized business rules, as well as access & permission rights for the user interface that will interact with the Afilias’ EPP-based, SRS;
• Connecting & performing all OT&E testing with Registry & Trademark Clearinghouse interfaces;
• Scheduling data escrow deposits, and their processing & payment administration;
• Conducting and managing ICANN Pre-Delegation system testing (along with Afilias);
• Project Management for the delegation process; and
• Training authorized staff for policy compliance under the new TLD.
Many ongoing needs of the Applicant, as registry operator, will also be provided by CSC, including:
• Day-to-Day service of TLD requests via dedicated service team;
• 24X7X365 Tier 1 Technical Support;
• Generation, review and submission of monthly ICANN compliance reports;
• Dedicated Account Management & Issue escalation;
• Weekly data escrow deposits and data escrow administration (along with Afilias)
• System monitoring, maintenance and upgrades (along with Afilias)
• Management of TLD systems and vendors
• Internal business reporting
• ICANN policy monitoring and reporting
The below response includes a description of the registry services to be provided for this TLD, additional services provided to support registry operations, and an overview of Afilias’ approach to registry management.
Registry services to be provided
To support this TLD, Applicant and Afilias will offer the following registry services, all in accordance with relevant technical standards and policies:
• Receipt of data from registrars concerning registration for domain names and name servers, and provision to registrars of status information relating to the EPP-based domain services for registration, queries, updates, transfers, renewals, and other domain management functions. Please see our responses to questions #24, #25, and #27 for full details, which we request be incorporated here by reference.
• Operation of the registry DNS servers: The Afilias DNS system, run and managed by Afilias, is a massively provisioned DNS infrastructure that utilizes among the most sophisticated DNS architecture, hardware, software and redundant design created. Afilias’ industry-leading system works in a seamless way to incorporate name servers from any number of other secondary DNS service vendors. Please see our response to question #35 for full details, which we request, be incorporated here by reference.
• Dissemination of TLD zone files: Afilias’ distinctive architecture allows for real-time updates and maximum stability for zone file generation, publication and dissemination. Please see our response to question #34 for full details, which we request, be incorporated here by reference.
• Dissemination of contact or other information concerning domain registrations: A port 43 WHOIS service with basic and expanded search capabilities with requisite measures to prevent abuse. Please see our response to question #26 for full details, which we request, be incorporated here by reference.
• Internationalized Domain Names (IDNs): Ability to support all Unicode characters at every level of the TLD, including alphabetic, ideographic and right-to-left scripts. Please see our response to question #44 for full details, which we request, be incorporated here by reference.
• DNS Security Extensions (DNSSEC): A fully DNSSEC-enabled registry, with a stable and efficient means of signing and managing zones. This includes the ability to safeguard keys and manage keys completely. Please see our response to question #43 for full details, which we request, be incorporated here by reference.
Each service will meet or exceed the contract service level agreement. All registry services for this TLD will be provided in a standards-compliant manner.
Afilias addresses security in every significant aspect – physical, data and network as well as process. Afilias’ approach to security permeates every aspect of the registry services provided. A dedicated security function exists within the company to continually identify existing and potential threats, and to put in place comprehensive mitigation plans for each identified threat. In addition, a rapid security response plan exists to respond comprehensively to unknown or unidentified threats. The specific threats and Afilias mitigation plans are defined in our response to question #30(b); please see that response for complete information. In short, Afilias is committed to ensuring the confidentiality, integrity, and availability of all information.
New registry services
No new registry services are planned for the launch of this TLD.
Additional services to support registry operation
Numerous supporting services and functions facilitate effective management of the TLD. These support services are also supported by Afilias, including:
• Customer support: 24x7 live phone and e-mail support for customers to address any access, update or other issues they may encounter. This includes assisting the customer identification of the problem as well as solving it. Customers include registrars and the registry operator, but not registrants except in unusual circumstances. Customers have access to a web-based portal for a rapid and transparent view of the status of pending issues.
• Financial services: billing and account reconciliation for all registry services according to pricing established in respective agreements.
Reporting is an important component of supporting registry operations. Afilias will provide reporting to the registry operator and registrars, and financial reporting.
Reporting provided to registry operator
Afilias provides an extensive suite of reports to the registry operator, including daily, weekly and monthly reports with data at the transaction level that enable the registry operator to track and reconcile at whatever level of detail preferred. Afilias provides the exact data required by ICANN in the required format to enable the registry operator to meet its technical reporting requirements to ICANN.
In addition, Afilias offers access to a data warehouse capability that will enable near real-time data to be available 24x7. This can be arranged by informing the Afilias Account Manager regarding who should have access. Afilias’ data warehouse capability enables drill-down analytics all the way to the transaction level.
Reporting available to registrars
Afilias provides an extensive suite of reporting to registrars and has been doing so in an exemplary manner for more than ten years. Specifically, Afilias provides daily, weekly and monthly reports with detail at the transaction level to enable registrars to track and reconcile at whatever level of detail they prefer.
Reports are provided in standard formats, facilitating import for use by virtually any registrar analytical tool. Registrar reports are available for download via a secure administrative interface. A given registrar will only have access to its own reports. These include the following:
• Daily Reports: Transaction Report, Billable Transactions Report, and Transfer Reports;
• Weekly: Domain Status and Name server Report, Weekly Name server Report, Domains Hosted by Name server Weekly Report, and;
• Monthly: Billing Report and Monthly Expiring Domains Report.
Weekly registrar reports are maintained for each registrar for four weeks. Weekly reports older than four weeks will be archived for a period of six months, after which they will be deleted.
Registrar account balances are updated real-time when payments and withdrawals are posted to the registrarsʹ accounts. In addition, the registrar account balances are updated as and when they perform billable transactions at the registry level.
Afilias provides Deposit⁄Withdrawal Reports that are updated periodically to reflect payments received or credits and withdrawals posted to the registrar accounts.
The following reports are also available: a) Daily Billable Transaction Report, containing details of all the billable transactions performed by all the registrars in the SRS, b) daily e-mail reports containing the number of domains in the registry and a summary of the number and types of billable transactions performed by the registrars, and c) registry operator versions of most registrar reports (for example, a daily Transfer Report that details all transfer activity between all of the registrars in the SRS).
Afilias approach to registry support
Afilias, the back end registry services provider for this TLD, is dedicated to managing the technical operations and support of this TLD in a secure, stable and reliable manner. With over a decade of registry experience, Afilias has the depth and breadth of experience that ensure existing and new needs are addressed, all while meeting or exceeding service level requirements and customer expectations. This is evident in Afilias’ participation in business, policy and technical organizations supporting registry and Internet technology within ICANN and related organizations. This allows Afilias to be at the forefront of security initiatives such as: DNSSEC, wherein Afilias worked with Public Interest Registry (PIR) to make the .ORG registry the first DNSSEC enabled gTLD and the largest TLD enabled at the time; in enhancing the Internet experience for users across the globe by leading development of IDNs; in pioneering the use of open-source technologies by its usage of PostgreSQL, and; being the first to offer near-real-time dissemination of DNS zone data.
THE RESPONSE FOR THIS QUESTION USES ANGLE BRACKETS (THE “〈” and “〉” CHARACTERS), WHICH ICANN INFORMS US (CASE ID 11027) CANNOT BE PROPERLY RENDERED IN TAS DUE TO SECURITY CONCERNS. HENCE, THE FULL ANSWER TO THIS QUESTION IS ATTACHED AS A PDF FILE.
THE RESPONSE FOR THIS QUESTION USES ANGLE BRACKETS (THE “〈” and “〉” CHARACTERS), WHICH ICANN INFORMS US (CASE ID 11027) CANNOT BE PROPERLY RENDERED IN TAS DUE TO SECURITY CONCERNS. HENCE, THE FULL ANSWER TO THIS QUESTION IS ATTACHED AS A PDF FILE.
Answers for this question (#26) are provided by Afilias, the back-end provider of registry services for this TLD.
Afilias operates the WHOIS (registration data directory service) infrastructure in accordance with RFCs and global best practices, as it does for the 16 TLDs it currently supports. Designed to be robust and scalable, Afilias’ WHOIS service has exceeded all contractual requirements for over a decade. It has extended search capabilities, and methods of limiting abuse.
The WHOIS service operated by Afilias meets and exceeds ICANN’s requirements. Specifically, Afilias will:
• Offer a WHOIS service made available on port 43 that is flexible and standards- compliant;
• Comply with all ICANN policies, and meeting or exceeding WHOIS performance requirements in Specification 10 of the new gTLD Registry Agreement;
• Enable a Searchable WHOIS with extensive search capabilities that offers ease of use while enforcing measures to mitigate access abuse, and;
• Employ a team with significant experience managing a compliant WHOIS service.
Such extensive knowledge and experience managing a WHOIS service enables Afilias to offer a comprehensive plan for this TLD that meets the needs of constituents of the domain name industry and Internet users. The service has been tested by our QA team for RFC compliance, and has been used by registrars and many other parties for an extended period of time. Afilias’ WHOIS service currently serves almost 500 million WHOIS queries per month, with the capacity already built in to handle an order of magnitude increase in WHOIS queries, and the ability to smoothly scale should greater growth be needed.
WHOIS system description and diagram
The Afilias WHOIS system, depicted in figure 26-a, is designed with robustness, availability, compliance, and performance in mind. Additionally, the system has provisions for detecting abusive usage (e.g., excessive numbers of queries from one source). The WHOIS system is generally intended as a publicly available single object lookup system. Afilias uses an advanced, persistent caching system to ensure extremely fast query response times.
Afilias will develop restricted WHOIS functions based on specific domain policy and regulatory requirements as needed for operating the business (as long as they are standards compliant). It will also be possible for contact and registrant information to be returned according to regulatory requirements. The WHOIS database supports multiple string and field searching through a reliable, free, secure web-based interface.
Data objects, interfaces, access and lookups
Registrars can provide an input form on their public websites through which a visitor is able to perform WHOIS queries. The registry operator can also provide a Web-based search on its site. The input form must accept the string to query, along with the necessary input elements to select the object type and interpretation controls. This input form sends its data to the Afilias port 43 WHOIS server. The results from the WHOIS query are returned by the server and displayed in the visitor’s Web browser. The sole purpose of the Web interface is to provide a user-friendly interface for WHOIS queries.
Afilias will provide WHOIS output as per Specification 4 of the new gTLD Registry Agreement. The output for domain records generally consists of the following elements:
• The name of the domain registered and the sponsoring registrar;
• The names of the primary and secondary nameserver(s) for the registered domain name;
• The creation date, registration status and expiration date of the registration;
• The name, postal address, e-mail address, and telephone and fax numbers of the domain name holder;
• The name, postal address, e-mail address, and telephone and fax numbers of the technical contact for the domain name holder;
• The name, postal address, e-mail address, and telephone and fax numbers of the administrative contact for the domain name holder, and;
• The name, postal address, e-mail address, and telephone and fax numbers of the billing contact for the domain name holder.
The following additional features are also present in Afilias’ WHOIS service:
• Support for IDNs, including the language tag and the Punycode representation of the IDN in addition to Unicode Hex and Unicode HTML formats;
• Enhanced support for privacy protection relative to the display of confidential information.
Afilias will also provide sophisticated WHOIS search functionality that includes the ability to conduct multiple string and field searches.
For all WHOIS queries, a user is required to enter the character string representing the information for which they want to search. The object type and interpretation control parameters to limit the search may also be specified. If object type or interpretation control parameter is not specified, WHOIS will search for the character string in the Name field of the Domain object.
WHOIS queries are required to be either an ʺexact searchʺ or a ʺpartial search,ʺ both of which are insensitive to the case of the input string.
An exact search specifies the full string to search for in the database field. An exact match between the input string and the field value is required.
A partial search specifies the start of the string to search for in the database field. Every record with a search field that starts with the input string is considered a match. By default, if multiple matches are found for a query, then a summary containing up to 50 matching results is presented. A second query is required to retrieve the specific details of one of the matching records.
If only a single match is found, then full details will be provided. Full detail consists of the data in the matching object as well as the data in any associated objects. For example: a query that results in a domain object includes the data from the associated host and contact objects.
WHOIS query controls fall into two categories: those that specify the type of field, and those that modify the interpretation of the input or determine the level of output to provide. Each is described below.
The following keywords restrict a search to a specific object type:
• Domain: Searches only domain objects. The input string is searched in the Name field.
• Host: Searches only nameserver objects. The input string is searched in the Name field and the IP Address field.
• Contact: Searches only contact objects. The input string is searched in the ID field.
• Registrar: Searches only registrar objects. The input string is searched in the Name field.
By default, if no object type control is specified, then the Name field of the Domain object is searched.
In addition, Afilias WHOIS systems can perform and respond to WHOIS searches by registrant name, postal address and contact names. Deployment of these features is provided as an option to the registry operator, based upon registry policy and business decision making.
Figure 26-b presents the keywords that modify the interpretation of the input or determine the level of output to provide.
By default, if no interpretation control keywords are used, the output will include full details if a single match is found and a summary if multiple matches are found.
Unique TLD requirements
There are no unique WHOIS requirements for this TLD.
Sunrise WHOIS processes
All ICANN TLDs must offer a Sunrise as part of a rights protection program. Afilias uses EPP extensions that allow registrars to submit trademark and other intellectual property rights (IPR) data to the registry. The following corresponding data will be displayed in WHOIS for relevant domains:
• Trademark Name: element that indicates the name of the Registered Mark.
• Trademark Number: element that indicates the registration number of the IPR.
• Trademark Locality: element that indicates the origin for which the IPR is established (a national or international trademark registry).
• Trademark Entitlement: element that indicates whether the applicant holds the trademark as the original “OWNER”, “CO-OWNER” or “ASSIGNEE”.
• Trademark Application Date: element that indicates the date the Registered Mark was applied for.
• Trademark Registration Date: element that indicates the date the Registered Mark was issued and registered.
• Trademark Class: element that indicates the class of the Registered Mark.
• IPR Type: element that indicates the Sunrise phase the application applies for.
IT and infrastructure resources
All the applications and databases for this TLD will run in a virtual environment hosted by a cluster of servers equipped with the latest Intel Westmere multi-core processors (or a more advanced, stable technology available at the time of deployment). The registry data will be stored on storage arrays of solid-state drives shared over a fast storage area network. The virtual environment allows the infrastructure to easily scale both vertically and horizontally to cater to changing demand. It also facilitates effective utilization of system resources thus reducing energy consumption and carbon footprint.
The applications and servers are supported by network firewalls, routers and switches.
The WHOIS system accommodates both IPv4 and IPv6 addresses.
Each of the servers and network devices are equipped with redundant hot-swappable components and multiple connections to ancillary systems. Additionally, 24x7 support agreements with our hardware vendor with a 4-hour response time at all our data centers guarantees replacement of failed parts in the shortest time possible.
Models of system and network devices used are:
• Servers: Cisco UCS B230 blade servers
• SAN storage arrays: IBM Storwize V7000 with Solid State Drives
• Firewalls: Cisco ASA 5585-X
• Load balancers: F5 Big-IP 6900
• Traffic shapers: Procera PacketLogic PL8720
• Routers: Juniper MX40 3D
• Network switches: Cisco Nexus 7010, Nexus 5548, Nexus 2232
There will be at least four virtual machines (VMs) offering WHOIS service. Each VM will run at least two WHOIS server instances - one for registrars and one for the public. All instances of the WHOIS service is made available to registrars and the public are rate limited to mitigate abusive behavior.
Frequency of synchronization between servers
Registration data records from the EPP publisher database will be replicated to the WHOIS system database on a near-real-time basis whenever an update occurs.
Specifications 4 and 10 compliance
The WHOIS service for this TLD will meet or exceed the performance requirements in the new gTLD Registry Agreement, Specification 10. Figure 26-c provides the exact measurements and commitments. Afilias has a 10 year track record of exceeding WHOIS performance and a skilled team to ensure this continues for all TLDs under management.
The WHOIS service for this TLD will meet or exceed the requirements in the new gTLD Registry Agreement, Specification 4.
RFC 3912 compliance
Afilias will operate the WHOIS infrastructure in compliance with RFCs and global best practices, as it does with the 16 TLDs Afilias currently supports.
Afilias maintains a registry-level centralized WHOIS database that contains information for every registered domain and for all host and contact objects. The WHOIS service will be available on the Internet standard WHOIS port (port 43) in compliance with RFC 3912. The WHOIS service contains data submitted by registrars during the registration process. Changes made to the data by a registrant are submitted to Afilias by the registrar and are reflected in the WHOIS database and service in near-real-time, by the instance running at the primary data center, and in under ten seconds by the instance running at the secondary data center, thus providing all interested parties with up-to-date information for every domain. This service is compliant with the new gTLD Registry Agreement, Specification 4.
The WHOIS service maintained by Afilias will be authoritative and complete, as this will be a “thick” registry (detailed domain contact WHOIS is all held at the registry); users do not have to query different registrars for WHOIS information, as there is one central WHOIS system. Additionally, visibility of different types of data is configurable to meet the registry operator’s needs.
Afilias offers a searchable WHOIS on a web-based Directory Service. Partial match capabilities are offered on the following fields: domain name, registrar ID, and IP address. In addition, Afilias WHOIS systems can perform and respond to WHOIS searches by registrant name, postal address and contact names.
Providing the ability to search important and high-value fields such as registrant name, address and contact names increases the probability of abusive behavior. An abusive user could script a set of queries to the WHOIS service and access contact data in order to create or sell a list of names and addresses of registrants in this TLD. Making the WHOIS machine readable, while preventing harvesting and mining of WHOIS data, is a key requirement integrated into the Afilias WHOIS systems. For instance, Afilias limits search returns to 50 records at a time. If bulk queries were ever necessary (e.g., to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process), Afilias makes such query responses available to carefully screened and limited staff members at the registry operator (and customer support staff) via an internal data warehouse. The Afilias WHOIS system accommodates anonymous access as well as pre-identified and profile-defined uses, with full audit and log capabilities.
The WHOIS service has the ability to tag query responses with labels such as “Do not redistribute” or “Special access granted”. This may allow for tiered response and reply scenarios. Further, the WHOIS service is configurable in parameters and fields returned, which allow for flexibility in compliance with various jurisdictions, regulations or laws.
Afilias offers exact-match capabilities on the following fields: registrar ID, nameserver name, and nameserver’s IP address (only applies to IP addresses stored by the registry, i.e., glue records). Search capabilities are fully available, and results include domain names matching the search criteria (including IDN variants). Afilias manages abuse prevention through rate limiting and CAPTCHA (described below). Queries do not require specialized transformations of internationalized domain names or internationalized data fields
Please see “Query Controls” above for details about search options and capabilities.
Deterring WHOIS abuse
Afilias has adopted two best practices to prevent abuse of the WHOIS service: rate limiting and CAPTCHA.
Abuse of WHOIS services on port 43 and via the Web is subject to an automated rate-limiting system. This ensures that uniformity of service to users is unaffected by a few parties whose activities abuse or otherwise might threaten to overload the WHOIS system.
Abuse of web-based public WHOIS services is subject to the use of CAPTCHA (Completely Automated Public Turing test to tell Computers and Humans Apart) technology. The use of CAPTCHA ensures that uniformity of service to users is unaffected by a few parties whose activities abuse or otherwise might threaten to overload the WHOIS system. The registry operator will adopt a CAPTCHA on its Web-based WHOIS.
Data mining of any sort on the WHOIS system is strictly prohibited, and this prohibition is published in WHOIS output and in terms of service.
For rate limiting on IPv4, there are configurable limits per IP and subnet. For IPv6, the traditional limitations do not apply. Whenever a unique IPv6 IP address exceeds the limit of WHOIS queries per minute, the same rate-limit for the given 64 bits of network prefix that the offending IPv6 IP address falls into will be applied. At the same time, a timer will start and rate-limit validation logic will identify if there are any other IPv6 address within the original 80-bit(⁄48) prefix. If another offending IPv6 address does fall into the ⁄48 prefix then rate-limit validation logic will penalize any other IPv6 addresses that fall into that given 80-bit (⁄48) network. As a security precaution, Afilias will not disclose these limits.
Pre-identified and profile-driven role access allows greater granularity and configurability in both access to the WHOIS service, and in volume⁄frequency of responses returned for queries.
Afilias staff are key participants in the ICANN Security & Stability Advisory Committee’s deliberations and outputs on WHOIS, including SAC003, SAC027, SAC033, SAC037, SAC040, and SAC051. Afilias staff are active participants in both technical and policy decision making in ICANN, aimed at restricting abusive behavior.
WHOIS staff resourcing plans
Since its founding, Afilias is focused on delivering secure, stable and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and on-going maintenance of this TLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the Afilias project management methodology allows efficient and effective use of our staff in a focused way.
Within Afilias, there are 11 staff members who develop and maintain the compliant WHOIS systems. They keep pace with access requirements, thwart abuse, and continually develop software. Of these resources, approximately two staffers are typically required for WHOIS-related code customization. Other resources provide quality assurance, and operations personnel maintain the WHOIS system itself. This team will be responsible for the implementation and on-going maintenance of the new TLD WHOIS service.
Answers for this question (#27) are provided by Afilias, the back-end provider of registry services for this TLD.
Afilias has been managing registrations for over a decade. Afilias has had experience managing registrations for over a decade and supports comprehensive registration lifecycle services including the registration states, all standard grace periods, and can address any modifications required with the introduction of any new ICANN policies.
This TLD will follow the ICANN standard domain lifecycle, as is currently implemented in TLDs such as .ORG and .INFO. The below response includes: a diagram and description of the lifecycle of a domain name in this TLD, including domain creation, transfer protocols, grace period implementation and the respective time frames for each; and the existing resources to support the complete lifecycle of a domain.
As depicted in Figure 27-a, prior to the beginning of the Trademark Claims Service or Sunrise IP protection program[s], Afilias will support the reservation of names in accordance with the new gTLD Registry Agreement, Specification 5.
After the IP protection programs and the general launch, eligible registrants may choose an accredited registrar to register a domain name. The registrar will check availability on the requested domain name and if available, will collect specific objects such as, the required contact and host information from the registrant. The registrar will then provision the information into the registry system using standard Extensible Provisioning Protocol (“EPP”) commands through a secure connection to the registry backend service provider.
When the domain is created, the standard five day Add Grace Period begins, the domain and contact information are available in WHOIS, and normal operating EPP domain statuses will apply. Other specifics regarding registration rules for an active domain include:
• The domain must be unique;
• Restricted or reserved domains cannot be registered;
• The domain can be registered from 1-10 years;
• The domain can be renewed at any time for 1-10 years, but cannot exceed 10 years;
• The domain can be explicitly deleted at any time;
• The domain can be transferred from one registrar to another except during the first 60 days following a successful registration or within 60 days following a transfer; and,
Contacts and hosts can be modified at any time.
The following describe the domain status values recognized in WHOIS when using the EPP protocol following RFC 5731.
• OK or Active: This is the normal status for a domain that has no pending operations or restrictions.
• Inactive: The domain has no delegated name servers.
• Locked: No action can be taken on the domain. The domain cannot be renewed, transferred, updated, or deleted. No objects such as contacts or hosts can be associated to, or disassociated from the domain. This status includes: Delete Prohibited ⁄ Server Delete Prohibited, Update Prohibited ⁄ Server Update Prohibited, Transfer Prohibited, Server Transfer Prohibited, Renew Prohibited, Server Renew Prohibited.
• Hold: The domain will not be included in the zone. This status includes: Client Hold, Server Hold.
• Transfer Prohibited: The domain cannot be transferred away from the sponsoring registrar. This status includes: Client Transfer Prohibited, Server Transfer Prohibited.
The following describe the registration operations that apply to the domain name during the registration period.
a. Domain modifications: This operation allows for modifications or updates to the domain attributes to include:
i. Registrant Contact
ii. Admin Contact
iii. Technical Contact
iv. Billing Contact
v. Host or nameservers
vi. Authorization information
vii. Associated status values
A domain with the EPP status of Client Update Prohibited or Server Update Prohibited may not be modified until the status is removed.
b. Domain renewals: This operation extends the registration period of a domain by changing the expiration date. The following rules apply:
i. A domain can be renewed at any time during its registration term,
ii. The registration term cannot exceed a total of 10 years.
A domain with the EPP status of Client Renew Prohibited or Server Renew Prohibited cannot be renewed.
c. Domain deletions: This operation deletes the domain from the Shared Registry Services (SRS). The following rules apply:
i. A domain can be deleted at any time during its registration term, if the domain is deleted during the Add Grace Period or the Renew⁄Extend Grace Period, the sponsoring registrar will receive a credit,
ii. A domain cannot be deleted if it has “child” nameservers that are associated to other domains.
A domain with the EPP status of Client Delete Prohibited or Server Delete Prohibited cannot be deleted.
d. Domain transfers: A transfer of the domain from one registrar to another is conducted by following the steps below.
i. The registrant must obtain the applicable 〈authInfo〉 code from the sponsoring (losing) registrar.
• Every domain name has an authInfo code as per EPP RFC 5731. The authInfo code is a six- to 16-character code assigned by the registrar at the time the name was created. Its purpose is to aid identification of the domain owner so proper authority can be established (it is the ʺpasswordʺ to the domain).
• Under the Registry-Registrar Agreement, registrars will be required to provide a copy of the authInfo code to the domain registrant upon his or her request.
ii. The registrant must provide the authInfo code to the new (gaining) registrar, who will then initiate a domain transfer request. A transfer cannot be initiated without the authInfo code.
• Every EPP 〈transfer〉 command must contain the authInfo code or the request will fail. The authInfo code represents authority to the registry to initiate a transfer.
iii. Upon receipt of a valid transfer request, the registry automatically asks the sponsoring (losing) registrar to approve the request within five calendar days.
• When a registry receives a transfer request the domain cannot be modified, renewed or deleted until the request has been processed. This status must not be combined with either Client Transfer Prohibited or Server Transfer Prohibited status.
• If the sponsoring (losing) registrar rejects the transfer within five days, the transfer request is cancelled. A new domain transfer request will be required to reinitiate the process.
• If the sponsoring (losing) registrar does not approve or reject the transfer within five days, the registry automatically approves the request.
iv. After a successful transfer, it is strongly recommended that registrars change the authInfo code, so that the prior registrar or registrant cannot use it anymore.
v. Registrars must retain all transaction identifiers and codes associated with successful domain object transfers and protect them from disclosure.
vi. Once a domain is successfully transferred the status of TRANSFERPERIOD is added to the domain for a period of five days.
vii. Successful transfers will result in a one year term extension (resulting in a maximum total of 10 years), which will be charged to the gaining registrar.
e. Bulk transfer: Afilias, supports bulk transfer functionality within the SRS for situations where ICANN may request the registry to perform a transfer of some or all registered objects (includes domain, contact and host objects) from one registrar to another registrar. Once a bulk transfer has been executed, expiry dates for all domain objects remain the same, and all relevant states of each object type are preserved. In some cases the gaining and the losing registrar as well as the registry must approved bulk transfers. A detailed log is captured for each bulk transfer process and is archived for audit purposes.
Applicant will support ICANN’s Transfer Dispute Resolution Process. Applicant will work with Afilias to respond to Requests for Enforcement (law enforcement or court orders) and will follow that process.
1. Auto-renew grace period
The Auto-Renew Grace Period displays as AUTORENEWPERIOD in WHOIS. An auto-renew must be requested by the registrant through the sponsoring registrar and occurs if a domain name registration is not explicitly renewed or deleted by the expiration date and is set to a maximum of 45 calendar days. In this circumstance the registration will be automatically renewed by the registry system the first day after the expiration date. If a Delete, Extend, or Transfer occurs within the AUTORENEWPERIOD the following rules apply:
i. Delete. If a domain is deleted the sponsoring registrar at the time of the deletion receives a credit for the auto-renew fee. The domain then moves into the Redemption Grace Period with a status of PENDING DELETE RESTORABLE.
ii. Renew⁄Extend. A domain can be renewed as long as the total term does not exceed 10 years. The account of the sponsoring registrar at the time of the extension will be charged for the additional number of years the registration is renewed.
iii. Transfer (other than ICANN-approved bulk transfer). If a domain is transferred, the losing registrar is credited for the auto-renew fee, and the year added by the operation is cancelled. As a result of the transfer, the expiration date of the domain is extended by minimum of one year as long as the total term does not exceed 10 years. The gaining registrar is charged for the additional transfer year(s) even in cases where a full year is not added because of the maximum 10 year registration restriction.
2. Redemption grace period
During this period, a domain name is placed in the PENDING DELETE RESTORABLE status when a registrar requests the deletion of a domain that is not within the Add Grace Period. A domain can remain in this state for up to 30 days and will not be included in the zone file. The only action a registrar can take on a domain is to request that it be restored. Any other registrar requests to modify or otherwise update the domain will be rejected. If the domain is restored it moves into PENDING RESTORE and then OK. After 30 days if the domain is not restored it moves into PENDING DELETE SCHEDULED FOR RELEASE before the domain is released back into the pool of available domains.
3. Pending delete
During this period, a domain name is placed in PENDING DELETE SCHEDULED FOR RELEASE status for five days, and all Internet services associated with the domain will remain disabled and domain cannot be restored. After five days the domain is released back into the pool of available domains.
Other grace periods
All ICANN required grace periods will be implemented in the registry backend service provider’s system including the Add Grace Period (AGP), Renew⁄Extend Grace Period (EGP), Transfer Grace Period (TGP), Auto-Renew Grace Period (ARGP), and Redemption Grace Period (RGP). The lengths of grace periods are configurable in the registry system. At this time, the grace periods will be implemented following other gTLDs such as .ORG. More than one of these grace periods may be in effect at any one time. The following are accompanying grace periods to the registration lifecycle.
Add grace period
The Add Grace Period displays as ADDPERIOD in WHOIS and is set to five calendar days following the initial registration of a domain. If the domain is deleted by the registrar during this period, the registry provides a credit to the registrar for the cost of the registration. If a Delete, Renew⁄Extend, or Transfer operation occurs within the five calendar days, the following rules apply.
i. Delete. If a domain is deleted within this period the sponsoring registrar at the time of the deletion is credited for the amount of the registration. The domain is deleted from the registry backend service provider’s database and is released back into the pool of available domains.
ii. Renew⁄Extend. If the domain is renewed within this period and then deleted, the sponsoring registrar will receive a credit for both the registration and the extended amounts. The account of the sponsoring registrar at the time of the renewal will be charged for the initial registration plus the number of years the registration is extended. The expiration date of the domain registration is extended by that number of years as long as the total term does not exceed 10 years.
iii. Transfer (other than ICANN-approved bulk transfer). Transfers under Part A of the ICANN Policy on Transfer of Registrations between registrars may not occur during the ADDPERIOD or at any other time within the first 60 days after the initial registration. Enforcement is the responsibility of the registrar sponsoring the domain name registration and is enforced by the SRS.
Renew ⁄ extend grace period
The Renew ⁄ Extend Grace Period displays as RENEWPERIOD in WHOIS and is set to five calendar days following an explicit renewal on the domain by the registrar. If a Delete, Extend, or Transfer occurs within the five calendar days, the following rules apply:
i. Delete. If a domain is deleted within this period the sponsoring registrar at the time of the deletion receives a credit for the renewal fee. The domain then moves into the Redemption Grace Period with a status of PENDING DELETE RESTORABLE.
ii. Renew⁄Extend. A domain registration can be renewed within this period as long as the total term does not exceed 10 years. The account of the sponsoring registrar at the time of the extension will be charged for the additional number of years the registration is renewed.
iii. Transfer (other than ICANN-approved bulk transfer). If a domain is transferred within the Renew⁄Extend Grace Period, there is no credit to the losing registrar for the renewal fee. As a result of the transfer, the expiration date of the domain registration is extended by a minimum of one year as long as the total term for the domain does not exceed 10 years.
If a domain is auto-renewed, then extended, and then deleted within the Renew⁄Extend Grace Period, the registrar will be credited for any auto-renew fee charged and the number of years for the extension. The years that were added to the domain’s expiration as a result of the auto-renewal and extension are removed. The deleted domain is moved to the Redemption Grace Period with a status of PENDING DELETE RESTORABLE.
Transfer Grace Period
The Transfer Grace period displays as TRANSFERPERIOD in WHOIS and is set to five calendar days after the successful transfer of domain name registration from one registrar to another registrar. Transfers under Part A of the ICANN Policy on Transfer of Registrations between registrars may not occur during the TRANSFERPERIOD or within the first 60 days after the transfer. If a Delete or Renew⁄Extend occurs within that five calendar days, the following rules apply:
i. Delete. If the domain is deleted by the new sponsoring registrar during this period, the registry provides a credit to the registrar for the cost of the transfer. The domain then moves into the Redemption Grace Period with a status of PENDING DELETE RESTORABLE.
ii. Renew⁄Extend. If a domain registration is renewed within the Transfer Grace Period, there is no credit for the transfer. The registrarʹs account will be charged for the number of years the registration is renewed. The expiration date of the domain registration is extended by the renewal years as long as the total term does not exceed 10 years.
Registration lifecycle resources
Since its founding, Afilias is focused on delivering secure, stable and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and on-going maintenance of this TLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the Afilias project management methodology allows efficient and effective use of our staff in a focused way. Virtually all Afilias resource are involved in the registration lifecycle of domains.
There are a few areas where registry staff devote resources to registration lifecycle issues:
a. Supporting Registrar Transfer Disputes. The registry operator will have a compliance staffer handle these disputes as they arise; they are very rare in the existing gTLDs.
b. Afilias has its development and quality assurance departments on hand to modify the grace period functionality as needed, if ICANN issues new Consensus Policies or the RFCs change.
Afilias has more than 30 staff members in these departments.
The registry operator, working with Afilias, will take the requisite operational and technical steps to promote WHOIS data accuracy, limit domain abuse, remove outdated and inaccurate data, and other security measures to ensure the integrity of the TLD. The specific measures include, but are not limited to:
• Posting a TLD Anti-Abuse Policy that clearly defines abuse, and provides point-of-contact information for reporting suspected abuse;
• Committing to rapid identification and resolution of abuse, including suspensions;
• Ensuring completeness of WHOIS information at the time of registration;
• Publishing and maintaining procedures for removing orphan glue records for names removed from the zone, and;
• Establishing measures to deter WHOIS abuse, including rate-limiting, determining data syntax validity, and implementing and enforcing requirements from the Registry-Registrar Agreement.
The Anti-Abuse Policy stated below will be enacted under the contractual authority of the registry operator through the Registry-Registrar Agreement, and the obligations will be passed on to and made binding upon registrants. This policy will be posted on the TLD web site along with contact information for registrants or users to report suspected abuse.
The policy is designed to address the malicious use of domain names. The registry operator and its registrars will make reasonable attempts to limit significant harm to Internet users. This policy is not intended to take the place of the Uniform Domain Name Dispute Resolution Policy (UDRP) or the Uniform Rapid Suspension System (URS), and it is not to be used as an alternate form of dispute resolution or as a brand protection mechanism. Its intent is not to burden law-abiding or innocent registrants and domain users; rather, the intent is to deter those who use domain names maliciously by engaging in illegal or fraudulent activity.
Repeat violations of the abuse policy will result in a case-by-case review of the abuser(s), and the registry operator reserves the right to escalate the issue, with the intent of levying sanctions that are allowed under the TLD anti-abuse policy.
The below policy is a recent version of the policy that has been used by the .INFO registry since 2008, and the .ORG registry since 2009. It has proven to be an effective and flexible tool.
.gecompany Anti-Abuse Policy
The following Anti-Abuse Policy is effective upon launch of the TLD. Malicious use of domain names will not be tolerated. The nature of such abuses creates security and stability issues for the registry, registrars, and registrants, as well as for users of the Internet in general. The registry operator definition of abusive use of a domain includes, without limitation, the following:
• Illegal or fraudulent actions;
• Spam: The use of electronic messaging systems to send unsolicited bulk messages. The term applies to email spam and similar abuses such as instant messaging spam, mobile messaging spam, and the spamming of web sites and Internet forums;
• Phishing: The use of counterfeit web pages that are designed to trick recipients into divulging sensitive data such as personally identifying information, usernames, passwords, or financial data;
• Pharming: The redirecting of unknowing users to fraudulent sites or services, typically through, but not limited to, DNS hijacking or poisoning;
• Willful distribution of malware: The dissemination of software designed to infiltrate or damage a computer system without the ownerʹs informed consent. Examples include, without limitation, computer viruses, worms, keyloggers, and Trojan horses.
• Malicious fast-flux hosting: Use of fast-flux techniques with a botnet to disguise the location of web sites or other Internet services, or to avoid detection and mitigation efforts, or to host illegal activities.
• Botnet command and control: Services run on a domain name that are used to control a collection of compromised computers or ʺzombies,ʺ or to direct distributed denial-of-service attacks (DDoS attacks);
• Illegal Access to Other Computers or Networks: Illegally accessing computers, accounts, or networks belonging to another party, or attempting to penetrate security measures of another individualʹs system (often known as ʺhackingʺ). Also, any activity that might be used as a precursor to an attempted system penetration (e.g., port scan, stealth scan, or other information gathering activity).
Pursuant to the Registry-Registrar Agreement, registry operator reserves the right at its sole discretion to deny, cancel, or transfer any registration or transaction, or place any domain name(s) on registry lock, hold, or similar status, that it deems necessary: (1) to protect the integrity and stability of the registry; (2) to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of registry operator, as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement and this Anti-Abuse Policy, or (5) to correct mistakes made by registry operator or any registrar in connection with a domain name registration. Registry operator also reserves the right to place upon registry lock, hold, or similar status a domain name during resolution of a dispute.
The policy stated above will be accompanied by notes about how to submit a report to the registry operator’s abuse point of contact, and how to report an orphan glue record suspected of being used in connection with malicious conduct (see below).
Abuse point of contact and procedures for handling abuse complaints
The registry operator will establish an abuse point of contact. This contact will be a role-based e-mail address of the form “[email protected]”. This e-mail address will allow multiple staff members to monitor abuse reports on a 24x7 basis, and then work toward closure of cases as each situation calls for. For tracking purposes, the registry operator will have a ticketing system with which all complaints will be tracked internally. The reporter will be provided with the ticket reference identifier for potential follow-up. Afilias will integrate its existing ticketing system with the registry operator’s to ensure uniform tracking and handling of the complaint. This role-based approach has been used successfully by ISPs, e-mail service providers, and registrars for many years, and is considered a global best practice.
The registry operator’s designated abuse handlers will then evaluate complaints received via the abuse system address. They will decide whether a particular issue is of concern, and decide what action, if any, is appropriate.
In general, the registry operator will find itself receiving abuse reports from a wide variety of parties, including security researchers and Internet security companies, financial institutions such as banks, Internet users, and law enforcement agencies among others. Some of these parties may provide good forensic data or supporting evidence of the malicious behavior. In other cases, the party reporting an issue may not be familiar with how to provide such data or proof of malicious behavior. It is expected that a percentage of abuse reports to the registry operator will not be actionable, because there will not be enough evidence to support the complaint (even after investigation), and because some reports or reporters will simply not be credible.
The security function includes a communication and outreach function, with information sharing with industry partners regarding malicious or abusive behavior, in order to ensure coordinated abuse mitigation across multiple TLDs.
Assessing abuse reports requires great care, and the registry operator will rely upon professional, trained investigators who are versed in such matters. The goals are accuracy, good record-keeping, and a zero false-positive rate so as not to harm innocent registrants.
Different types of malicious activities require different methods of investigation and documentation. Further, the registry operator expects to face unexpected or complex situations that call for professional advice, and will rely upon professional, trained investigators as needed.
In general, there are two types of domain abuse that must be addressed:
a) Compromised domains. These domains have been hacked or otherwise compromised by criminals, and the registrant is not responsible for the malicious activity taking place on the domain. For example, the majority of domain names that host phishing sites are compromised. The goal in such cases is to get word to the registrant (usually via the registrar) that there is a problem that needs attention with the expectation that the registrant will address the problem in a timely manner. Ideally such domains do not get suspended, since suspension would disrupt legitimate activity on the domain.
b) Malicious registrations. These domains are registered by malefactors for the purpose of abuse. Such domains are generally targets for suspension, since they have no legitimate use.
The standard procedure is that the registry operator will forward a credible alleged case of malicious domain name use to the domain’s sponsoring registrar with a request that the registrar investigate the case and act appropriately. The registrar will be provided evidence collected as a result of the investigation conducted by the trained abuse handlers. As part of the investigation, if inaccurate or false WHOIS registrant information is detected, the registrar is notified about this. The registrar is the party with a direct relationship with—and a direct contract with—the registrant. The registrar will also have vital information that the registry operator will not, such as:
• Details about the domain purchase, such as the payment method used (credit card, PayPal, etc.);
• The identity of a proxy-protected registrant;
• The purchaser’s IP address;
• Whether there is a reseller involved, and;
• The registrant’s past sales history and purchases in other TLDs (insofar as the registrar can determine this).
Registrars do not share the above information with registry operators due to privacy and liability concerns, among others. Because they have more information with which to continue the investigation, and because they have a direct relationship with the registrant, the registrar is in the best position to evaluate alleged abuse. The registrar can determine if the use violates the registrar’s legal terms of service or the registry Anti-Abuse Policy, and can decide whether or not to take any action. While the language and terms vary, registrars will be expected to include language in their registrar-registrant contracts that indemnifies the registrar if it takes action, and allows the registrar to suspend or cancel a domain name; this will be in addition to the registry Anti-Abuse Policy. Generally, registrars can act if the registrant violates the registrar’s terms of service, or violates ICANN policy, or if illegal activity is involved, or if the use violates the registry’s Anti-Abuse Policy.
If a registrar does not take action within a time period indicated by the registry operator (usually 24 hours), the registry operator might then decide to take action itself. At all times, the registry operator reserves the right to act directly and immediately if the potential harm to Internet users seems significant or imminent, with or without notice to the sponsoring registrar.
The registry operator will be prepared to call upon relevant law enforcement bodies as needed. There are certain cases, for example, Illegal pharmacy domains, where the registry operator will contact the Law Enforcement Agencies to share information about these domains, provide all the evidence collected and work closely with them before any action will be taken for suspension. The specific action is often dependent upon the jurisdiction of which the registry operator, although the operator in all cases will adhere to applicable laws and regulations.
When valid court orders or seizure warrants are received from courts or law enforcement agencies of relevant jurisdiction, the registry operator will order execution in an expedited fashion. Compliance with these will be a top priority and will be completed as soon as possible and within the defined timelines of the order. There are certain cases where Law Enforcement Agencies request information about a domain including but not limited to:
• Registration information
• History of a domain, including recent updates made
• Other domains associated with a registrant’s account
• Patterns of registrant portfolio
Requests for such information is handled on a priority basis and sent back to the requestor as soon as possible. Afilias sets a goal to respond to such requests within 24 hours.
The registry operator may also engage in proactive screening of its zone for malicious use of the domains in the TLD, and report problems to the sponsoring registrars. The registry operator could take advantage of a combination of the following resources, among others:
• Blocklists of domain names and nameservers published by organizations such as SURBL and Spamhaus.
• Anti-phishing feeds, which will provide URLs of compromised and maliciously registered domains being used for phishing.
• Analysis of registration or DNS query data [DNS query data received by the TLD nameservers.]
The registry operator will keep records and track metrics regarding abuse and abuse reports. These will include:
• Number of abuse reports received by the registry’s abuse point of contact described above;
• Number of cases and domains referred to registrars for resolution;
• Number of cases and domains where the registry took direct action;
• Resolution times;
• Number of domains in the TLD that have been blacklisted by major anti-spam blocklist providers, and;
• Phishing site uptimes in the TLD.
Removal of orphan glue records
By definition, orphan glue records used to be glue records. Glue records are related to delegations and are necessary to guide iterative resolvers to delegated nameservers. A glue record becomes an orphan when its parent nameserver record is removed without also removing the corresponding glue record. (Please reference the ICANN SSAC paper SAC048 at: http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf.) Orphan glue records may be created when a domain (example.tld) is placed on EPP ServerHold or ClientHold status. When placed on Hold, the domain is removed from the zone and will stop resolving. However, any child nameservers (now orphan glue) of that domain (e.g., ns1.example.tld) are left in the zone. It is important to keep these orphan glue records in the zone so that any innocent sites using that nameserver will continue to resolve. This use of Hold status is an essential tool for suspending malicious domains.
Afilias observes the following procedures, which are being followed by other registries and are generally accepted as DNS best practices. These procedures are also in keeping with ICANN SSAC recommendations.
When a request to delete a domain is received from a registrar, the registry first checks for the existence of glue records. If glue records exist, the registry will check to see if other domains in the registry are using the glue records. If other domains in the registry are using the glue records then the request to delete the domain will fail until no other domains are using the glue records. If no other domains in the registry are using the glue records then the glue records will be removed before the request to delete the domain is satisfied. If no glue records exist then the request to delete the domain will be satisfied.
If a registrar cannot delete a domain because of the existence of glue records that are being used by other domains, then the registrar may refer to the zone file or the “weekly domain hosted by nameserver report” to find out which domains are using the nameserver in question and attempt to contact the corresponding registrar to request that they stop using the nameserver in the glue record. The registry operator does not plan on performing mass updates of the associated DNS records.
The registry operator will accept, evaluate, and respond appropriately to complaints that orphan glue is being used maliciously. Such reports should be made in writing to the registry operator, and may be submitted to the registry’s abuse point-of-contact. If it is confirmed that an orphan glue record is being used in connection with malicious conduct, the registry operator will have the orphan glue record removed from the zone file. Afilias has the technical ability to execute such requests as needed.
Methods to promote WHOIS accuracy
The creation and maintenance of accurate WHOIS records is an important part of registry management. As described in our response to question #26, WHOIS, the registry operator will manage a secure, robust and searchable WHOIS service for this TLD.
WHOIS data accuracy
The registry operator will offer a “thick” registry system. In this model, all key contact details for each domain name will be stored in a central location by the registry. This allows better access to domain data, and provides uniformity in storing the information. The registry operator will ensure that the required fields for WHOIS data (as per the defined policies for the TLD) are enforced at the registry level. This ensures that the registrars are providing required domain registration data. Fields defined by the registry policy to be mandatory are documented as such and must be submitted by registrars. The Afilias registry system verifies formats for relevant individual data fields (e.g. e-mail, and phone⁄fax numbers). Only valid country codes are allowed as defined by the ISO 3166 code list. The Afilias WHOIS system is extensible, and is capable of using the VAULT system, described further below.
Similar to the centralized abuse point of contact described above, the registry operator can institute a contact email address which could be utilized by third parties to submit complaints for inaccurate or false WHOIS data detected. This information will be processed by Afilias’ support department and forwarded to the registrars. The registrars can work with the registrants of those domains to address these complaints. Afilias will audit registrars on a yearly basis to verify whether the complaints being forwarded are being addressed or not. This functionality, available to all registry operators, is activated based on the registry operator’s business policy.
Afilias also incorporates a spot-check verification system where a randomly selected set of domain names are checked periodically for accuracy of WHOIS data. Afilias’ .PRO registry system incorporates such a verification system whereby 1% of total registrations or 100 domains, whichever number is larger, are spot-checked every month to verify the domain name registrant’s critical information provided with the domain registration data. With both a highly qualified corps of engineers and a 24x7 staffed support function, Afilias has the capacity to integrate such spot-check functionality into this TLD, based on the registry operator’s business policy. Note: This functionality will not work for proxy protected WHOIS information, where registrars or their resellers have the actual registrant data. The solution to that problem lies with either registry or registrar policy, or a change in the general marketplace practices with respect to proxy registrations.
Finally, Afilias’ registry systems have a sophisticated set of billing and pricing functionality which aids registry operators who decide to provide a set of financial incentives to registrars for maintaining or improving WHOIS accuracy. For instance, it is conceivable that the registry operator may decide to provide a discount for the domain registration or renewal fees for validated registrants, or levy a larger cost for the domain registration or renewal of proxy domain names. The Afilias system has the capability to support such incentives on a configurable basis, towards the goal of promoting better WHOIS accuracy.
Role of registrars
As part of the RRA (Registry Registrar Agreement), the registry operator will require the registrar to be responsible for ensuring the input of accurate WHOIS data by their registrants. The Registrar⁄Registered Name Holder Agreement will include a specific clause to ensure accuracy of WHOIS data, and to give the registrar rights to cancel or suspend registrations if the Registered Name Holder fails to respond to the registrar’s query regarding accuracy of data. ICANN’s WHOIS Data Problem Reporting System (WDPRS) will be available to those who wish to file WHOIS inaccuracy reports, as per ICANN policy (http:⁄⁄wdprs.internic.net⁄).
Controls to ensure proper access to domain functions
Several measures are in place in the Afilias registry system to ensure proper access to domain functions, including authentication provisions in the RRA relative to notification and contact updates via use of AUTH-INFO codes.
IP address access control lists, TLS⁄SSL certificates and proper authentication are used to control access to the registry system. Registrars are only given access to perform operations on the objects they sponsor.
Every domain will have a unique AUTH-INFO code. The AUTH-INFO code is a 6- to 16-character code assigned by the registrar at the time the name is created. Its purpose is to aid identification of the domain owner so proper authority can be established. It is the ʺpasswordʺ to the domain name. Registrars must use the domain’s password in order to initiate a registrar-to-registrar transfer. It is used to ensure that domain updates (update contact information, transfer, or deletion) are undertaken by the proper registrant, and that this registrant is adequately notified of domain update activity. Only the sponsoring registrar of a domain has access to the domain’s AUTH-INFO code stored in the registry, and this is accessible only via encrypted, password-protected channels.
Information about other registry security measures such as encryption and security of registrar channels are confidential to ensure the security of the registry system. The details can be found in the response to question #30b.
Validation and abuse mitigation mechanisms
Afilias has developed advanced validation and abuse mitigation mechanisms. These capabilities and mechanisms are described below. These services and capabilities are discretionary and may be utilized by the registry operator based on their policy and business need.
Afilias has the ability to analyze the registration data for known patterns at the time of registration. A database of these known patterns is developed from domains and other associated objects (e.g., contact information) which have been previously detected and suspended after being flagged as abusive. Any domains matching the defined criteria can be flagged for investigation. Once analyzed and confirmed by the domain anti-abuse team members, these domains may be suspended. This provides proactive detection of abusive domains.
Provisions are available to enable the registry operator to only allow registrations by pre-authorized and verified contacts. These verified contacts are given a unique code that can be used for registration of new domains.
Registrant pre-verification and authentication
One of the systems that could be used for validity and identity authentication is VAULT (Validation and Authentication Universal Lookup). It utilizes information obtained from a series of trusted data sources with access to billions of records containing data about individuals for the purpose of providing independent age and id verification as well as the ability to incorporate additional public or private data sources as required. At present it has the following: US Residential Coverage - 90% of Adult Population and also International Coverage - Varies from Country to Country with a minimum of 80% coverage (24 countries, mostly European).
Various verification elements can be used. Examples might include applicant data such as name, address, phone, etc. Multiple methods could be used for verification include integrated solutions utilizing API (XML Application Programming Interface) or sending batches of requests.
• Verification and Authentication requirements would be based on TLD operator requirements or specific criteria.
• Based on required WHOIS Data; registrant contact details (name, address, phone)
• If address⁄ZIP can be validated by VAULT, the validation process can continue (North America +25 International countries)
• If in-line processing and registration and EPP⁄API call would go to the verification clearinghouse and return up to 4 challenge questions.
• If two-step registration is required, then registrants would get a link to complete the verification at a separate time. The link could be specific to a domain registration and pre-populated with data about the registrant.
• If WHOIS data is validated a token would be generated and could be given back to the registrar which registered the domain.
• WHOIS data would reflect the Validated Data or some subset, i.e., fields displayed could be first initial and last name, country of registrant and date validated. Other fields could be generic validation fields much like a “privacy service”.
• A “Validation Icon” customized script would be sent to the registrants email address. This could be displayed on the website and would be dynamically generated to avoid unauthorized use of the Icon. When clicked on the Icon would should limited WHOIS details i.e. Registrant: jdoe, Country: USA, Date Validated: March 29, 2011, as well as legal disclaimers.
• Validation would be annually renewed, and validation date displayed in the WHOIS.
Abuse prevention resourcing plans
Since its founding, Afilias is focused on delivering secure, stable and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and on-going maintenance of this TLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the Afilias project management methodology allows efficient and effective use of our staff in a focused way. Abuse prevention and detection is a function that is staffed across the various groups inside Afilias, and requires a team effort when abuse is either well hidden or widespread, or both. While all of Afilias’ 200+ employees are charged with responsibility to report any detected abuse, the engineering and analysis teams, numbering over 30, provide specific support based on the type of abuse and volume and frequency of analysis required. The Afilias security and support teams have the authority to initiate mitigation.
Afilias has developed advanced validation and abuse mitigation mechanisms. These capabilities and mechanisms are described below. These services and capabilities are discretionary and may be utilized by the registry operator based on their policy and business need.
This TLD’s anticipated volume of registrations in the first three years of operations is listed in response #46. Afilias and the registry operator’s anti-abuse function anticipates the expected volume and type of registrations, and together will adequately cover the staffing needs for this TLD. The registry operator will maintain an abuse response team, which may be a combination of internal staff and outside specialty contractors, adjusting to the needs of the size and type of TLD. The team structure planned for this TLD is based on several years of experience responding to, mitigating, and managing abuse for TLDs of various sizes. The team will generally consist of abuse handlers (probably internal), a junior analyst, (either internal or external), and a senior security consultant (likely an external resource providing the registry operator with extra expertise as needed). These responders will be specially trained in the investigation of abuse complaints, and will have the latitude to act expeditiously to suspend domain names (or apply other remedies) when called for.
The exact resources required to maintain an abuse response team must change with the size and registration procedures of the TLD. An initial abuse handler is necessary as a point of contact for reports, even if a part-time responsibility. The abuse handlers monitor the abuse email address for complaints and evaluate incoming reports from a variety of sources. A large percentage of abuse reports to the registry operator may be unsolicited commercial email. The designated abuse handlers can identify legitimate reports and then decide what action is appropriate, either to act upon them, escalate to a security analyst for closer investigation, or refer them to registrars as per the above-described procedures. A TLD with rare cases of abuse would conform to this structure.
If multiple cases of abuse within the same week occur regularly, the registry operator will consider staffing internally a security analyst to investigate the complaints as they become more frequent. Training an abuse analyst requires 3-6 months and likely requires the active guidance of an experienced senior security analyst for guidance and verification of assessments and recommendations being made.
If this TLD were to regularly experience multiple cases of abuse within the same day, a full-time senior security analyst would likely be necessary. A senior security analyst capable of fulfilling this role should have several years of experience and able to manage and train the internal abuse response team.
The abuse response team will also maintain subscriptions for several security information services, including the blocklists from organizations like SURBL and Spamhaus and anti-phishing and other domain related abuse (malware, fast-flux etc.) feeds. The pricing structure of these services may depend on the size of the domain and some services will include a number of rapid suspension requests for use as needed.
For a large TLD, regular audits of the registry data are required to maintain control over abusive registrations. When a registrar with a significant number of registrations has been compromised or acted maliciously, the registry operator may need to analyze a set of registration or DNS query data. A scan of all the domains of a registrar is conducted only as needed. Scanning and analysis for a large registrar may require as much as a week of full-time effort for a dedicated machine and team.
Rights protection is a core responsibility of the TLD operator, and is supported by a fully-developed plan for rights protection that includes:
• Establishing mechanisms to prevent unqualified registrations (e.g., registrations made in violation of the registry’s eligibility restrictions or policies);
• Implementing a robust Sunrise program, utilizing the Trademark Clearinghouse, the services of one of ICANN’s approved dispute resolution providers, a trademark validation agent, and drawing upon sunrise policies and rules used successfully in previous gTLD launches;
• Implementing a professional trademark claims program that utilizes the Trademark Clearinghouse, and drawing upon models of similar programs used successfully in previous TLD launches;
• Complying with the URS requirements;
• Complying with the UDRP;
• Complying with the PDDRP, and;
• Including all ICANN-mandated and independently developed rights protection mechanisms (“RPMs”) in the registry-registrar agreement entered into by ICANN-accredited registrars authorized to register names in the TLD.
The response below details the rights protection mechanisms at the launch of the TLD (Sunrise and Trademark Claims Service) which comply with rights protection policies (URS, UDRP, PDDRP, and other ICANN RPMs), outlines additional provisions made for rights protection, and provides the resourcing plans.
Safeguards for rights protection at the launch of the TLD
The launch of this TLD will include the operation of a trademark claims service according to the defined ICANN processes for checking a registration request and alerting trademark holders of potential rights infringement.
Applicant will establish the following Sunrise eligibility requirements (SERs) as minimum requirements, verified by Clearinghouse data, and incorporate a Sunrise Dispute Resolution Policy (SDRP). The SERs include: (i) ownership of a mark that satisfies the criteria set forth in section 7.2 of the Trademark Clearing House specifications, (ii) description of international class of goods or services covered by registration; (iii) representation that all provided information is true and correct; and (iv) provision of data sufficient to document rights in the trademark.
The SDRP will allow challenges based on the following four grounds: (i) at time the challenged domain name was registered, the registrants did not hold a trademark registration of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; (ii) the domain name is not identical to the mark on which the registrant based its Sunrise registration; (iii) the trademark registration on which the registrant based its Sunrise registration is not of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; or (iv) the trademark registration on which the domain name registrant based its Sunrise registration did not issue on or before the effective date of the Registry Agreement and was not applied for on or before ICANN announced the applications received.
Ongoing rights protection mechanisms
Several mechanisms will be in place to protect rights in this TLD. As described in our responses to questions #27 and #28, measures are in place to ensure domain transfers and updates are only initiated by the appropriate domain holder, and an experienced team is available to respond to legal actions by law enforcement or court orders.
This TLD will conform to all ICANN RPMs including URS (defined below), UDRP, PDDRP, and all measures defined in Specification 7 of the new TLD agreement.
Uniform Rapid Suspension (URS)
The registry operator will implement decisions rendered under the URS on an ongoing basis. Per the URS policy posted on ICANN’s Web site as of this writing, the registry operator will receive notice of URS actions from the ICANN-approved URS providers. These emails will be directed immediately to the registry operator’s support staff, which is on duty 24x7. The support staff will be responsible for creating a ticket for each case, and for executing the directives from the URS provider. All support staff will receive pertinent training.
As per ICANN’s URS guidelines, within 24 hours of receipt of the notice of complaint from the URS provider, the registry operator shall “lock” the domain, meaning the registry shall restrict all changes to the registration data, including transfer and deletion of the domain names, but the name will remain in the TLD DNS zone file and will thus continue to resolve. The support staff will “lock” the domain by associating the following EPP statuses with the domain and relevant contact objects:
• ServerUpdateProhibited, with an EPP reason code of “URS”
• ServerDeleteProhibited, with an EPP reason code of “URS”
• ServerTransferProhibited, with an EPP reason code of “URS”
• The registry operator’s support staff will then notify the URS provider immediately upon locking the domain name, via email.
The registry operator’s support staff will retain all copies of emails from the URS providers, assign them a tracking or ticket number, and will track the status of each opened URS case through to resolution via spreadsheet or database.
The registry operator’s support staff will execute further operations upon notice from the URS providers. The URS provider is required to specify the remedy and required actions of the registry operator, with notification to the registrant, the complainant, and the registrar.
As per the URS guidelines, if the complainant prevails, the “registry operator shall suspend the domain name, which shall remain suspended for the balance of the registration period and would not resolve to the original 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.”
Rights protection via the RRA
The following will be memorialized and be made binding via the Registry-Registrar and Registrar-Registrant Agreements:
• The registry may reject a registration request or a reservation request, or may delete, revoke, suspend, cancel, or transfer a registration or reservation under the following criteria:
a. to enforce registry policies and ICANN requirements; each as amended from time to time;
b. that is not accompanied by complete and accurate information as required by ICANN requirements and⁄or registry policies or where required information is not updated and⁄or corrected as required by ICANN requirements and⁄or registry policies;
c. to protect the integrity and stability of the registry, its operations, and the TLD system;
d. to comply with any applicable law, regulation, holding, order, or decision issued by a court, administrative authority, or dispute resolution service provider with jurisdiction over the registry;
e. to establish, assert, or defend the legal rights of the registry or a third party or to avoid any civil or criminal liability on the part of the registry and⁄or its affiliates, subsidiaries, officers, directors, representatives, employees, contractors, and stockholders;
f. to correct mistakes made by the registry or any accredited registrar in connection with a registration; or
g. as otherwise provided in the Registry-Registrar Agreement and⁄or the Registrar-Registrant Agreement.
Reducing opportunities for behaviors such as phishing or pharming
In our response to question #28, the registry operator has described its anti-abuse program. Rather than repeating the policies and procedures here, please see our response to question #28 for full details.
With specific respect to phishing and pharming, it should be noted by ICANN that this will be a single entity TLD in which Applicant has direct control over each registrant (they are typically on staff or otherwise contractually bound) and how each registration may be used. Further, there will be no open registration period for this TLD, as it will never be an “open” TLD. Since all criminal activity (such as phishing and pharming) is precluded by the mission, values and policies of the registry operator (and its parent organization), criminal activity is not expected to be a problem. If such activity occurs due to hacking or other compromises, the registry operator will take prompt and effective steps to eliminate the activity.
In the case of this TLD, Applicant will apply an approach that addresses registered domain names (rather than potentially registered domains). This approach will not infringe upon the rights of eligible registrants to register domains, and allows Applicant internal controls, as well as community-developed UDRP and URS policies and procedures if needed, to deal with complaints, should there be any.
Afilias is a member of various security fora which provide access to lists of names in each TLD which may be used for malicious purposes. Such identified names will be subject to the TLD anti-abuse policy, including rapid suspensions after due process.
Rights protection resourcing plans
Since its founding, Afilias is focused on delivering secure, stable and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and on-going maintenance of this TLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the Afilias project management methodology allows efficient and effective use of our staff in a focused way.
Supporting RPMs requires several departments within the registry operator as well as within Afilias. The implementation of Sunrise and the Trademark Claims service and on-going RPM activities will pull from the 102 Afilias staff members of the engineering, product management, development, security and policy teams at Afilias and the support staff of the registry operator, which is on duty 24x7. A trademark validator will also be assigned within the registry operator, whose responsibilities may require as much as 50% of full-time employment if the domains under management were to exceed several million. No additional hardware or software resources are required to support this as Afilias has fully-operational capabilities to manage abuse today.
The answer to question #30a is provided by Afilias, the back-end provider of registry services for this TLD.
Afilias aggressively and actively protects the registry system from known threats and vulnerabilities, and has deployed an extensive set of security protocols, policies and procedures to thwart compromise. Afilias’ robust and detailed plans are continually updated and tested to ensure new threats are mitigated prior to becoming issues. Afilias will continue these rigorous security measures, which include:
• Multiple layers of security and access controls throughout registry and support systems;
• 24x7 monitoring of all registry and DNS systems, support systems and facilities;
• Unique, proven registry design that ensures data integrity by granting only authorized access to the registry system, all while meeting performance requirements;
• Detailed incident and problem management processes for rapid review, communications, and problem resolution, and;
• Yearly external audits by independent, industry-leading firms, as well as twice-yearly internal audits.
Security policies and protocols
Afilias has included security in every element of its service, including facilities, hardware, equipment, connectivity⁄Internet services, systems, computer systems, organizational security, outage prevention, monitoring, disaster mitigation, and escrow⁄insurance, from the original design, through development, and finally as part of production deployment. Examples of threats and the confidential and proprietary mitigation procedures are detailed in our response to question #30(b).
There are several important aspects of the security policies and procedures to note:
• Afilias hosts domains in data centers around the world that meet or exceed global best practices.
• Afilias’ DNS infrastructure is massively provisioned as part of its DDoS mitigation strategy, thus ensuring sufficient capacity and redundancy to support new gTLDs.
• Diversity is an integral part of all of our software and hardware stability and robustness plan, thus avoiding any single points of failure in our infrastructure.
• Access to any element of our service (applications, infrastructure and data) is only provided on an as-needed basis to employees and a limited set of others to fulfill their job functions. The principle of least privilege is applied.
• All registry components – critical and non-critical – are monitored 24x7 by staff at our NOCs, and the technical staff has detailed plans and procedures that have stood the test of time for addressing even the smallest anomaly. Well-documented incident management procedures are in place to quickly involve the on-call technical and management staff members to address any issues.
Afilias follows the guidelines from the ISO 27001 Information Security Standard (Reference: http:⁄⁄www.iso.org⁄iso⁄iso_catalogue⁄catalogue_tc⁄catalogue_detail.htm?csnumber=42103 ) for the management and implementation of its Information Security Management System. Afilias also utilizes the COBIT IT governance framework to facilitate policy development and enable controls for appropriate management of risk (Reference: http:⁄⁄www.isaca.org⁄cobit). Best practices defined in ISO 27002 are followed for defining the security controls within the organization. Afilias continually looks to improve the efficiency and effectiveness of our processes, and follows industry best practices as defined by the IT Infrastructure Library, or ITIL (Reference: http:⁄⁄www.itil-officialsite.com⁄).
The Afilias registry system is located within secure data centers that implement a multitude of security measures both to minimize any potential points of vulnerability and to limit any damage should there be a breach. The characteristics of these data centers are described fully in our response to question #30(b).
The Afilias registry system employs a number of multi-layered measures to prevent unauthorized access to its network and internal systems. Before reaching the registry network, all traffic is required to pass through a firewall system. Packets passing to and from the Internet are inspected, and unauthorized or unexpected attempts to connect to the registry servers are both logged and denied. Management processes are in place to ensure each request is tracked and documented, and regular firewall audits are performed to ensure proper operation. 24x7 monitoring is in place and, if potential malicious activity is detected, appropriate personnel are notified immediately.
Afilias employs a set of security procedures to ensure maximum security on each of its servers, including disabling all unnecessary services and processes and regular application of security-related patches to the operating system and critical system applications. Regular external vulnerability scans are performed to verify that only services intended to be available are accessible.
Regular detailed audits of the server configuration are performed to verify that the configurations comply with current best security practices. Passwords and other access means are changed on a regular schedule and are revoked whenever a staff member’s employment is terminated.
Access to registry system
Access to all production systems and software is strictly limited to authorized operations staff members. Access to technical support and network operations teams where necessary are read only and limited only to components required to help troubleshoot customer issues and perform routine checks. Strict change control procedures are in place and are followed each time a change is required to the production hardware⁄application. User rights are kept to a minimum at all times. In the event of a staff member’s employment termination, all access is removed immediately.
Afilias applications use encrypted network communications. Access to the registry server is controlled. Afilias allows access to an authorized registrar only if each of the authentication factors matches the specific requirements of the requested authorization. These mechanisms are also used to secure any web-based tools that allow authorized registrars to access the registry. Additionally, all write transactions in the registry (whether conducted by authorized registrars or the registryʹs own personnel) are logged.
EPP connections are encrypted using TLS⁄SSL, and mutually authenticated using both certificate checks and login⁄password combinations. Web connections are encrypted using TLS⁄SSL for an encrypted tunnel to the browser, and authenticated to the EPP server using login⁄password combinations.
All systems are monitored for security breaches from within the data center and without, using both system-based and network-based testing tools. Operations staff also monitor systems for security-related performance anomalies. Triple-redundant continual monitoring ensures multiple detection paths for any potential incident or problem. Details are provided in our response to questions #30(b) and #42. Network Operations and Security Operations teams perform regular audits in search of any potential vulnerability.
To ensure that registrar hosts configured erroneously or maliciously cannot deny service to other registrars, Afilias uses traffic shaping technologies to prevent attacks from any single registrar account, IP address, or subnet. This additional layer of security reduces the likelihood of performance degradation for all registrars, even in the case of a security compromise at a subset of registrars.
There is a clear accountability policy that defines what behaviors are acceptable and unacceptable on the part of non-staff users, staff users, and management. Periodic audits of policies and procedures are performed to ensure that any weaknesses are discovered and addressed. Aggressive escalation procedures and well-defined Incident Response management procedures ensure that decision makers are involved at early stages of any event.
In short, security is a consideration in every aspect of business at Afilias, and this is evidenced in a track record of a decade of secure, stable and reliable service.
Supporting operational excellence as an example of security practices, Afilias performs a number of internal and external security audits each year of the existing policies, procedures and practices for:
• Access control;
• Security policies;
• Production change control;
• Backups and restores;
• Batch monitoring;
• Intrusion detection, and
• Physical security.
Afilias has an annual Type 2 SSAE 16 audit performed by PricewaterhouseCoopers (PwC). Further, PwC performs testing of the general information technology controls in support of the financial statement audit. A Type 2 report opinion under SSAE 16 covers whether the controls were properly designed, were in place, and operating effectively during the audit period (calendar year). This SSAE 16 audit includes testing of internal controls relevant to Afiliasʹ domain registry system and processes. The report includes testing of key controls related to the following control objectives:
• Controls provide reasonable assurance that registrar account balances and changes to the registrar account balances are authorized, complete, accurate and timely.
• Controls provide reasonable assurance that billable transactions are recorded in the Shared Registry System (SRS) in a complete, accurate and timely manner.
• Controls provide reasonable assurance that revenue is systemically calculated by the Deferred Revenue System (DRS) in a complete, accurate and timely manner.
• Controls provide reasonable assurance that the summary and detail reports, invoices, statements, registrar and registry billing data files, and ICANN transactional reports provided to registry operator(s) are complete, accurate and timely.
• Controls provide reasonable assurance that new applications and changes to existing applications are authorized, tested, approved, properly implemented and documented.
• Controls provide reasonable assurance that changes to existing system software and implementation of new system software are authorized, tested, approved, properly implemented and documented.
• Controls provide reasonable assurance that physical access to data centers is restricted to properly authorized individuals.
• Controls provide reasonable assurance that logical access to system resources is restricted to properly authorized individuals.
• Controls provide reasonable assurance that processing and backups are appropriately authorized and scheduled and that deviations from scheduled processing and backups are identified and resolved.
The last Type 2 report issued was for the year 2010, and it was unqualified, i.e., all systems were evaluated with no material problems found.
During each year, Afilias monitors the key controls related to the SSAE controls. Changes or additions to the control objectives or activities can result due to deployment of new services, software enhancements, infrastructure changes or process enhancements. These are noted and after internal review and approval, adjustments are made for the next review.
In addition to the PricewaterhouseCoopers engagement, Afilias performs internal security audits twice a year. These assessments are constantly being expanded based on risk assessments and changes in business or technology.
Additionally, Afilias engages an independent third-party security organization, PivotPoint Security, to perform external vulnerability assessments and penetration tests on the sites hosting and managing the Registry infrastructure. These assessments are performed with major infrastructure changes, release of new services or major software enhancements. These independent assessments are performed at least annually. A report from a recent assessment is attached with our response to question #30(b).
Afilias has engaged with security companies specializing in application and web security testing to ensure the security of web-based applications offered by Afilias, such as the Web Admin Tool (WAT) for registrars and registry operators.
Finally, Afilias has engaged IBM’s Security services division to perform ISO 27002 gap assessment studies so as to review alignment of Afilias’ procedures and policies with the ISO 27002 standard. Afilias has since made adjustments to its security procedures and policies based on the recommendations by IBM.
Special TLD considerations
Afilias’ rigorous security practices are regularly reviewed; if there is a need to alter or augment procedures for this TLD, they will be done so in a planned and deliberate manner.
Commitments to registrant protection
With over a decade of experience protecting domain registration data, Afilias understands registrant security concerns. Afilias supports a “thick” registry system in which data for all objects are stored in the registry database that is the centralized authoritative source of information. As an active member of IETF (Internet Engineering Task Force), ICANN’s SSAC (Security & Stability Advisory Committee), APWG (Anti-Phishing Working Group), MAAWG (Messaging Anti-Abuse Working Group), USENIX, and ISACA (Information Systems Audits and Controls Association), the Afilias team is highly attuned to the potential threats and leading tools and procedures for mitigating threats. As such, registrants should be confident that:
• Any confidential information stored within the registry will remain confidential;
• The interaction between their registrar and Afilias is secure;
• The Afilias DNS system will be reliable and accessible from any location;
• The registry system will abide by all polices, including those that address registrant data;
• Afilias will not introduce any features or implement technologies that compromise access to the registry system or that compromise registrant security.
Afilias has directly contributed to the development of the documents listed below and we have implemented them where appropriate. All of these have helped improve registrants’ ability to protect their domains name(s) during the domain name lifecycle.
• [SAC049]: SSAC Report on DNS Zone Risk Assessment and Management (03 June 2011)
• [SAC044]: A Registrantʹs Guide to Protecting Domain Name Registration Accounts (05 November 2010)
• [SAC040]: Measures to Protect Domain Registration Services Against Exploitation or Misuse (19 August 2009)
• [SAC028]: SSAC Advisory on Registrar Impersonation Phishing Attacks (26 May 2008)
• [SAC024]: Report on Domain Name Front Running (February 2008)
• [SAC022]: Domain Name Front Running (SAC022, SAC024) (20 October 2007)
• [SAC011]: Problems caused by the non-renewal of a domain name associated with a DNS Name Server (7 July 2006)
• [SAC010]: Renewal Considerations for Domain Name Registrants (29 June 2006)
• [SAC007]: Domain Name Hijacking Report (SAC007) (12 July 2005)
To protect any unauthorized modification of registrant data, Afilias mandates TLS⁄SSL transport (per RFC 5246) and authentication methodologies for access to the registry applications. Authorized registrars are required to supply a list of specific individuals (five to ten people) who are authorized to contact the registry. Each such individual is assigned a pass phrase. Any support requests made by an authorized registrar to registry customer service are authenticated by registry customer service. All failed authentications are logged and reviewed regularly for potential malicious activity. This prevents unauthorized changes or access to registrant data by individuals posing to be registrars or their authorized contacts.
These items reflect an understanding of the importance of balancing data privacy and access for registrants, both individually and as a collective, worldwide user base.
The Afilias 24⁄7 Customer Service Center consists of highly trained staff who collectively are proficient in 15 languages, and who are capable of responding to queries from registrants whose domain name security has been compromised – for example, a victim of domain name hijacking. Afilias provides specialized registrant assistance guides, including specific hand-holding and follow-through in these kinds of commonly occurring circumstances, which can be highly distressing to registrants
Security resourcing plans
Please refer to our response to question #30b for security resourcing plans.
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