8(b). State the specific national or other jursidiction that defines the type of entity identified in 8(a).
8(c). Attach evidence of the applicant's establishment.
9(a). If applying company is publicly traded, provide the exchange and symbol.
9(b). If the applying entity is a subsidiary, provide the parent company.
Cisco Systems, Inc.
9(c). If the applying entity is a joint venture, list all joint venture partners.
11(a). Name(s) and position(s) of all directors
Evan Barry Sloves
President⁄CEO and Secretary
Graham Rae Allan
Vice President⁄Asst Secretary
Robert William Gardner
Chief Financial Officer⁄Treasurer
11(b). Name(s) and position(s) of all officers and partners
Angela Marion Woo
Vice President⁄Asst Secretary
Dan Harry Lang
Vice President⁄Asst Secretary
Robert Francis Johnson
11(c). Name(s) and position(s) of all shareholders holding at least 15% of shares
11(d). For an applying entity that does not have directors, officers, partners, or shareholders: Name(s) and position(s) of all individuals having legal or executive responsibility
Applied-for gTLD string
13. Provide the applied-for gTLD string. If an IDN, provide the U-label.
14(a). If an IDN, provide the A-label (beginning with "xn--").
14(b). If an IDN, provide the meaning or restatement of the string
in English, that is, a description of the literal meaning of the string in the
opinion of the applicant.
14(c). If an IDN, provide the language of the label (in English).
14(c). If an IDN, provide the language of the label (as referenced by ISO-639-1).
14(d). If an IDN, provide the script of the label (in English).
14(d). If an IDN, provide the script of the label (as referenced by ISO 15924).
14(e). If an IDN, list all code points contained in the U-label according to Unicode form.
15(a). If an IDN, Attach IDN Tables for the proposed registry.
15(b). Describe the process used for development of the IDN tables submitted, including consultations and sources used.
15(c). List any variant strings to the applied-for gTLD string according to the relevant IDN tables.
16. Describe the applicant's efforts to ensure that there are no known operational or rendering problems concerning the applied-for gTLD string.
If such issues are known, describe steps that will be taken to mitigate these issues in software and other applications.
The .cisco string and A-Label were developed in line with and checked against the eligibility, stability and policy criteria as stated in the ICANN Applicant Guidebook - version 2012-01-11. The results of those checks are as follows:
- The string has less than 63 characters;
- The string in ASCII is composed of three or more visually distinct characters;
- The ASCII label consists entirely of letters;
- The string is not a reserved name as shown in section 220.127.116.11.1 - Reserved Names of the ICANN Applicant Guidebook - version 2012-01-11; and
- .cisco is not identical or similar to any of the top 10 invalid TLD’s responsible for the majority of DNS pollution, as referenced in the Security and Stability Advisory Committee (SSAC)’s report on this topic at http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac045.pdf. It is likely that the .cisco has not already been queried with meaningful frequency at the root. Therefore, it is unlikely that .cisco will inherit significant invalid query traffic.
Due to the positive results of these checks, Cisco Technology, Inc does not believe that the .cisco gTLD will be subject to any operational or rendering problems.
17. (OPTIONAL) Provide a representation of the label according to the International Phonetic Alphabet (http://www.langsci.ucl.ac.uk/ipa/).
18(a). Describe the mission/purpose of your proposed gTLD.
THE MISSION AND PURPOSE OF THE NEW RESTRICTED .CISCO gTLD IS TO BENEFIT INTERNET USERS BY ENSURING INCREASED TRUST AND CONFIDENCE THROUGH THE ELIMINATION OF USER CONFUSION AND ASSURANCE OF BRAND AUTHENTICITY.
The new .cisco gTLD will operate as a restricted registry, in which Cisco Technology, Inc (Cisco) can create and control domain spaces that promote its brand identity and authenticity. In this regard, the .cisco gTLD will be used by Cisco to provide information, services and resources to consumers in a way that promotes trust, convenience and utility. The .cisco gTLD will provide an authoritative internet space for Cisco and, potentially, its affiliates and partners. Second and third level domains can then be utilised for brand management and marketing purposes, with internet users assured of brand authenticity.
Cisco is the worldwide leader in networking that transforms how people connect, communicate and collaborate. Founded in 1984, Cisco pioneered the development of Internet Protocol-based networking technologies. Cisco has continued this tradition with the development of routing, switching, and other networking-based technologies such as application networking services, collaboration, home networking, security, storage area networking, telepresence systems, unified communications, unified computing, video systems, and wireless. This is in keeping with Cisco’s mission to shape the future of the Internet by creating unprecedented value and opportunity for its customers, employees, investors and ecosystem partners. Headquartered in the United States (California), Cisco and its affiliates have over 240 offices across North America, Latin America, Africa, Asia Pacific, Europe and the Middle East and employ about 63,500 people. Cisco’s parent entity, Cisco Systems, Inc, is listed on the NASDAQ Stock Market and, by Q1 of FY2012, generated around USD11.3 billion in revenue. Cisco’s products and services target enterprises and service providers, small businesses, and home and executive users, and have been used in industries such as financial services, government, healthcare and education. At Cisco, creating long-lasting customer partnerships and working alongside customers to identify their needs and provide solutions that support their success is paramount. Through networked technologies and partnerships, Cisco aims to enable its customers to be more competitive and differentiate themselves in the market by solving their most important technology and business issues. In this regard, consumer trust and continuous innovation are critical considerations in all its activities.
Since the inception of the current domain name system, business activities conducted on the internet are constantly changing and evolving with increased complexity. The volume of commercial transactions over the internet is growing and bringing benefits of simplicity and lowered transaction costs to businesses and consumers. However, at the same time, criminal activities over the internet including data breach, hacking and phishing activities have also become more sophisticated, resulting in loss of consumer confidence beyond mere monetary harm. The .cisco gTLD will facilitate greater trust and assurance from internet users connecting with Cisco online, whilst still allowing convenient and efficient interaction.
Cisco’s mission and purpose for the proposed new gTLD align with ICANN’s initiatives to promote public interest. Cisco is committed to contribute to achieving such initiatives in line with ICANN’s Affirmation of Commitments, which includes:
- consumer trust: the .cisco gTLD registry will be operated in a centralised manner with a restrictive registration policy. Registration of domain names will only be available to Cisco at this stage, which will provide added consumer trust that .cisco domain names are authentic and reliable. As .cisco domain names are subject to registration standards, policies and procedures under Cisco’s control, this eliminates the possibility of malicious conduct within the .cisco domain space;
- competition: the proposed new gTLD is not intended to instigate competition and consumer choice at the level of registration of domain names among prospective registrants. Instead it is anticipated to contribute to ICANN’s initiatives to promote public interest through its operation focused on promoting consumer trust. Increased trust in .cisco will drive existing and new top level domain (TLD) registry operators to make improvements in mechanisms to improve consumer trust of their TLDs; and
- consumer choice: the proposed new gTLD will enable user-driven improvements and innovations, which will enhance Cisco’s marketing efforts through the ability to create new second and third level domain names on demand. These names will provide consumers with more choices for interacting with Cisco. As Cisco has effective control over the registration and use of domain names under the .cisco domain space, this will also contribute towards general service innovations on the internet.
Given the restricted nature of .cisco, the projected number of registrations is likely to be limited to about 50 domain names in the first year. However, over the next few years, the number of registrations is likely to increase to about 650 domain names as Cisco develops and implements new services and marketing campaigns through the creation of relevant domain names for Cisco’s products and services.
As the .cisco gTLD expands and evolves, Cisco may consider offering the use of second level domain names to its affiliates and partners. In any such instance, Cisco will continue to comply with all operational, technical and policy requirements, as well as maintain consumer trust and the stability of the internet. Cisco will keep ICANN reasonably informed of any material developments relating to .cisco, including compliance with the continued operations instrument obligations as set out in Specification 8 of the Registry Agreement.
Cisco does not intend to use geographic names at the second level initially. However, Cisco may use geographic names at a later stage to localise its websites in the countries in which it operates. Such use of geographic names will be in accordance with registration policy and the proposed measures for protection of geographic names as outlined in response to Question 22, with the aim to:
- connect internet users with relevant information as applicable to the territory; and
- comply with required rules and regulations in the relevant territory.
At this stage, Cisco does not intend to utilise Internationalized Domain Names (IDNs). However, as the use of the .cisco gTLD evolves, Cisco may utilise IDNs within the .cisco domain space to allow internet users to engage with .cisco in their native language, creating a more positive user experience and encouraging diversity.
Cisco is a well-recognised global brand with its “Cisco” trademark registered in about 115 countries and territories, such as the US, EU, Australia, China, Brazil and India, for categories including: Electrical and scientific apparatus (Class 9); Advertising and business (Class 35); Telecommunications (Class 38); Education (Class 41); Computer, scientific & legal (Class 42). The company also owns over 1,000 trademark registrations containing the “Cisco” mark across 147 countries including the US, EU, South Korea, Hong Kong, South Africa and Russia in the same categories.
Further, Cisco has an extensive domain name portfolio including approximately 190 existing domain names with an exact match to the applied-for .cisco string (e.g., cisco.com, cisco.org.uk, cisco.us and cisco.org.ru).
Recently, Cisco was successful in securing a sunrise application for the cisco.xxx domain space based on existing trademark registrations.
18(b). How proposed gTLD will benefit registrants, Internet users, and others
18(B)I. WHAT IS THE GOAL OF YOUR PROPOSED gTLD IN TERMS OF AREAS OF SPECIALTY, SERVICE LEVELS OR REPUTATION?
The key goals of the proposed new .cisco gTLD are in line with ICANN’s Affirmation of Commitments: to promote consumer trust, competition and consumer choice. Cisco also seeks to foster its online reputation by participating in the new evolution of the gTLD programme and provide an authoritative internet space through which Cisco is able to communicate with its customers directly and effectively. The ability to create domain names on demand related to specific marketing, specialty service and product development supports these goals. Strengthened security measures, service levels and more effective functionality will provide a trusted and positive user experience.
18(B)II. WHAT DO YOU ANTICIPATE YOUR PROPOSED gTLD WILL ADD TO THE CURRENT SPACE, IN TERMS OF COMPETITION, DIFFERENTIATION, OR INNOVATION?
It is anticipated that the proposed .cisco gTLD will make positive contributions to the wider internet community by providing:
DIFFERENTIATION (INCREASED TRUST):
The .cisco gTLD will simplify how internet users interact with Cisco by providing a distinctive domain space. Internet users will be able to navigate directly to the .cisco gTLD site instead of navigating through Cisco’s large portfolio of domain names across the existing TLDs. This will contribute to the convenience of internet users connecting with Cisco online, saving them time and resources searching for an official site or the relevant product, solution or service offered by Cisco. By providing a simpler .cisco gTLD, Cisco’s customers and employees will be able to use social media to share content on Cisco and engage with each other more easily. The current domain name system has shown that it is vulnerable to malicious abuses due to registration of domain names which seek to exploit consumer confusion. Cisco can address some of these vulnerabilities by maintaining complete control over the domain names registered under the .cisco domain space. Together with consumer trust, internet users will be able to rely on the authoritativeness of the domain names under .cisco domain space, which will differentiate interaction between internet users and Cisco.
The differentiation of .cisco gTLD as a trusted site for Cisco will drive existing and new TLD registry operators to make improvements in mechanisms to improve consumer trust of their TLDs. Internet users will be encouraged to interact with domain names under .cisco domain space. As a result, .cisco will have a flow on effect to enable increased competition. Therefore, the benefits of the proposed .cisco will be distributed not only to its direct customers, but to the internet community at large forcing improved services and competitive pricing in the market place.
With the expansion of the internet community to all corners of the world, the existing TLD structure presents limitations, not only in the availability of domain names for registrants, but also to businesses and organisations establishing a coherent global online brand presence to meet their evolving business needs. It is often difficult to register a domain name in existing domain space due to unavailability of the desired name. This problem is amplified for organisations such as Cisco who work across many different jurisdictions and geographical markets. Even when the desired domain name is available, it may come with a high price tag associated with a purchase of such desired name from a third party. It is a challenge, in terms of cost and resources, to maintain Cisco’s global presence due to these restrictions. Cisco seeks to address these limitations by providing an authoritative internet space for Cisco and its users with the new .cisco gTLD. With the proposed .cisco gTLD, Cisco’s large portfolio of products, solutions and services can also be organised using relevant second or third level domain names to improve navigation amongst its users. Cisco will be able to combine its use of the domain space with innovative user focused marketing and services to provide greater consumer choice.
The proposed .cisco gTLD will provide a positive user experience, which meets the changing and growing needs of the global internet community. Cisco will maintain control in the registration and use of domain names and will ensure that the new gTLD will only be used for purposes authorised by Cisco. Therefore, the .cisco gTLD will:
- provide an easy and intuitive reference and access point for Cisco’s promotional and marketing efforts towards its internet users and customers;
- represent authenticity by limiting the registrations of domain names to Cisco’s exclusive use initially thus promoting user confidence;
- direct internet users to relevant information in a timely manner by creating domain names on demand to manage Cisco’s large portfolio of products, solutions and services;
- allow the use of IDNs to enable customer to interact directly in their native language;
- allow the use of geographic names to localise its websites to connect with internet users in the relevant regions and to comply with local laws;
- enhance security and minimise security risks by implementing necessary technical and policy measures;
- strengthen brand reputation and user confidence by using a more consistent .cisco TLD thereby eliminating user confusion; and
- prevent potential abuses in the registration process reducing overall costs to businesses and users.
The .cisco gTLD should address the concerns that the current domain name system is open to potential malicious abuse and user confusion in the registration processes. Although the current system allows an eligible party to lodge a claim through existing Uniform Domain Name Dispute Resolution Policy (UDRP) or other dispute resolution processes, the .cisco gTLD will reduce potential abuses in the registration processes and overall costs to internet users. User confidence in the domain name system will be strengthened, which will ultimately contribute towards promoting ICANN’s core values in benefiting the public interest.
18(B)IV. PROVIDE A COMPLETE DESCRIPTION OF THE APPLICANTʹS INTENDED REGISTRATION POLICIES IN SUPPORT OF THE GOALS LISTED ABOVE
The proposed registration policy is attached in response to Question 28.
Only Cisco will be eligible to register domain names in .cisco at this stage. The domain name registration processes will address the requirements mandated by ICANN, including rights abuse prevention measures.
18(B)V. WILL YOUR PROPOSED gTLD IMPOSE ANY MEASURES FOR PROTECTING THE PRIVACY OR CONFIDENTIAL INFORMATION OF REGISTRANTS OR USERS? IF SO, PLEASE DESCRIBE ANY SUCH MEASURES.
Cisco is committed to the protection of privacy and confidential information in accordance with its objective of increasing consumer trust and providing a safe and legitimate internet space for internet users. Privacy and confidential information will be protected in accordance with all applicable laws and regulations relating to internet security, privacy and user’s confidential information including compliance with the US-EU Safe Harbor Privacy Principles.
- Collection of personal information: Cisco informs its users of the purpose for collecting personal information.
- Use of personal information: Cisco uses any personal information collected specifically according to the way Cisco specified as the reason for its collection.
- Access to and accuracy of personal information: Cisco makes good faith efforts to honour its user requests to access and correct their data if it is inaccurate or delete their data if Cisco is not required to retain it by law or for legitimate purposes.
- Sharing of personal information: Cisco does not sell or share personal information to third parties for marketing purposes unless granted or required by law to do so.
- Security of personal information
- Children’s privacy: Cisco does not knowingly collect personal information from children under the age of 13.
Cisco will deploy Domain Name System Security Extensions (DNSSEC) which is intended to benefit both Cisco and its users interacting with Cisco online. DNSSEC provides additional security by validating information in the transmission; therefore, it is intended to benefit those who publish information in the domain name system (DNS) and the users who retrieve information from the new .cisco gTLD. Cisco already implements measures to protect privacy or confidential information of its users against misuse, loss, alteration and unauthorised access. Such measures include the use of:
- Hypertext Transfer Protocol Secure (HTTPS) protocol encryption;
- User passwords; and
- Secure Sockets Layer (SSL) Encryption.
Cisco is also TRUSTe certified in connection with its compliance with the US-EU Safe Harbor Privacy Principles.
Cisco will continue to apply all security measures currently implemented and will comply with all other policies and practices required by ICANN in the Registry Agreement and any relevant Consensus Policy for protecting the privacy and confidential information of registrants and users in the new .cisco domain space.
18(B)VI. DESCRIBE WHETHER AND IN WHAT WAYS OUTREACH AND COMMUNICATIONS WILL HELP TO ACHIEVE YOUR PROJECTED BENEFITS.
After delegation, Cisco will consider how best to publicise and promote recognition of the new gTLD within the internet community to be a trusted site and as a sign of authenticity. During the initial stage of the operation of the proposed new gTLD, it is anticipated that internet users will be re-directed to current websites. However, over time, it is foreseen that communication to the internet community of the existence of the proposed new gTLD and encouragement to utilise the trusted site will contribute towards minimising malicious abuses and protecting internet users.
18(c). Describe operating rules to eliminate or minimize social costs or financial resource costs, various types of consumer vulnerabilities.
As a restricted gTLD, registration will only be open to Cisco at this stage and no third parties will be able to register domain names under .cisco domain space. Therefore, it is not anticipated that third party trademark owners will incur costs in relation to the .cisco gTLD. The affiliate entities wishing to register domain names must ensure that all the policy requirements for registration are satisfied. Cisco will utilise the services of the proposed Trademark Clearinghouse to ensure that domain names registered and the use of those domain names do not infringe any registered third party intellectual property rights.
No unaffiliated third party will be permitted to register domain names at this stage. It is estimated that time and money spent by consumers who have been targeted by malicious abuse in utilising services on the internet will reduce over time as a result of the new, trusted .cisco gTLD.
18(C)I. HOW WILL MULTIPLE APPLICATIONS FOR A PARTICULAR DOMAIN NAME BE RESOLVED, FOR EXAMPLE, BY AUCTION OR ON A FIRST-COME⁄FIRST-SERVE BASIS?
The initial use of the proposed new gTLD will be restricted to internal business use and Cisco is intended to be the only registrant under the .cisco gTLD. Therefore, conflicts between multiple applications are not anticipated to occur.
18(C)II. EXPLAIN ANY COST BENEFITS FOR REGISTRANTS YOU INTEND TO IMPLEMENT (E.G., ADVANTAGEOUS PRICING, INTRODUCTORY DISCOUNTS, BULK REGISTRATION DISCOUNTS).
This gTLD will be used for internal purposes only, at this stage, so pricing incentives are not applicable or relevant.
18(C)III. NOTE THAT THE REGISTRY AGREEMENT REQUIRES THAT REGISTRARS BE OFFERED THE OPTION TO OBTAIN INITIAL DOMAIN NAME REGISTRATIONS FOR PERIODS OF ONE TO TEN YEARS AT THE DISCRETION OF THE REGISTRAR, BUT NO GREATER THAN TEN YEARS. ADDITIONALLY, THE REGISTRY AGREEMENT REQUIRES ADVANCE WRITTEN NOTICE OF PRICE INCREASES. DO YOU INTEND TO MAKE CONTRACTUAL COMMITMENTS TO REGISTRANTS REGARDING THE MAGNITUDE OF PRICE ESCALATION? IF SO, PLEASE DESCRIBE YOUR PLAN.
This gTLD will be used for internal purposes only, at this stage, so pricing incentives or pricing increases are not applicable or relevant as no additional fees are to be charged.
19. Is the application for a community-based TLD?
20(a). Provide the name and full description of the community that the applicant is committing to serve.
20(b). Explain the applicant's relationship to the community identified in 20(a).
20(c). Provide a description of the community-based purpose of the applied-for gTLD.
20(d). Explain the relationship between the applied-for gTLD string and the community identified in 20(a).
20(e). Provide a description of the applicant's intended registration policies in support of the community-based purpose of the applied-for gTLD.
20(f). Attach any written endorsements from institutions/groups representative of the community identified in 20(a).
21(a). Is the application for a geographic name?
Protection of Geographic Names
22. Describe proposed measures for protection of geographic names at
the second and other levels in the applied-for gTLD.
Cisco respects the GAC’s Principles regarding New gTLDs, dated March 28, 2007, and generally wishes to abide by the same. In particular, Cisco adheres to and⁄or intends to adhere to the recommendations directed towards new registry operators in Sections 2.1, 2.4, 2.7(b). On the other hand, Cisco assumes that several of the recommendations directed towards new registry operators, in general, are less applicable in the case of Single-Registrant operational models such as .cisco than in a completely open Registry model. These include without limitation Sections 2.2, 2.3, 2.7(a) and 2.9.
In order to comply with the requirements of the Registry Agreement, Specification 5, and as with all other domains in the .cisco TLD, all Two-character labels (§2) and Country and Territory Names (§5) will be initially reserved. However, Cisco believes that the use of geographic terms can provide great benefit and simplicity to internet users because these terms are intuitive ways to resolve to Cisco’s content that is specifically relevant and targeted to users in the particular geographic region and in line with local customs, laws and regulations. The use of the geographic terms will be valuable to internet users because they can be reassured that the content that they are viewing is relevant to their local situation thus mitigating the risk of unnecessary user confusion.
If Cisco elects to use any Two-character label and⁄or Country or Territory Name domains, it will participate in or implement a process by which any Government may reasonably object to such use. Cisco envisions a number of possible scenarios for ensuring Government agreement to the use of Country and Territory names. These will be explored in detail with ICANN and the Governmental Advisory Committee to ensure a mutually agreeable solution. Scenarios range from at a minimum; Cisco informing the Chair of the Governmental Advisory Committee (GAC) to ICANN in writing of its proposed use of geographic terms and provide Governments who wish to do so with an opportunity to block the use of their relevant name in the .cisco TLD. Other plausible scenarios would include:
SCENARIO 1 (LETTER TO GAC)
In advance of any use of geographical names, Cisco will send a letter to the chair of the Governmental Advisory Committee (GAC) informing the GAC of its intention to use geographical names in the .cisco TLD. The letter will outline the reasons for using geographical names and provide Governments with the opportunity to contact Cisco within 90 days to reserve their respective geographical name from use in the TLD. Should a Government inform Cisco that it wishes to reserve the use of their respective geographical name, the name will remain reserved for the duration of Cisco’s registry agreement with ICANN. The opportunity to reserve a name will be offered to Governments free of charge.
In advance of any use of geographical names, Cisco will send a letter to the Government concerned and inform it of Cisco’s intention to use geographical names in the .cisco TLD. The letter will outline the reasons for using geographical names and provide the Government with the opportunity to contact Cisco within 90 days to reserve its respective geographical name from use in the TLD. Should the Government inform Cisco that it wishes to reserve the use of its respective geographical name, the name will remain reserved for the duration of Cisco’s registry agreement with ICANN. The opportunity to reserve a name will be offered to the Government free of charge.
SCENARIO 3 (LETTER REQUESTING PERMISSION FROM INDIVIDUAL GOVERNMENT)
In advance of any use of geographical names Cisco will send a letter to the Government concerned and inform it of Cisco’s intention to use geographical names in the .cisco TLD. The letter will outline the reasons for using geographical names and request the Government’s approval or non-objection to the proposed use of the geographical name. Should the Government not respond to Cisco within 90 days, Cisco will understand this to mean that the Government does not object to Cisco’s proposed use of the geographical name. However should the Government at a later stage contact Cisco and request that the geographical name no longer be used, Cisco will work in good faith with the Government to try to find a mutually agreeable solution.
Generally, it is extremely unlikely that Cisco’s tightly controlled use of any cc.cisco or countryname.cisco domain name could be confusing or detrimental to users, or otherwise offensive to any country. Nor is it likely to be detrimental to the operator of a country code top level domain. To the extent that use of any .cisco domain was ever deemed confusing or offensive, Cisco has a strong desire to resolve the situation quickly and respectfully to any affected Government’s sovereign interests. Cisco will ensure that its designated abuse contact is aware of the additional sensitivities that may potentially arise with respect to use of cc.cisco or countryname.cisco domains, such that any complaints of this nature are prioritized accordingly. Cisco will not use geographic names until ICANN has approved such use.
23. Provide name and full description of all the Registry Services to be provided.
23. REGISTRY SERVICES
Cisco Technology, Inc. (Cisco) has engaged Melbourne IT Limited and its affiliate entities (Melbourne IT) as a service provider to assist Cisco with this application and on-going management of its .cisco gTLD, should this application be successful. Melbourne IT’s managed services incorporate the management and oversight of Cisco’s selected backend registry services provider, Neustar Inc (Neustar), as well as other third party service providers.
Cisco has elected to partner with NeuStar, Inc (Neustar) to provide back-end services for the .cisco registry. In making this decision, Cisco recognized that Neustar already possesses a production-proven registry system that can be quickly deployed and smoothly operated over its robust, flexible, and scalable world-class infrastructure. The existing registry services will be leveraged for the .cisco registry. The following section describes the registry services to be provided.
23.2 STANDARD TECHNICAL AND BUSINESS COMPONENTS
Neustar will provide the highest level of service while delivering a secure, stable and comprehensive registry platform. Cisco will use Neustarʹs Registry Services platform to deploy the .cisco registry, by providing the following Registry Services (none of these services are offered in a manner that is unique to .cisco):
- Registry-Registrar Shared Registration Service (SRS)
- Extensible Provisioning Protocol (EPP)
- Domain Name System (DNS)
- Data Escrow
- Dissemination of Zone Files using Dynamic Updates
- Access to Bulk Zone Files
- Dynamic WHOIS Updates
- IPv6 Support
- Rights Protection Mechanisms
- Internationalized Domain Names (IDN). [Optional should be deleted if not being offered].
The following is a description of each of the services.
Neustarʹs secure and stable SRS is a production-proven, standards-based, highly reliable, and high-performance domain name registration and management system. The SRS includes an EPP interface for receiving data from registrars for the purpose of provisioning and managing domain names and name servers. The response to Question 24 provides specific SRS information.
The .cisco registry will use the Extensible Provisioning Protocol (EPP) for the provisioning of domain names. The EPP implementation will be fully compliant with all RFCs. Registrars are provided with access via an EPP API and an EPP based Web GUI. With more than 10 gTLD, ccTLD, and private TLDs implementations, Neustar has extensive experience building EPP-based registries. Additional discussion on the EPP approach is presented in the response to Question 25.
Cisco will leverage Neustarʹs world-class DNS network of geographically distributed nameserver sites to provide the highest level of DNS service. The service utilizes Anycast routing technology, and supports both IPv4 and IPv6. The DNS network is highly proven, and currently provides service to over 20 TLDs and thousands of enterprise companies. Additional information on the DNS solution is presented in the response to Questions 35.
Neustarʹs existing standard WHOIS solution will be used for the .cisco. The service provides supports for near real-time dynamic updates. The design and construction is agnostic with regard to data display policy is flexible enough to accommodate any data model. In addition, a searchable WHOIS service that complies with all ICANN requirements will be provided. The following WHOIS options will be provided:
- Standard WHOIS (Port 43)
- Standard WHOIS (Web)
- Searchable WHOIS (Web)
An RFC compliant DNSSEC implementation will be provided using existing DNSSEC capabilities. Neustar is an experienced provider of DNSSEC services, and currently manages signed zones for three large top level domains: .biz, .us, and .co. Registrars are provided with the ability to submit and manage DS records using EPP, or through a web GUI. Additional information on DNSSEC, including the management of security extensions is found in the response to Question 43.
23.2.6 DATA ESCROW
Data escrow will be performed in compliance with all ICANN requirements in conjunction with an approved data escrow provider. The data escrow service will:
- Protect against data loss
- Follow industry best practices
- Ensure easy, accurate, and timely retrieval and restore capability in the event of a hardware failure
- Minimizes the impact of software or business failure.
Additional information on the Data Escrow service is provided in the response to Question 38.
23.2.7 DISSEMINATION OF ZONE FILES USING DYNAMIC UPDATES
Dissemination of zone files will be provided through a dynamic, near real-time process. Updates will be performed within the specified performance levels. The proven technology ensures that updates pushed to all nodes within a few minutes of the changes being received by the SRS. Additional information on the DNS updates may be found in the response to Question 35.
23.2.8 ACCESS TO BULK ZONE FILES
Cisco will provide third party access to the bulk zone file in accordance with specification 4, Section 2 of the Registry Agreement. Credentialing and dissemination of the zone files will be facilitated through the Central Zone Data Access Provider.
23.2.9 DYNAMIC WHOIS UPDATES
Updates to records in the WHOIS database will be provided via dynamic, near real-time updates. Guaranteed delivery message oriented middleware is used to ensure each individual WHOIS server is refreshed with dynamic updates. This component ensures that all WHOIS servers are kept current as changes occur in the SRS, while also decoupling WHOIS from the SRS. Additional information on WHOIS updates is presented in response to Question 26.
23.2.10 IPv6 SUPPOR
The .cisco registry will provide IPv6 support in the following registry services: SRS, WHOIS, and DNS⁄DNSSEC. In addition, the registry supports the provisioning of IPv6 AAAA records. A detailed description on IPv6 is presented in the response to Question 36.
23.2.11 REQUIRED RIGHTS PROTECTION MECHANISMS
Cisco, will provide all ICANN required Rights Mechanisms, including:
More information is presented in the response to Question 29.
23.2.12 INTERNATIONALIZED DOMAIN NAMES (IDN)
IDN registrations are provided in full compliance with the IDNA protocol. Neustar possesses extensive experience offering IDN registrations in numerous TLDs, and its IDN implementation uses advanced technology to accommodate the unique bundling needs of certain languages. Character mappings are easily constructed to block out characters that may be deemed as confusing to users. A detailed description of the IDN implementation is presented in response to Question 44.
23.3 UNIQUE SERVICES
Cisco will not be offering services that are unique to .cisco.
23.4 SECURITY OR STABILITY CONCERNS
All services offered are standard registry services that have no known security or stability concerns. Neustar has demonstrated a strong track record of security and stability within the industry.
Demonstration of Technical & Operational Capability
24. Shared Registration System (SRS) Performance
Cisco has partnered with NeuStar, Inc (ʺNeustarʺ), an experienced TLD registry operator, for the operation of the .cisco Registry. The applicant is confident that the plan in place for the operation of a robust and reliable Shared Registration System (SRS) as currently provided by Neustar will satisfy the criterion established by ICANN.
Neustar built its SRS from the ground up as an EPP based platform and has been operating it reliably and at scale since 2001. The software currently provides registry services to five TLDs (.BIZ, .US, TEL, .CO and .TRAVEL) and is used to provide gateway services to the .CN and .TW registries. Neustarʹs state of the art registry has a proven track record of being secure, stable, and robust. It manages more than 6 million domains, and has over 300 registrars connected today.
The following describes a detailed plan for a robust and reliable SRS that meets all ICANN requirements including compliance with Specifications 6 and 10.
24.2 THE PLAN FOR OPERATION OF A ROBUST AND RELIABLE SRS
24.2.1 HIGH-LEVEL SRS SYSTEM DESCRIPTION
The SRS to be used for .cisco will leverage a production-proven, standards-based, highly reliable and high-performance domain name registration and management system that fully meets or exceeds the requirements as identified in the new gTLD Application Guidebook.
The SRS is the central component of any registry implementation and its quality, reliability and capabilities are essential to the overall stability of the TLD. Neustar has a documented history of deploying SRS implementations with proven and verifiable performance, reliability and availability. The SRS adheres to all industry standards and protocols. By leveraging an existing SRS platform, Cisco is mitigating the significant risks and costs associated with the development of a new system. Highlights of the SRS include:
- State-of-the-art, production proven multi-layer design
- Ability to rapidly and easily scale from low to high volume as a TLD grows
- Fully redundant architecture at two sites
- Support for IDN registrations in compliance with all standards
- Use by over 300 Registrars
- EPP connectivity over IPv6
- Performance being measured using 100% of all production transactions (not sampling).
24.2.2 SRS SYSTEMS, SOFTWARE, HARDWARE, AND INTEROPERABILITY
The systems and software that the registry operates on are a critical element to providing a high quality of service. If the systems are of poor quality, if they are difficult to maintain and operate, or if the registry personnel are unfamiliar with them, the registry will be prone to outages. Neustar has a decade of experience operating registry infrastructure to extremely high service level requirements. The infrastructure is designed using best of breed systems and software. Much of the application software that performs registry-specific operations was developed by the current engineering team and a result the team is intimately familiar with its operations.
The architecture is highly scalable and provides the same high level of availability and performance as volumes increase. It combines load balancing technology with scalable server technology to provide a cost effective and efficient method for scaling.
The Registry is able to limit the ability of any one registrar from adversely impacting other registrars by consuming too many resources due to excessive EPP transactions. The system uses network layer 2 level packet shaping to limit the number of simultaneous connections registrars can open to the protocol layer.
All interaction with the Registry is recorded in log files. Log files are generated at each layer of the system. These log files record at a minimum:
- The IP address of the client
- Transaction Details
- Processing Time.
In addition to logging of each and every transaction with the SRS Neustar maintains audit records, in the database, of all transformational transactions. These audit records allow the Registry, in support of the applicant, to produce a complete history of changes for any domain name.
24.2.3 SRS DESIGN
The SRS incorporates a multi-layer architecture that is designed to mitigate risks and easily scale as volumes increase. The three layers of the SRS are:
- Protocol Layer
- Business Policy Layer
Each of the layers is described below.
24.2.4 PROTOCOL LAYER
The first layer is the protocol layer, which includes the EPP interface to registrars. It consists of a high availability farm of load-balanced EPP servers. The servers are designed to be fast processors of transactions. The servers perform basic validations and then feed information to the business policy engines as described below. The protocol layer is horizontally scalable as dictated by volume.
The EPP servers authenticate against a series of security controls before granting service, as follows:
- The registrarʹs host exchanges keys to initiates a TLS handshake session with the EPP server.
- The registrarʹs host must provide credentials to determine proper access levels.
- The registrarʹs IP address must be preregistered in the network firewalls and traffic-shapers.
24.2.5 BUSINESS POLICY LAYER
The Business Policy Layer is the brain of the registry system. Within this layer, the policy engine servers perform rules-based processing as defined through configurable attributes. This process takes individual transactions, applies various validation and policy rules, persists data and dispatches notification through the central database in order to publish to various external systems. External systems fed by the Business Policy Layer include backend processes such as dynamic update of DNS, WHOIS and Billing.
Similar to the EPP protocol farm, the SRS consists of a farm of application servers within this layer. This design ensures that there is sufficient capacity to process every transaction in a manner that meets or exceeds all service level requirements. Some registries couple the business logic layer directly in the protocol layer or within the database. This architecture limits the ability to scale the registry. Using a decoupled architecture enables the load to be distributed among farms of inexpensive servers that can be scaled up or down as demand changes.
The SRS today processes over 30 million EPP transactions daily.
The database is the third core components of the SRS. The primary function of the SRS database is to provide highly reliable, persistent storage for all registry information required for domain registration services. The database is highly secure, with access limited to transactions from authenticated registrars, trusted application-server processes, and highly restricted access by the registry database administrators. A full description of the database can be found in response to Question 33.
Figure 24-1 attached depicts the overall SRS architecture including network components.
24.2.7 NUMBER OF SERVERS
As depicted in the SRS architecture diagram above Neustar operates a high availability architecture where at each level of the stack there are no single points of failures. Each of the network level devices run with dual pairs as do the databases. For the .cisco registry, the SRS will operate with 8 protocol servers and 6 policy engine servers. These expand horizontally as volume increases due to additional TLDs, increased load, and through organic growth. In addition to the SRS servers described above, there are multiple backend servers for services such as DNS and WHOIS. These are discussed in detail within those respective response sections.
24.2.8 DESCRIPTION OF INTERCONNECTIVITY WITH OTHER REGISTRY SYSTEMS
The core SRS service interfaces with other external systems via Neustarʹs external systems layer. The services that the SRS interfaces with include:
- Data Warehouse (Reporting and Data Escrow).
Other external interfaces may be deployed to meet the unique needs of a TLD. At this time there are no additional interfaces planned for .cisco.
The SRS includes an external notifier concept in its business policy engine as a message dispatcher. This design allows time-consuming backend processing to be decoupled from critical online registrar transactions. Using an external notifier solution, the registry can utilize control levers that allow it to tune or to disable processes to ensure optimal performance at all times. For example, during the early minutes of a TLD launch, when unusually high volumes of transactions are expected, the registry can elect to suspend processing of one or more back end systems in order to ensure that greater processing power is available to handle the increased load requirements. This proven architecture has been used with numerous TLD launches, some of which have involved the processing of over tens of millions of transactions in the opening hours. The following are the standard three external notifiers used the SRS:
24.2.9 WHOIS EXTERNAL NOTIFIER
The WHOIS external notifier dispatches a work item for any EPP transaction that may potentially have an impact on WHOIS. It is important to note that, while the WHOIS external notifier feeds the WHOIS system, it intentionally does not have visibility into the actual contents of the WHOIS system. The WHOIS external notifier serves just as a tool to send a signal to the WHOIS system that a change is ready to occur. The WHOIS system possesses the intelligence and data visibility to know exactly what needs to change in WHOIS. See response to Question 26 for greater detail.
24.2.10 DNS EXTERNAL NOTIFIER
The DNS external notifier dispatches a work item for any EPP transaction that may potentially have an impact on DNS. Like the WHOIS external notifier, the DNS external notifier does not have visibility into the actual contents of the DNS zones. The work items that are generated by the notifier indicate to the dynamic DNS update sub-system that a change occurred that may impact DNS. That DNS system has the ability to decide what actual changes must be propagated out to the DNS constellation. See response to Question 35 for greater detail.
24.2.11 BILLING EXTERNAL NOTIFIER
The billing external notifier is responsible for sending all billable transactions to the downstream financial systems for billing and collection. This external notifier contains the necessary logic to determine what types of transactions are billable. The financial systems use this information to apply appropriate debits and credits based on registrar.
24.2.12 DATA WAREHOUSE
The data warehouse is responsible for managing reporting services, including registrar reports, business intelligence dashboards, and the processing of data escrow files. The Reporting Database is used to create both internal and external reports, primarily to support registrar billing and contractual reporting requirement. The data warehouse databases are updated on a daily basis with full copies of the production SRS data.
24.2.13 FREQUENCY OF SYNCHRONIZATION BETWEEN SERVERS
The external notifiers discussed above perform updates in near real-time, well within the prescribed service level requirements. As transactions from registrars update the core SRS, update notifications are pushed to the external systems such as DNS and WHOIS. These updates are typically live in the external system within 2-3 minutes.
24.2.14 SYNCHRONIZATION SCHEME (E.G., HOT STANDBY, COLD STANDBY)
Neustar operates two hot databases within the data center that is operating in primary mode. These two databases are kept in sync via synchronous replication. Additionally, there are two databases in the secondary data center. These databases are updated real time through asynchronous replication. This model allows for high performance while also ensuring protection of data. See response to Question 33 for greater detail.
24.2.15 COMPLIANCE WITH SPECIFICATION 6 SECTION 1.2
The SRS implementation for .cisco is fully compliant with Specification 6, including section 1.2. EPP Standards are described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. Extensible Provisioning Protocol or EPP is defined by a core set of RFCs that standardize the interface that make up the registry-registrar model. The SRS interface supports EPP 1.0 as defined in the following RFCs shown in Table 24-1 attached.
Additional information on the EPP implementation and compliance with RFCs can be found in the response to Question 25.
24.2.16 COMPLIANCE WITH SPECIFICATION 10
Specification 10 of the New TLD Agreement defines the performance specifications of the TLD, including service level requirements related to DNS, RDDS (WHOIS), and EPP. The requirements include both availability and transaction response time measurements. As an experienced registry operator, Neustar has a long and verifiable track record of providing registry services that consistently exceed the performance specifications stipulated in ICANN agreements. This same high level of service will be provided for the .cisco Registry. The following section describes Neustarʹs experience and its capabilities to meet the requirements in the new agreement.
To properly measure the technical performance and progress of TLDs, Neustar collects data on key essential operating metrics. These measurements are key indicators of the performance and health of the registry. Neustarʹs current .biz SLA commitments are among the most stringent in the industry today, and exceed the requirements for new TLDs. Table 24-2 compares the current SRS performance levels compared to the requirements for new TLDs, and clearly demonstrates the ability of the SRS to exceed those requirements.
Their ability to commit and meet such high performance standards is a direct result of their philosophy towards operational excellence. See response to Question 31 for a full description of their philosophy for building and managing for performance.
24.3 RESOURCING PLANS
The development, customization, and on-going support of the SRS are the responsibility of a combination of technical and operational teams, including:
- Database Administration
- Systems Administration
- Network Engineering.
Additionally, if customization or modifications are required, the Product Management and Quality Assurance teams will be involved in the design and testing. Finally, the Network Operations and Information Security play an important role in ensuring the systems involved are operating securely and reliably.
The necessary resources will be pulled from the pool of operational resources described in detail in the response to Question 31. Neustarʹs SRS implementation is very mature, and has been in production for over 10 years. As such, very little new development related to the SRS will be required for the implementation of the .cisco registry. The following resources are available from those teams:
- Development⁄Engineering 19 employees
- Database Administration- 10 employees
- Systems Administration 24 employees
- Network Engineering 5 employees
The resources are more than adequate to support the SRS needs of all the TLDs operated by Neustar, including the .cisco registry.
25. Extensible Provisioning Protocol (EPP)
Ciscoʹs back-end registry operator, Neustar, has over 10 years of experience operating EPP based registries. They deployed one of the first EPP registries in 2001 with the launch of .biz. In 2004, they were the first gTLD to implement EPP 1.0. Over the last ten years Neustar has implemented numerous extensions to meet various unique TLD requirements. Neustar will leverage its extensive experience to ensure Cisco is provided with an unparalleled EPP based registry. The following discussion explains the EPP interface which will be used for the .cisco registry. This interface exists within the protocol farm layer as described in Question 24 and is depicted in Figure 25-1 attached.
25.2 EPP INTERFACE
Registrars are provided with two different interfaces for interacting with the registry. Both are EPP based, and both contain all the functionality necessary to provision and manage domain names. The primary mechanism is an EPP interface to connect directly with the registry. This is the interface registrars will use for most of their interactions with the registry.
However, an alternative web GUI (Registry Administration Tool) that can also be used to perform EPP transactions will be provided. The primary use of the Registry Administration Tool is for performing administrative or customer support tasks. The main features of the EPP implementation are:
- Standards Compliance: The EPP XML interface is compliant to the EPP RFCs. As future EPP RFCs are published or existing RFCs are updated, Neustar makes changes to the implementation keeping in mind of any backward compatibility issues.
- Scalability: The system is deployed keeping in mind that it may be required to grow and shrink the footprint of the Registry system for a particular TLD.
- Fault-tolerance: The EPP servers are deployed in two geographically separate data centers to provide for quick failover capability in case of a major outage in a particular data center. The EPP servers adhere to strict availability requirements defined in the SLAs.
- Configurability: The EPP extensions are built in a way that they can be easily configured to turn on or off for a particular TLD.
- Extensibility: The software is built ground up using object oriented design. This allows for easy extensibility of the software without risking the possibility of the change rippling through the whole application.
- Auditable: The system stores detailed information about EPP transactions from provisioning to DNS and WHOIS publishing. In case of a dispute regarding a name registration, the Registry can provide comprehensive audit information on EPP transactions.
- Security: The system provides IP address based access control, client credential-based authorization test, digital certificate exchange, and connection limiting to the protocol layer.
25.3 COMPLIANCE WITH RFCs AND SPECIFICATIONS
The registry-registrar model is described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. As shown in Table 25-1 attached, EPP is defined by the core set of RFCs that standardize the interface that registrars use to provision domains with the SRS. As a core component of the SRS architecture, the implementation is fully compliant with all EPP RFCs.
Neustar ensures compliance with all RFCs through a variety of processes and procedures. Members from the engineering and standards teams actively monitor and participate in the development of RFCs that impact the registry services, including those related to EPP. When new RFCs are introduced or existing ones are updated, the team performs a full compliance review of each system impacted by the change. Furthermore, all code releases include a full regression test that includes specific test cases to verify RFC compliance.
Neustar has a long history of providing exceptional service that exceeds all performance specifications. The SRS and EPP interface have been designed to exceed the EPP specifications defined in Specification 10 of the Registry Agreement and profiled in Table 25-2 attached. Evidence of Neustarʹs ability to perform at these levels can be found in the .biz monthly progress reports found on the ICANN website.
25.3.1 EPP TOOLKITS
Toolkits, under open source licensing, are freely provided to registrars for interfacing with the SRS. Both Java and C++ toolkits will be provided, along with the accompanying documentation. The Registrar Tool Kit (RTK) is a software development kit (SDK) that supports the development of a registrar software system for registering domain names in the registry using EPP. The SDK consists of software and documentation as described below.
The software consists of working Java and C++ EPP common APIs and samples that implement the EPP core functions and EPP extensions used to communicate between the registry and registrar. The RTK illustrates how XML requests (registration events) can be assembled and forwarded to the registry for processing. The software provides the registrar with the basis for a reference implementation that conforms to the EPP registry-registrar protocol. The software component of the SDK also includes XML schema definition files for all Registry EPP objects and EPP object extensions. The RTK also includes a dummy server to aid in the testing of EPP clients.
The accompanying documentation describes the EPP software package hierarchy, the object data model, and the defined objects and methods (including calling parameter lists and expected response behavior). New versions of the RTK are made available from time to time to provide support for additional features as they become available and support for other platforms and languages.
25.4 PROPIETARY EPP EXTENSIONS
The .cisco registry will not include proprietary EPP extensions. Neustar has implemented various EPP extensions for both internal and external use in other TLD registries. These extensions use the standard EPP extension framework described in RFC 5730. Table 25-3 attached provides a list of extensions developed for other TLDs. Should the .cisco registry require an EPP extension at some point in the future, the extension will be implemented in compliance with all RFC specifications including RFC 3735.
The full EPP schema to be used in the .cisco registry is attached in the document titled EPP Schema Files.
25.5 RESOURCING PLANS
The development and support of EPP is largely the responsibility of the Development⁄Engineering and Quality Assurance teams. As an experience registry operator with a fully developed EPP solution, on-going support is largely limited to periodic updates to the standard and the implementation of TLD specific extensions.
The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:
These resources are more than adequate to support any EPP modification needs of the .cisco registry.
Cisco recognizes the importance of an accurate, reliable, and up-to-date WHOIS database to governments, law enforcement, intellectual property holders and the public as a whole and is firmly committed to complying with all of the applicable WHOIS specifications for data objects, bulk access, and lookups as defined in Specifications 4 and 10 to the Registry Agreement. .ciscoʹs back-end registry services provider, Neustar, has extensive experience providing ICANN and RFC-compliant WHOIS services for each of the TLDs that it operates both as a Registry Operator for gTLDs, ccTLDs and back-end registry services provider. As one of the first thick registry operators in the gTLD space, Neustarʹs WHOIS service has been designed from the ground up to display as much information as required by a TLD and respond to a very stringent availability and performance requirement.
Some of the key features of .ciscoʹs solution include:
- Fully compliant with all relevant RFCs including 3912
- Production proven, highly flexible, and scalable with a track record of 100% availability over the past 10 years
- Exceeds current and proposed performance specifications
- Supports dynamic updates with the capability of doing bulk updates
- Geographically distributed sites to provide greater stability and performance
- In addition, .ciscoʹs thick-WHOIS solution also provides for additional search capabilities and mechanisms to mitigate potential forms of abuse as discussed below. (e.g., IDN, registrant data).
26.2 SOFTWARE COMPONENTS
The WHOIS architecture comprises the following components:
- An in-memory database local to each WHOIS node: To provide for the performance needs, the WHOIS data is served from an in-memory database indexed by searchable keys.
- Redundant servers: To provide for redundancy, the WHOIS updates are propagated to a cluster of WHOIS servers that maintain an independent copy of the database.
- Attack resistant: To ensure that the WHOIS system cannot be abused using malicious queries or DOS attacks, the WHOIS server is only allowed to query the local database and rate limits on queries based on IPs and IP ranges can be readily applied.
- Accuracy auditor: To ensure the accuracy of the information served by the WHOIS servers, a daily audit is done between the SRS information and the WHOIS responses for the domain names which are updated during the last 24-hour period. Any discrepancies are resolved proactively.
- Modular design: The WHOIS system allows for filtering and translation of data elements between the SRS and the WHOIS database to allow for customizations.
- Scalable architecture: The WHOIS system is scalable and has a very small footprint. Depending on the query volume, the deployment size can grow and shrink quickly.
- Flexible: It is flexible enough to accommodate thin, thick, or modified thick models and can accommodate any future ICANN policy, such as different information display levels based on user categorization.
- SRS master database: The SRS database is the main persistent store of the Registry information. The Update Agent computes what WHOIS updates need to be pushed out. A publish-subscribe mechanism then takes these incremental updates and pushes to all the WHOIS slaves that answer queries.
26.3 COMPLIANCE WITH RFC AND SPECIFICATIONS 4 AND 10
Neustar has been running thick-WHOIS Services for over 10+ years in full compliance with RFC 3912 and with Specifications 4 and 10 of the Registry Agreement.RFC 3912 is a simple text based protocol over TCP that describes the interaction between the server and client on port 43. Neustar built a home-grown solution for this service. It processes millions of WHOIS queries per day.
Table 26-1 attached describes Neustarʹs compliance with Specifications 4 and 10.
Neustar ensures compliance with all RFCs through a variety of processes and procedures. Members from the engineering and standards teams actively monitor and participate in the development of RFCs that impact the registry services, including those related to WHOIS. When new RFCs are introduced or existing ones are updated, the team performs a full compliance review of each system impacted by the change. Furthermore, all code releases include a full regression test that includes specific test cases to verify RFC compliance.
26.4 HIGH-LEVEL WHOIS SYSTEM DESCRIPTION
26.4.1 WHOIS SERVICE (PORT 43)
The WHOIS service is responsible for handling port 43 queries. Our WHOIS is optimized for speed using an in-memory database and master-slave architecture between the SRS and WHOIS slaves.
The WHOIS service also has built-in support for IDN. If the domain name being queried is an IDN, the returned results include the language of the domain name, the domain nameʹs UTF-8 encoded representation along with the Unicode code page.
26.4.2 WEB PAGE FOR WHOIS QUERIES
In addition to the WHOIS Service on port 43, Neustar provides a web based WHOIS application (www.whois..cisco). It is an intuitive and easy to use application for the general public to use. WHOIS web application provides all of the features available in the port 43 WHOIS. This includes full and partial search on:
- Domain names
- Registrant, Technical and Administrative Contacts
It also provides features not available on the port 43 service. These include:
1. Redemption Grace Period calculation: Based on the registryʹs policy, domains in pendingDelete can be restorable or scheduled for release depending on the date⁄time the domain went into pendingDelete. For these domains, the web based WHOIS displays Restorable or Scheduled for Release to clearly show this additional status to the user.
2. Extensive support for international domain names (IDN)
3. Ability to perform WHOIS lookups on the actual Unicode IDN
4. Display of the actual Unicode IDN in addition to the ACE-encoded name
5. A Unicode to Punycode and Punycode to Unicode translator
6. An extensive FAQ
7. A list of upcoming domain deletions
26.5 IT AND INFRASTRUCTURE RESOURCES
As described above the WHOIS architecture uses a workflow that decouples the update process from the SRS. This ensures SRS performance is not adversely affected by the load requirements of dynamic updates. It is also decoupled from the WHOIS lookup agent to ensure the WHOIS service is always available and performing well for users. Each of Neustarʹs geographically diverse WHOIS sites use:
- Firewalls, to protect this sensitive data
- Dedicated servers for MQ Series, to ensure guaranteed delivery of WHOIS updates
- Packetshaper for source IP address-based bandwidth limiting
- Load balancers to distribute query load
- Multiple WHOIS servers for maximizing the performance of WHOIS service.
The WHOIS service uses HP BL 460C servers, each with 2 X Quad Core CPU and a 64GB of RAM. The existing infrastructure has 6 servers, but is designed to be easily scaled with additional servers should it be needed.
Figure 26-1 attached depicts the different components of the WHOIS architecture.
26.6 INTERCONNECTIVITY WITH OTHER REGISTRY SYSTEM
As described in Question 24 about the SRS and further in response to Question 31, Technical Overview, when an update is made by a registrar that impacts WHOIS data, a trigger is sent to the WHOIS system by the external notifier layer. The update agent processes these updates, transforms the data if necessary and then uses messaging oriented middleware to publish all updates to each WHOIS slave. The local update agent accepts the update and applies it to the local in-memory database. A separate auditor compares the data in WHOIS and the SRS daily and monthly to ensure accuracy of the published data.
26.7 FREQUENCY OF SYNCHRONIZATION BETWEEN SERVERS
Updates from the SRS, through the external notifiers, to the constellation of independent WHOIS slaves happens in real-time via an asynchronous publish⁄subscribe messaging architecture. The updates are guaranteed to be updated in each slave within the required SLA of 95%, less than or equal to 60 minutes. Please note that Neustarʹs current architecture is built towards the stricter SLAs (95%, less than or equal to 15 minutes) of .BIZ. The vast majority of updates tend to happen within 2-3 minutes.
26.8 PROVISION FOR SEARCHABLE WHOIS CAPABILITIES
Neustar will create a new web-based service to address the new search features based on requirements specified in Specification 4 Section 1.8. The application will enable users to search the WHOIS directory using any one or more of the following fields:
- Domain name
- Registrar ID
- Contacts and registrantʹs name
- Contact and registrantʹs postal address, including all the sub-fields described in EPP (e.g., street, city, state or province, etc.)
- Name server name and name server IP address
- The system will also allow search using non-Latin character sets which are compliant with IDNA specification.
The user will choose one or more search criteria, combine them by Boolean operators (AND, OR, NOT) and provide partial or exact match regular expressions for each of the criterion name-value pairs. The domain names matching the search criteria will be returned to the user.
Figure 26-2 attached shows an architectural depiction of the new service.
To mitigate the risk of this powerful search service being abused by unscrupulous data miners, a layer of security will be built around the query engine which will allow the registry to identify rogue activities and then take appropriate measures. Potential abuses include, but are not limited to:
- Data Mining
- Unauthorized Access
- Excessive Querying
- Denial of Service Attacks
To mitigate the abuses noted above, Neustar will implement any or all of these mechanisms as appropriate:
- Username-password based authentication
- Certificate based authentication
- Data encryption
- CAPTCHA mechanism to prevent robo invocation of Web query
- Fee-based advanced query capabilities for premium customers.
The searchable WHOIS application will adhere to all privacy laws and policies of the .cisco registry.
26.9 RESOURCING PLANS
As with the SRS, the development, customization, and on-going support of the WHOIS service is the responsibility of a combination of technical and operational teams.The primary groups responsible for managing the service include:
- Development⁄Engineering 19 employees
- Database Administration 10 employees
- Systems Administration 24 employees
- Network Engineering 5 employees
Additionally, if customization or modifications are required, the Product Management and Quality Assurance teams will also be involved. Finally, the Network Operations and Information Security play an important role in ensuring the systems involved are operating securely and reliably. The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31.Neustarʹs WHOIS implementation is very mature, and has been in production for over 10 years.As such, very little new development will be required to support the implementation of the .cisco registry.
The resources are more than adequate to support the WHOIS needs of all the TLDs operated by Neustar, including the .cisco registry.
27. Registration Life Cycle
27.1 REGISTRATION LIFE CYCLE
.cisco will follow the lifecycle and business rules found in the majority of gTLDs today. Ciscoʹs back-end operator, Neustar, has over ten years of experience managing numerous TLDs that utilize standard and unique business rules and lifecycles. This section describes the business rules, registration states, and the overall domain lifecycle that will be use for .cisco.
27.1.2 DOMAIN LIFECYCLE - DESCRIPTION
The registry will use the EPP 1.0 standard for provisioning domain names, contacts and hosts. Each domain record is comprised of three registry object types: domain, contacts, and hosts.
Domains, contacts and hosts may be assigned various EPP defined statuses indicating either a particular state or restriction placed on the object. Some statuses may be applied by the Registrar; other statuses may only be applied by the Registry. Statuses are an integral part of the domain lifecycle and serve the dual purpose of indicating the particular state of the domain and indicating any restrictions placed on the domain. The EPP standard defines 17 statuses, however only 14 of these statuses will be used in the .cisco registry per the defined .cisco business rules.
The following is a brief description of each of the statuses. Server statuses may only be applied by the Registry, and client statuses may be applied by the Registrar.
- OK Default status applied by the Registry.
- Inactive Default status applied by the Registry if the domain has less than 2 nameservers.
- PendingCreate Status applied by the Registry upon processing a successful Create command, and indicates further action is pending. This status will not be used in the .cisco registry.
- PendingTransfer Status applied by the Registry upon processing a successful Transfer request command, and indicates further action is pending.
- PendingDelete Status applied by the Registry upon processing a successful Delete command that does not result in the immediate deletion of the domain, and indicates further action is pending.
- PendingRenew Status applied by the Registry upon processing a successful Renew command that does not result in the immediate renewal of the domain, and indicates further action is pending. This status will not be used in the .cisco registry.
- PendingUpdate Status applied by the Registry if an additional action is expected to complete the update, and indicates further action is pending. This status will not be used in the .cisco registry.
- Hold Removes the domain from the DNS zone.
- UpdateProhibited Prevents the object from being modified by an Update command.
- TransferProhibited Prevents the object from being transferred to another Registrar by the Transfer command.
- RenewProhibited Prevents a domain from being renewed by a Renew command.
- DeleteProhibited Prevents the object from being deleted by a Delete command.
The lifecycle of a domain begins with the registration of the domain. All registrations must follow the EPP standard, as well as the specific business rules described in the response to Question 18 above. Upon registration a domain will either be in an active or inactive state. Domains in an active state are delegated and have their delegation information published to the zone. Inactive domains either have no delegation information or their delegation information in not published in the zone. Following the initial registration of a domain, one of five actions may occur during its lifecycle:
- Domain may be updated - Domain may be deleted, either within or after the add-grace period - Domain may be renewed at anytime during the term - Domain may be auto-renewed by the Registry - Domain may be transferred to another registrar.
Each of these actions may result in a change in domain state. This is described in more detail in the following section. Every domain must eventually be renewed, auto-renewed, transferred, or deleted. A registrar may apply EPP statuses described above to prevent specific actions such as updates, renewals, transfers, or deletions.
27.2 REGISTRATION STATES
27.2.1 DOMAIN LIFECYCLE REGISTRATION STATES
As described above the .cisco registry will implement a standard domain lifecycle found in most TLD registries today. There are five possible domain states:
- Active - Inactive - Locked - Pending Transfer - Pending Delete.
All domains are always in either an Active or Inactive state, and throughout the course of the lifecycle may also be in a Locked, Pending Transfer, and Pending Delete state. Specific conditions such as applied EPP policies and registry business rules will determine whether a domain can be transitioned between states. Additionally, within each state, domains may be subject to various timed events such as grace periods, and notification periods.
27.2.2 ACTIVE STATES
The active state is the normal state of a domain and indicates that delegation data has been provided and the delegation information is published in the zone. A domain in an Active state may also be in the Locked or Pending Transfer states.
27.2.3 INACTIVE STATE
The Inactive state indicates that a domain has not been delegated or that the delegation data has not been published to the zone. A domain in an Inactive state may also be in the Locked or Pending Transfer states. By default all domain in the Pending Delete state are also in the Inactive state.
27.2.4 LOCKED STATE
The Locked state indicates that certain specified EPP transactions may not be performed to the domain. A domain is considered to be in a Locked state if at least one restriction has been placed on the domain; however up to eight restrictions may be applied simultaneously. Domains in the Locked state will also be in the Active or Inactive, and under certain conditions may also be in the Pending Transfer or Pending Delete states.
27.2.5 PENDING TRANSFER STATE
The Pending Transfer state indicates a condition in which there has been a request to transfer the domain from one registrar to another. The domain is placed in the Pending Transfer state for a period of time to allow the current (losing) registrar to approve (ack) or reject (nack) the transfer request. Registrars may only nack requests for reasons specified in the Inter-Registrar Transfer Policy.
27.2.6 PENDING DELETE STATE
The Pending Delete State occurs when a Delete command has been sent to the Registry after the first 5 days (120 hours) of registration. The Pending Delete period is 35-days during which the first 30-days the name enters the Redemption Grace Period (RGP) and the last 5-days guarantee that the domain will be purged from the Registry Database and available to public pool for registration on a first come, first serve basis.
27.3 TYPICAL REGISTRATION LIFECYCLE ACTIVITIES
27.3.1 DOMAIN CREATION PROCESS
The creation (registration) of domain names is the fundamental registry operation. All other operations are designed to support or compliment a domain creation. The following steps occur when a domain is created.
1. Contact objects are created in the SRS database. The same contact object may be used for each contact type, or they may all be different. If the contacts already exist in the database this step may be skipped.
2. Nameservers are created in the SRS database. Nameservers are not required to complete the registration process; however any domain with less than 2 name servers will not be resolvable.
3. The domain is created using the each of the objects created in the previous steps. In addition, the term and any client statuses may be assigned at the time of creation.
The actual number of EPP transactions needed to complete the registration of a domain name can be as few as one and as many as 40. The latter assumes seven distinct contacts and 13 nameservers, with Check and Create commands submitted for each object.
27.3.2 UPDATE PROCESS
Registry objects may be updated (modified) using the EPP Modify operation. The Update transaction updates the attributes of the object.
For example, the Update operation on a domain name will only allow the following attributes to be updated:
- Domain statuses - Registrant ID - Administrative Contact ID - Billing Contact ID - Technical Contact ID - Nameservers - AuthInfo - Additional Registrar provided fields.
The Update operation will not modify the details of the contacts. Rather it may be used to associate a different contact object (using the Contact ID) to the domain name. To update the details of the contact object the Update transaction must be applied to the contact itself. For example, if an existing registrant wished to update the postal address, the Registrar would use the Update command to modify the contact object, and not the domain object.
27.3.4 RENEW PROCESS
The term of a domain may be extended using the EPP Renew operation. ICANN policy general establishes the maximum term of a domain name to be 10 years, and Neustar recommends not deviating from this policy. A domain may be renewed⁄extended at any point time, even immediately following the initial registration. The only stipulation is that the overall term of the domain name may not exceed 10 years. If a Renew operation is performed with a term value will extend the domain beyond the 10 year limit, the Registry will reject the transaction entirely.
27.3.5 TRANSFER PROCESS
The EPP Transfer command is used for several domain transfer related operations:
- Initiate a domain transfer - Cancel a domain transfer - Approve a domain transfer - Reject a domain transfer.
To transfer a domain from one Registrar to another the following process is followed:
1. The gaining (new) Registrar submits a Transfer command, which includes the AuthInfo code of the domain name.
2. If the AuthInfo code is valid and the domain is not in a status that does not allow transfers the domain is placed into pendingTransfer status
3. A poll message notifying the losing Registrar of the pending transfer is sent to the Registrarʹs message queue
4. The domain remains in pendingTransfer status for up to 120 hours, or until the losing (current) Registrar Acks (approves) or Nack (rejects) the transfer request
5. If the losing Registrar has not Acked or Nacked the transfer request within the 120 hour timeframe, the Registry auto-approves the transfer
6. The requesting Registrar may cancel the original request up until the transfer has been completed.
A transfer adds an additional year to the term of the domain. In the event that a transfer will cause the domain to exceed the 10 year maximum term, the Registry will add a partial term up to the 10 year limit. Unlike with the Renew operation, the Registry will not reject a transfer operation.
27.3.6 DELETION PROCESS
A domain may be deleted from the SRS using the EPP Delete operation. The Delete operation will result in either the domain being immediately removed from the database or the domain being placed in pendingDelete status. The outcome is dependent on when the domain is deleted. If the domain is deleted within the first five days (120 hours) of registration, the domain is immediately removed from the database. A deletion at any other time will result in the domain being placed in pendingDelete status and entering the Redemption Grace Period (RGP). Additionally, domains that are deleted within five days (120) hours of any billable (add, renew, transfer) transaction may be deleted for credit.
27.4 APPLICABLE TIME ELEMENTS
The following section explains the time elements that are involved.
27.4.1 GRACE PERIODS
There are six grace periods:
- Add-Delete Grace Period (AGP) - Renew-Delete Grace Period - Transfer-Delete Grace Period - Auto-Renew-Delete Grace Period - Auto-Renew Grace Period - Redemption Grace Period (RGP).
The first four grace periods listed above are designed to provide the Registrar with the ability to cancel a revenue transaction (add, renew, or transfer) within a certain period of time and receive a credit for the original transaction.
The following describes each of these grace periods in detail.
27.4.2 ADD-DELETE GRACE PERIOD
The APG is associated with the date the Domain was registered. Domains may be deleted for credit during the initial 120 hours of a registration, and the Registrar will receive a billing credit for the original registration. If the domain is deleted during the Add Grace Period, the domain is dropped from the database immediately and a credit is applied to the Registrarʹs billing account.
27.4.3 RENEW-DELETE GRACE PERIOD
The Renew-Delete Grace Period is associated with the date the Domain was renewed. Domains may be deleted for credit during the 120 hours after a renewal. The grace period is intended to allow Registrars to correct domains that were mistakenly renewed. It should be noted that domains that are deleted during the renew grace period will be placed into pendingDelete and will enter the RGP (see below).
27.4.4 TRANSFER-DELETE GRACE PERIOD
The Transfer-Delete Grace Period is associated with the date the Domain was transferred to another Registrar. Domains may be deleted for credit during the 120 hours after a transfer. It should be noted that domains that are deleted during the renew grace period will be placed into pendingDelete and will enter the RGP. A deletion of domain after a transfer is not the method used to correct a transfer mistake. Domains that have been erroneously transferred or hijacked by another party can be transferred back to the original registrar through various means including contacting the Registry.
27.4.5 AUTO-RENEW-DELETE GRACE PERIOD
The Auto-Renew-Delete Grace Period is associated with the date the Domain was auto-renewed. Domains may be deleted for credit during the 120 hours after an auto-renewal. The grace period is intended to allow Registrars to correct domains that were mistakenly auto-renewed. It should be noted that domains that are deleted during the auto-renew delete grace period will be placed into pendingDelete and will enter the RGP.
27.4.6 AUTO-RENEW GRACE PERIOD
The Auto-Renew Grace Period is a special grace period intended to provide registrants with an extra amount of time, beyond the expiration date, to renew their domain name. The grace period lasts for 45 days from the expiration date of the domain name. Registrars are not required to provide registrants with the full 45 days of the period.
27.4.7 REDEMPTION GRACE PERIOD
The RGP is a special grace period that enables Registrars to restore domains that have been inadvertently deleted but are still in pendingDelete status within the Redemption Grace Period. All domains enter the RGP except those deleted during the AGP.
The RGP period is 30 days, during which time the domain may be restored using the EPP RenewDomain command as described below. Following the 30day RGP period the domain will remain in pendingDelete status for an additional five days, during which time the domain may NOT be restored. The domain is released from the SRS, at the end of the 5 day non-restore period. A restore fee applies and is detailed in the Billing Section. A renewal fee will be automatically applied for any domain past expiration.
Neustar has created a unique restoration process that uses the EPP Renew transaction to restore the domain and fulfill all the reporting obligations required under ICANN policy. The following describes the restoration process.
27.5 STATE DIAGRAM
Figure 27-1 attached provides a description of the registration lifecycle.
The different states of the lifecycle are active, inactive, locked, pending transfer, and pending delete.Please refer to section 27.2 for detailed descriptions of each of these states. The lines between the states represent triggers that transition a domain from one state to another.
The details of each trigger are described below:
- Create:Registry receives a create domain EPP command.
- WithNS:The domain has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
- WithOutNS:The domain has not met the minimum number of nameservers required by registry policy. The domain will not be in the DNS zone.
- Remove Nameservers: Domainʹs nameserver(s) is removed as part of an update domain EPP command. The total nameserver is below the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
- Add Nameservers: Nameserver(s) has been added to domain as part of an update domain EPP command.The total number of nameservers has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
- Delete: Registry receives a delete domain EPP command.
- DeleteAfterGrace: Domain deletion does not fall within the add grace period.
- DeleteWithinAddGrace:Domain deletion falls within add grace period.
- Restore: Domain is restored.Domain goes back to its original state prior to the delete command.
- Transfer: Transfer request EPP command is received.
- Transfer Approve⁄Cancel⁄Reject:Transfer requested is approved or cancel or rejected.
- TransferProhibited: The domain is in clientTransferProhibited and⁄or serverTranferProhibited status. This will cause the transfer request to fail.The domain goes back to its original state.
- DeleteProhibited: The domain is in clientDeleteProhibited and⁄or serverDeleteProhibited status.This will cause the delete command to fail.The domain goes back to its original state.
Note: the locked state is not represented as a distinct state on the diagram as a domain may be in a locked state in combination with any of the other states: inactive, active, pending transfer, or pending delete.
27.5.1 EPP RFC CONSISTENCY
As described above, the domain lifecycle is determined by ICANN policy and the EPP RFCs. Neustar has been operating ICANN TLDs for the past 10 years consistent and compliant with all the ICANN policies and related EPP RFCs.
The registration lifecycle and associated business rules are largely determined by policy and business requirements; as such the Product Management and Policy teams will play a critical role in working Applicant to determine the precise rules that meet the requirements of the TLD. Implementation of the lifecycle rules will be the responsibility of Development⁄Engineering team, with testing performed by the Quality Assurance team.Neustarʹs SRS implementation is very flexible and configurable, and in many case development is not required to support business rule changes.
The .cisco registry will be using standard lifecycle rules, and as such no customization is anticipated.However should modifications be required in the future, the necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31.The following resources are available from those teams:
These resources are more than adequate to support the development needs of all the TLDs operated by Neustar, including the .cisco registry.
28. Abuse Prevention and Mitigation
28.1 ABUSE PREVENTION AND MITIGATION
Strong abuse prevention of a new gTLD is an important benefit to the internet community. .cisco, Cisco and Ciscoʹs back-end registry services provider, Neustar Inc (Neustar), agree that a registry must not only aim for the highest standards of technical and operational competence, but also needs to act as a steward of the space on behalf of the Internet community and ICANN in promoting the public interest. Neustar brings extensive experience establishing and implementing registration policies. This experience will be leveraged to help Cisco combat abusive and malicious domain activity within the new gTLD space.
As stated in response to Question 18, Cisco’s registration policy will address the minimum requirements mandated by ICANN including rights abuse prevention measures. Cisco will be the single registrant of domain names under .Cisco and as such the risk of abuse in .Cisco is very low. Cisco will implement its draft registration policy as means of abuse prevention and mitigation ** (see end of document).
One of those public interest functions for a responsible domain name registry includes working towards the eradication of abusive domain name registrations, including, but not limited to, those resulting from:
- Illegal or fraudulent actions
- Distribution of malware
- Fast flux hosting
- Distribution of child pornography
- Online sale or distribution of illegal pharmaceuticals.
More specifically, although traditionally botnets have used Internet Relay Chat (IRC) servers to control registry and the compromised PCs, or bots, for DDoS attacks and the theft of personal information, an increasingly popular technique, known as fast-flux DNS, allows botnets to use a multitude of servers to hide a key host or to create a highly-available control network. This ability to shift the attacker’s infrastructure over a multitude of servers in various countries creates an obstacle for law enforcement and security researchers to mitigate the effects of these botnets. But a point of weakness in this scheme is its dependence on DNS for its translation services. By taking an active role in researching and monitoring these sorts of botnets, Cisco’s partner, Neustar, has developed the ability to efficiently work with various law enforcement and security communities to begin a new phase of mitigation of these types of threats.
POLICIES AND PROCEDURES TO MINIMIZE ABUSIVE REGISTRATIONS
A Registry must have the policies, resources, personnel, and expertise in place to combat such abusive DNS practices. As Ciscoʹs registry provider, Neustar is at the forefront of the prevention of such abusive practices and is one of the few registry operators to have actually developed and implemented an active “domain takedown” policy. We also believe that a strong program is essential given that registrants have a reasonable expectation that they are in control of the data associated with their domains, especially its presence in the DNS zone. Because domain names are sometimes used as a mechanism to enable various illegitimate activities on the Internet often the best preventative measure to thwart these attacks is to remove the names completely from the DNS before they can impart harm, not only to the domain name registrant, but also to millions of unsuspecting Internet users.
Removing the domain name from the zone has the effect of shutting down all activity associated with the domain name, including the use of all websites and e-mail. The use of this technique should not be entered into lightly. The Cisco Registry will include the necessary action of removing a domain from the zone when its presence in the zone poses a threat to the security and stability of the infrastructure of the Internet or the registry.
ABUSE POINT OF CONTACT
As required by the Registry Agreement, Cisco will establish and publish on its website a single abuse point of contact responsible for addressing inquiries from law enforcement and the public related to malicious and abusive conduct. Cisco will also provide such information to ICANN prior to the delegation of any domain names in the TLD. This information shall consist of, at a minimum, a valid e-mail address dedicated solely to the handling of malicious conduct complaints, and a telephone number and mailing address for the primary contact. We will ensure that this information will be kept accurate and up to date and will be provided to ICANN if and when changes are made. In addition, with respect to inquiries from ICANN-Accredited registrars, our registry services provider, Neustar, shall have an additional point of contact, as it does today, handling requests by registrars related to abusive domain name practices.
28.2 POLICIES REGARDING ABUSE COMPLAINTS
One of the key policies each new gTLD registry will need to have is an Acceptable Use Policy that clearly delineates the types of activities that constitute “abuse” and the repercussions associated with an abusive domain name registration. In addition, the policy will be incorporated into the applicable Registry-Registrar Agreement and reserve the right for the registry to take the appropriate actions based on the type of abuse. This will include locking down the domain name preventing any changes to the contact and nameserver information associated with the domain name, placing the domain name “on hold” rendering the domain name non-resolvable, transferring to the domain name to another registrar, and⁄or in cases in which the domain name is associated with an existing law enforcement investigation, substituting name servers to collect information about the DNS queries to assist the investigation.
Cisco will adopt an Acceptable Use Policy that clearly defines the types of activities that will not be permitted in the TLD and reserves the right of the Applicant to lock, cancel, transfer or otherwise suspend or take down domain names violating the Acceptable Use Policy and allow the Registry where and when appropriate to share information with law enforcement. Each ICANN-Accredited Registrar must agree to pass through the Acceptable Use Policy to its resellers (if applicable) and ultimately to the TLD registrants. Below is the Registry’s initial Acceptable Use Policy that we will use in connection with the Cisco.
.CISCO REGISTRYʹS ACCEPTABLE USE POLICY
This Acceptable Use Policy gives the Registry the ability to quickly lock, cancel, transfer or take ownership of any .cisco domain name, either temporarily or permanently, if the domain name is being used in a manner that appears to threaten the stability, integrity or security of the Registry, or any of its registrar partners – and⁄or that may put the safety and security of any registrant or user at risk. The process also allows the Registry to take preventive measures to avoid any such criminal or security threats.
The Acceptable Use Policy may be triggered through a variety of channels, including, among other things, private complaint, public alert, government or enforcement agency outreach, and the on-going monitoring by the Registry or its partners. In all cases, the Registry or its designees will alert Registry’s registrar partners about any identified threats, and will work closely with them to bring offending sites into compliance.
The following are some (but not all) activities that may be subject to rapid domain compliance:
- Phishing: the attempt to acquire personally identifiable information by masquerading as a website other than Cisco.
- Pharming: the redirection of Internet users to websites other than those the user intends to visit, usually through unauthorized changes to the Hosts file on a victim’s computer or DNS records in DNS servers.
- Dissemination of Malware: the intentional creation and distribution of ʺmaliciousʺ software designed to infiltrate a computer system without the owner’s consent, including, without limitation, computer viruses, worms, key loggers, and Trojans.
- Fast Flux Hosting: a technique used to shelter Phishing, Pharming and Malware sites and networks from detection and to frustrate methods employed to defend against such practices, whereby the IP address associated with fraudulent websites are changed rapidly so as to make the true location of the sites difficult to find.
- Botnetting: the development and use of a command, agent, motor, service, or software which is implemented: (1) to remotely control the computer or computer system of an Internet user without their knowledge or consent, (2) to generate direct denial of service (DDOS) attacks.
- Malicious Hacking: the attempt to gain unauthorized access (or exceed the level of authorized access) to a computer, information system, user account or profile, database, or security system.
- Child Pornography: the storage, publication, display and⁄or dissemination of pornographic materials depicting individuals under the age of majority in the relevant jurisdiction.
The .cisco Registry reserves the right, in its sole discretion, to take any administrative and operational actions necessary, including the use of computer forensics and information security technological services, among other things, in order to implement the Acceptable Use Policy. In addition, the Registry reserves the right to deny, cancel or transfer any registration or transaction, or place any domain name(s) on registry lock, hold or similar status, that it deems necessary, in its discretion; (1) to protect the integrity and stability of the registry; (2) to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of Registry as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement or (5) to correct mistakes made by the Registry or any Registrar in connection with a domain name registration. Registry also reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a dispute.
TAKING ACTION AGAINST ABUSIVE AND⁄OR MALICIOUS ACTIVITY
The Registry is committed to ensuring that those domain names associated with abuse or malicious conduct in violation of the Acceptable Use Policy are dealt with in a timely and decisive manner. These include taking action against those domain names that are being used to threaten the stability and security of the Cisco registry, or is part of a real-time investigation by law enforcement.
Once a complaint is received from a trusted source, third-party, or detected by the Registry, the Registry will use commercially reasonable efforts to verify the information in the complaint. If that information can be verified to the best of the ability of the Registry, the sponsoring registrar will be notified and be given 12 hours to investigate the activity and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the Registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), the Registry will place the domain on “ServerHold”. Although this action removes the domain name from the TLD zone, the domain name record still appears in the TLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved.
COORDINATION WITH LAW ENFORCEMENT
With the assistance of Neustar as its back-end registry services provider, Cisco can meet its obligations under Section 2.8 of the Registry Agreement where required to take reasonable steps to investigate and respond to reports from law enforcement and governmental and quasi-governmental agencies of illegal conduct in connection with the use of its TLD. The Registry will respond to legitimate law enforcement inquiries within one business day from receiving the request. Such response shall include, at a minimum, an acknowledgement of receipt of the request, Questions or comments concerning the request, and an outline of the next steps to be taken by Cisco for rapid resolution of the request.
In the event such request involves any of the activities which can be validated by the Registry and involves the type of activity set forth in the Acceptable Use Policy, the sponsoring registrar is then given 12 hours to investigate the activity further and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), the Registry will place the domain on “serverHold”.
28.3 MEASURES FOR REMOVAL OF ORPHAN GLUE RECORDS
As the Security and Stability Advisory Committee of ICANN (SSAC) rightly acknowledges, although orphaned glue records may be used for abusive or malicious purposes, the “dominant use of orphaned glue supports the correct and ordinary operation of the DNS.” See http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf.
While orphan glue often support correct and ordinary operation of the DNS, we understand that such glue records can be used maliciously to point to name servers that host domains used in illegal phishing, bot-nets, malware, and other abusive behaviors. Problems occur when the parent domain of the glue record is deleted but its children glue records still remain in DNS. Therefore, when the Registry has written evidence of actual abuse of orphaned glue, the Registry will take action to remove those records from the zone to mitigate such malicious conduct.
Neustar run a daily audit of entries in its DNS systems and compares those with its provisioning system. This serves as an umbrella protection to make sure that items in the DNS zone are valid. Any DNS record that shows up in the DNS zone but not in the provisioning system will be flagged for investigation and removed if necessary. This daily DNS audit serves to not only prevent orphaned hosts but also other records that should not be in the zone.
In addition, if either Cisco or Neustar become aware of actual abuse on orphaned glue after receiving written notification by a third party through its Abuse Contact or through its customer support, such glue records will be removed from the zone.
28.4 MEASURES TO PROMOTE WHOIS ACCURACY
Cisco acknowledges that ICANN has developed a number of mechanisms over the past decade that are intended to address the issue of inaccurate WHOIS information. Such measures alone have not proven to be sufficient and Cisco will offer a mechanism whereby third parties can submit complaints directly to the Applicant (as opposed to ICANN or the sponsoring Registrar) about inaccurate or incomplete WHOIS data. Such information shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Thirty days after forwarding the complaint to the registrar, Cisco will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, Applicant reserves the right to suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.
In addition, Cisco shall on its own initiative, no less than twice per year, perform a manual review of a random sampling of Cisco domain names to test the accuracy of the WHOIS information. Although this will not include verifying the actual information in the WHOIS record, Cisco will be examining the WHOIS data for prima facie evidence of inaccuracies. In the event that such evidence exists, it shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Thirty days after forwarding the complaint to the registrar, the Applicant will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, Cisco reserves the right to suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.
28.4.1 AUTHENTICATION OF REGISTRANT INFORMATION
Authentication of registrant information as complete and accurate at time of registration. Measures to accomplish this could include performing background checks, verifying all contact information of principals mentioned in registration data, reviewing proof of establishment documentation, and other means.
28.4.2 MONITORING OF REGISTRATION DATA
Regular monitoring of registration data for accuracy and completeness, employing authentication methods, and establishing policies and procedures to address domain names with inaccurate or incomplete WHOIS data.
28.4.3 POLICIES AND PROCEDURES ENSURING COMPLIANCE
If relying on registrars to enforce measures, establishing policies and procedures to ensure compliance, which may include audits, financial incentives, penalties, or other means. Note that the requirements of the RAA will continue to apply to all ICANN-accredited registrars.
28.5 RESOURCING PLANS
Responsibility for abuse mitigation rests with a variety of functional groups. The Abuse Monitoring team is primarily responsible for providing analysis and conducting investigations of reports of abuse. The customer service team also plays an important role in assisting with the investigations, responded to customers, and notifying registrars of abusive domains. Finally, the Policy⁄Legal team is responsible for developing the relevant policies and procedures. The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:
- Customer Support – 12 employees
- Policy⁄Legal – 2 employees
The resources are more than adequate to support the abuse mitigation procedures of the .cisco registry.
** .CISCO’S DRAFT REGISTRATION POLICY
1. DOMAIN NAME LICENCES
Upon registration of a Domain Name, the Registrant holds a licence to use the Domain Name for a specified period of time in accordance with the Registry Rules. Domain Names may be registered and renewed for 1, 2, 3, 4, 5, 6, 7, 8, 9 or 10 years.
2. SELECTION OF REGISTRARS
Registrars eligible to register domain names must meet the following non-discriminatory criteria (in compliance with clause 2.9 (a) of the Registry Agreement):
(i) be an accredited ICANN Registrar;
(ii) demonstrate a level of understanding of the Domain Name registration policies of the Registry;
(iii) have experience of managing the Domain Names of major corporations;
(iv) have proven tools for domain name portfolio management;
(v) have business processes to perform automated validation (and any additional human checks as required by the Registry) of the eligibility of the domain name for registration according to the Domain Name policies of .cisco;
(vi) demonstrate a sufficient level of security to protect against unauthorised access to the Domain Name records;
(vii) demonstrate experience and have appropriate resources in managing abuse prevention, mitigation and responses;
(viii) provide multi-language support for the registration of IDNs;
(ix) comply with any re-validation of its Registry-Registrar agreement at such regular intervals as are determined by the Registry or as required by ICANN from time to time;
(x) meet applicable technical requirements of .cisco; and
(xi) comply with all conditions, dependencies, policies and other requirements reasonably imposed by Cisco, including maintenance of suitable systems and applications that are capable of interacting with the Registry system.
3. ELIGIBLE REGISTRANTS
The Registrant must be:
(i) an Affiliate entity of Cisco; or
(ii) an organisation explicitly authorised by Cisco; or
(iii) a natural person explicitly authorised by Cisco.
If the Registrant does not meet one of the above eligibility criteria, there is no entitlement to register a Domain Name under the .cisco TLD. If the Registrant ceases to be eligible at any time in the future, the .cisco Registry may cancel or suspend the licence to use the Domain Name immediately.
4. REGISTRY APPROVAL REQUIREMENT
Registration of Domain Names under the .cisco TLD must be approved by Cisco in addition to meeting all requirements under the Registry Rules. Cisco’s approval for a complete and validly submitted application will be authorised by:
(i) a head of appropriate department as nominated by Cisco (“Authorisation Provider”); or
(ii) an authorised person as nominated by Cisco (“Authorised Person”) and notified to the Registrar from time to time.
The Authorisation Provider will notify the Registrar of its decision.
5. REQUIRED CRITERIA FOR DOMAIN NAME REGISTRATION
An application for Domain Name registration must meet all the following criteria:
a. the Domain Name is not already registered;
b. it is not reserved or blocked by the .cisco Registry; or
c. it meets all .cisco Registry’s technical requirements.
(ii) technical requirements;
a. a maximum of 63 characters (after its conversion into the ASCII for IDNs);
b. use of characters selected from the list of supported characters as nominated by the .cisco Registry; and
c. any additional technical requirements as required by the .cisco Registry from time to time.
(iii) the Domain Name must be consistent with the mission and purposes of the .cisco TLD and consistent with the Domain Name registration policy of .cisco, and include but not be limited to:
a. product name;
b. service name;
c. marketing term;
d. geographic identifier; or
e. any relevant name or term as approved by Authorisation Provider or Authorised Person.
(iv) compliance with all requirements under the Registry Rules: the Registrant must comply with all provisions contained in the Registry Rules.
6. OBLIGATION OF REGISTRANTS
The Registrant must enter into an agreement with the Registrar for Domain Name registration under which the Registrant will be bound by the Registry Rules specified through the Registry-Registrar agreement as amended by the Registry from time to time.
The Registrant must also agree to be bound by the minimum requirements in clause 3.7.7 of ICANNʹs Registrar accreditation agreement.
The Registrant must represent and warrant that:
(i) it meets, and will continue to meet, the eligibility criteria at all times and must notify the Registrar if it ceases to meet such criteria;
(ii) the registration, renewal and use of the Domain Name does not violate any third party intellectual property rights, applicable laws or regulation;
(iii) it is entitled to register the Domain Name;
(iv) the registration and use of the Domain Name is made in good faith and for a lawful purpose;
(v) if the use of registered Domain Name is licensed to a third party,
a. the Registrant must have a licencing agreement with the licensee for the use of the Domain Name that is not less onerous than the obligation of the Registrant contained in the Registry Rules; and
b. where there is a breach of any provisions contained in the Registry Rules by the licensee of the Domain Name, Registry may revoke the Domain Name at its sole discretion.
(vi) it owns or otherwise has the right to provide all registration data (including personal information) for each Domain Name registered and provision of such registrant data complies with all applicable data protection laws and regulations; and
(vii) it has appropriate consent and licences to allow for publication of registration data in the WHOIS database.
7. REGISTRANT CONTACT INFORMATION
The Registrant must provide complete and accurate contact information of the Registrant (in accordance with clause 18.104.22.168 of the ICANN’s Registrar accreditation agreement), including but not limited to the following;
(i) if the Registrant is a company or organisation:
a. name of a company or organisation;
b. registered office and principal place of business; and
c. contact details of the Registrant including e-mail address and telephone number;
(ii) if the Registrant is a natural person:
a. full name of the Registrant;
b. address of the Registrant; and
c. contact details of the Registrant including e-mail address and telephone number.
All Registrant contact information must be complete and accurate. Any changes to such Registrant information must be promptly notified to the Registrar, and no later than one (1) month of such change.
8. REVOCATION OF DOMAIN NAMES
The Registrant acknowledges that the .cisco Registry may revoke a Domain Name immediately at its sole discretion:
(i) in the event the Registrant breaches any .cisco Registry Rules;
(ii) to comply with applicable law, court order, government rule or under any dispute resolution processes;
(iii) where such Domain Name is used for any of the following prohibited activities (Prohibited Activities):
b. intellectual property and privacy violations;
c. obscene speech or materials;
d. defamatory or abusive language;
e. forging headers, return addresses and internet protocol addresses;
f. illegal or unauthorised access to other computers or networks;
g. distribution of internet viruses, worms, Trojan horses or other destructive activities; and
h. any other illegal or prohibited activities as determined by the .cisco Registry.
(iv) in order to protect the integrity and stability of the domain name system and the .cisco Registry;
(v) where such Domain Name is placed under reserved names list at any time; and
(vi) where Registrant fails to make payment to the Registrar for registration, renewal or any other relevant services.
9. USE OF SECOND OR THIRD LEVEL IDNs
In addition to meeting all required criteria for registration of domain names above, an application for an IDN Domain Name must:
(i) comply with any additional registration policy on IDNs for each language;
(ii) meet all technical requirement for the applicable IDN;
(iii) comply with the IDN tables used by the .cisco Registry as amended from time to time; and
(iv) meet any other additional technical requirements as required by the .cisco Registry.
10. USE OF GEOGRAPHIC NAMES
All two-character labels and country and territory names will be initially reserved in accordance with specification 5 of the Registry Agreement.
Upon approval from ICANN and any other guidelines by applicable governments and ICANN’s Governmental Advisory Committee, the Registry may release the two-character labels and country and territory names in accordance with Cisco’s response to Question 22 Geographic Names.
11. RESERVED NAMES
The .cisco Registry may place certain names in its reserved list from time to time where:
(i) the .cisco Registry believes in its sole discretion that use of such names may pose a risk to the operational stability or integrity of the .cisco Registry;
(ii) in accordance with ICANN’s specifications contained in the Registry Agreement, guidelines or recommendations;
(iii) there is a risk of trademark infringement or where the name otherwise may cause confusion taking into consideration the mission and purpose of the TLD; or
(iv) the .cisco Registry in its sole discretion decides certain names to be reserved for any reason.
12. ALLOCATION OF DOMAIN NAME
The .cisco Registry will register Domain Names on a first-come, first-served basis in accordance with the .cisco Registry Rules. The .cisco Registry does not provide pre-registration or reservation of Domain Names.
13. LIMITATION ON REGISTRATION ⁄ DOMAIN NAME LICENCES
There is no restriction on the number of Domain Names any Registrant may hold. The Registrant may further licence the use of the Domain Name to any third parties provided that the Registrant enters into an agreement with such third parties on the terms not less onerous than its obligations under the .cisco Registry Rules.
14. PROTECTION OF THIRD PARTY INTELLECTUAL PROPERTY RIGHTS
The .cisco Registry will implement all rights protection measures as required by ICANN in clause 2.8 of the Registry Agreement, including the use of the Uniform Rapid Suspension (URS) procedure, and Uniform Domain Name Dispute Resolution Policy (UDRP).
15. TERM OF REGISTRATION ⁄ RENEWAL
INITIAL TERM OF REGISTRATION:
A Domain Name can be registered for a period between one (1) to ten (10) years.
RENEWAL OF REGISTRATION:
(i) The term may be extended at any time for a period between one (1) to ten (10) years, provided that the total aggregate term of the Domain Name does not exceed ten (10) years at any time.
(ii) Upon change of sponsorship of the Domain Name from one Registrar to another, according to Part A of the ICANN Policy on Transfer of Registrations between Registrars, the term of registration of the registered Domain Name will be extended by one year, provided that the maximum term of registration at any time does not exceed ten (10) years.
(iii) The change of sponsorship of the registration of a Domain Name from one Registrar to another, accordingly to Part B of the ICANN Policy on Transfer of Registrations between Registrars will not result in the extension of the term of registration.
CANCELLATION OF REGISTRATION:
The Registrant may cancel a Domain Name registration at any time by submitting its request in writing with the Registrar.
Upon expiry of the Domain Name, the .cisco Registry will auto-renew the Domain Name for a one year term (1) year term unless the Registrant submits its intention not to renew the Domain Name.
The .cisco Registry will implement the business rules for the renewal of Domain Names documented in appendix 7 of the .com Registry Agreement.
16. TRANSFER OF DOMAIN NAMES BETWEEN REGISTRANTS
Any transfer of a Domain Name between Registrants must be approved by the Registry through the Registrar. The legal heirs of the Registrant or purchaser of the Registrant may request the transfer provided that they meet the eligibility criteria for registration under the .cisco TLD. If the Registrant becomes subject to insolvency or any other proceeding, the administrator may request the transfer. The transferee must provide appropriate documentation as required by the .cisco Registry to approve such transfer.
17. CHANGE OF REGISTRAR
If the agreement between the Registry and the Registrar is terminated and if the Registrar has not transferred its Domain Name portfolio to another Registrar, the Registry will notify affected Registrants. The Registrants must select a new Registrar within one (1) month following such notice from the .cisco Registry. If the Registrant fails to appoint a new Registrar within the timeframe set out above, the .cisco Registry may suspend the Domain Name.
If the Registrant wishes to change the Registrar, the Registrant must obtain the auth-info code from the Registrantʹs current Registrar, and request a transfer through the gaining Registrar in compliance with ICANNʹs Inter-Registrar transfer policy.
18. PRIVACY AND DATA PROTECTION
By registering a Domain Name, the registrant authorises the .cisco Registry to process personal information and other data required for the operation of the .cisco TLD. The .cisco Registry will only use the data for the operation of the .cisco Registry including but not limited to its internal use, communication with the Registrant, and provision of WHOIS look-up facility.
The .cisco Registry may only transfer the data to third parties:
(i) with the Registrant’s consent;
(ii) in order to comply with laws, regulations or orders by a competent public authority and any Alternative Dispute Resolution (ADR) providers; or
(iii) for a publicly available and searchable WHOIS look-up facility, in accordance with specification 4 of the Registry Agreement.
The .cisco Registry provides a publicly available and searchable WHOIS look up facility, where information about the Domain Nameʹs status (including creation and expiry dates), and registrant, administrative and the technical contact administering the Domain Name can be found, in accordance with specification 4 of the Registry Agreement.
In order to prevent misuse of the WHOIS look up facility, the .cisco Registry requires that any person submitting a WHOIS database query will be required to read and agree to the terms and conditions, which will provide that:
(i) the WHOIS database is provided for information purposes only; and
(ii) the user agrees not to use the WHOIS information to allow or enable the transmission of unsolicited commercial advertising or other communication via email or other methods to the Registrants.
20. PRICING ⁄ PAYMENT
The .cisco TLD does not charge a separate fee for the Registrar to register domain names, as the TLD is used only for the specified mission and purpose of .cisco TLD. Cisco shall bear the cost of operating the .cisco Registry.
The .cisco Registry will provide Registrars with 30 days’ notice of any price change for new registrations, and 180 days advance notice of any price change for renewals in accordance with clause 2.10 of the Registry Agreement.
21. DISPUTE RESOLUTION
The Registrant agrees to be bound by ICANN’s Dispute Resolution Policies in respect of all disputes in connection with the Domain Name.
22. COMPLIANCE WITH CONSENSUS AND TEMPORARY POLICIES
The Registrant agrees to be bound by all applicable consensus and temporary policies as required and mandated by ICANN.
Affiliate means in relation to a party any corporation or other business entity controlling, controlled by, or under common control of that party and for the purposes of this definition, a corporation or other business entity shall be deemed to control another corporation or business entity if it owns directly or indirectly:
(i) fifty percent (50%) or more of the voting securities or voting interest in any such corporation or other entity; or
(ii) fifty percent (50%) or more of the interest in the profit or income in the case of a business entity other than a corporation; or
(iii) in the case of a partnership, any other compatible interest equal to at least a fifty percent (50%) share in the general partner.
Domain Name means a domain name registered directly under the .cisco TLD or for which a request or application for registration has been filed with the Registry;
ICANN’s Dispute Policy means the dispute policy currently known as the Uniform Domain Name Dispute Resolution Policy (UDRP) issued and as may be updated from time to time by the Internet Corporation of Assigned Names and Number (ICANN) and the Uniform Rapid Suspension (URS) (see Specification 7 of the Registry Agreement).
Registrar means an ICANN accredited registrar which enters into and is in compliance with the registry-registrar agreement for the TLD, and which provides domain name registration services to Registrants;
Registry Agreement means the agreement between Cisco and ICANN;
Registry Rules mean:
(i) Registration terms and conditions agreed between the Registry and Registrant for registration of a Domain Name; and
(ii) Registration policies provided and amended by the Registry from time to time.
Registrant means a natural person, company or organisation who holds a Domain Name registration or who has requested or applied for the registration of a Domain Name.
29. Rights Protection Mechanisms
29.1. RIGHTS PROTECTION MECHANISMS
Cisco is firmly committed to the protection of Intellectual Property rights and to implementing the mandatory rights protection mechanisms contained in the Applicant Guidebook and detailed in Specification 7 of the Registry Agreement. Cisco recognizes that although the New gTLD program includes significant protections beyond those that were mandatory for a number of the current TLDs, a key motivator for Cisco’s selection of Neustar as its registry services provider is Neustar’s experience in successfully launching a number of TLDs with diverse rights protection mechanisms, including many the ones required in the Applicant Guidebook. More specifically, Cisco will implement the following rights protection mechanisms in accordance with the Applicant Guidebook as further described below:
- Trademark Clearinghouse: a one-stop shop so that trademark holders can protect their trademarks with a single registration.
- Sunrise and Trademark Claims processes for the TLD.
- Implementation of the Uniform Dispute Resolution Policy to address domain names that have been registered and used in bad faith in the TLD.
- Uniform Rapid Suspension: A quicker, more efficient and cheaper alternative to the Uniform Dispute Resolution Policy to deal with clear cut cases of cybersquatting.
- Implementation of a Thick WHOIS making it easier for rights holders to identify and locate infringing parties
A. TRADEMARK CLEARINGHOUSE INCLUDING SUNRISE AND TRADEMARK CLAIMS
The first mandatory rights protection mechanism (“RPM”) required to be implemented by each new gTLD Registry is support for, and interaction with, the trademark clearinghouse. The trademark clearinghouse is intended to serve as a central repository for information to be authenticated, stored and disseminated pertaining to the rights of trademark holders. The data maintained in the clearinghouse will support and facilitate other RPMs, including the mandatory Sunrise Period and Trademark Claims service. Although many of the details of how the trademark clearinghouse will interact with each registry operator and registrars, Cisco is actively monitoring the developments of the Implementation Assistance Group (“IAG”) designed to assist ICANN staff in firming up the rules and procedures associated with the policies and technical requirements for the trademark clearinghouse. In addition, Cisco’s back-end registry services provider is actively participating in the IAG to ensure that the protections afforded by the clearinghouse and associated RPMs are feasible and implementable.
Utilizing the trademark clearinghouse, all operators of new gTLDs must offer:
(i) a sunrise registration service for at least 30 days during the pre-launch phase giving eligible trademark owners an early opportunity to register second-level domains in new gTLDs; and
(ii) a trademark claims service for at least the first 60 days that second-level registrations are open. The trademark claim service is intended to provide clear noticeʺ to a potential registrant of the rights of a trademark owner whose trademark is registered in the clearinghouse.
Cisco’s back-end registry service provider, Neustar, has already implemented Sunrise and⁄or Trademark Claims programs for numerous TLDs including .biz, .us, .travel, .tel and .co and will implement the both of these services on behalf of Cisco for the .cisco registry.
NEUSTAR’S EXPERIENCE IN IMPLEMENTING SUNRISE AND TRADEMARK CLAIMS PROCESSES
In early 2002, Neustar became the first registry operator to launch a successful authenticated Sunrise process. This process permitted qualified trademark owners to pre-register their trademarks as domain names in the .us TLD space prior to the opening of the space to the general public. Unlike any other “Sunrise” plans implemented (or proposed before that time), Neustar validated the authenticity of Trademark applications and registrations with the United States Patent and Trademark Office (USPTO).
Subsequently, as the back-end registry operator for the .tel gTLD and the .co ccTLD, Neustar launched validated Sunrise programs employing processes. These programs are very similar to those that are to be employed by the Trademark Clearinghouse for new gTLDs.
Below is a high level overview of the implementation of the .co Sunrise period that demonstrates Neustar’s experience and ability to provide a Sunrise service and an overview of Neustar’s experience in implementing a Trademark Claims program to trademark owners for the launch of .BIZ. Neustar’s experience in each of these rights protection mechanisms will enable it to seamlessly provide these services in relation to .cisco as required by ICANN.
a) SUNRISE AND .CO
The Sunrise process for .co was divided into two sub-phases:
- Local Sunrise giving holders of eligible trademarks that have obtained registered status from the Colombian trademark office the opportunity apply for the .CO domain names corresponding with their marks
- Global Sunrise program giving holders of eligible registered trademarks of national effect, that have obtained a registered status in any country of the world the opportunity apply for the .CO domain names corresponding with their marks for a period of time before registration is open to the public at large.
Like the new gTLD process set forth in the Applicant Guidebook, trademark owners had to have their rights validated by a Clearinghouse provider prior to the registration being accepted by the Registry. The Clearinghouse used a defined process for checking the eligibility of the legal rights claimed as the basis of each Sunrise application using official national trademark databases and submitted documentary evidence.
Applicants and⁄or their designated agents had the option of interacting directly with the Clearinghouse to ensure their applications were accurate and complete prior to submitting them to the Registry pursuant to an optional “Pre-validation Process”. Whether or not an applicant was “pre-validated”, the applicant had to submit its corresponding domain name application through an accredited registrar. When the Applicant was pre-validated through the Clearinghouse, each was given an associated approval number that it had to supply the registry. If they were not pre-validated, applicants were required to submit the required trademark information through their registrar to the Registry.
As the registry level, Neustar, subsequently either delivered the:
- Approval number and domain name registration information to the Clearinghouse
- When there was no approval number, trademark information and the domain name registration information was provided to the Clearinghouse through EPP (as is currently required under the Applicant Guidebook).
Information was then used by the Clearinghouse as either further validation of those pre-validated applications, or initial validation of those that did not go through pre-validation. If the applicant was validated and their trademark matched the domain name applied-for, the Clearinghouse communicated that fact to the Registry via EPP.
When there was only one validated sunrise application, the application proceeded to registration when the .co launched. If there were multiple validated applications (recognizing that there could be multiple trademark owners sharing the same trademark), those were included in the .co Sunrise auction process.
Neustar tracked all of the information it received and the status of each application and posted that status on a secure Website to enable trademark owners to view the status of its Sunrise application.
Although the exact process for the Sunrise program and its interaction between the trademark owner, Registry, Registrar, and IP Clearinghouse is not completely defined in the Applicant Guidebook and is dependent on the current RFI issued by ICANN in its selection of a Trademark Clearinghouse provider, Neustar’s expertise in launching multiple Sunrise processes and its established software will implement a smooth and compliant Sunrise process for the new TLDs.
b) TRADEMARK CLAIMS SERVICE EXPERIENCE
With Neustar’s biz TLD launched in 2001, Neustar became the first TLD with a Trademark Claims service. Neustar developed the Trademark Claim Service by enabling companies to stake claims to domain names prior to the commencement of live .biz domain registrations.
During the Trademark Claim process, Neustar received over 80,000 Trademark Claims from entities around the world. Recognizing that multiple intellectual property owners could have trademark rights in a particular mark, multiple Trademark Claims for the same string were accepted. All applications were logged into a Trademark Claims database managed by Neustar.
The Trademark Claimant was required to provide various information about their trademark rights, including the:
- Particular trademark or service mark relied on for the trademark Claim
- Date a trademark application on the mark was filed, if any, on the string of the domain name
- Country where the mark was filed, if applicable
- Registration date, if applicable
- Class or classes of goods and services for which the trademark or service mark was registered
- Name of a contact person with whom to discuss the claimed trademark rights.
Once all Trademark Claims and domain name applications were collected, Neustar then compared the claims contained within the Trademark Claims database with its database of collected domain name applications (DNAs). In the event of a match between a Trademark Claim and a domain name application, an e-mail message was sent to the domain name applicant notifying the applicant of the existing Trademark Claim. The e-mail also stressed that if the applicant chose to continue the application process and was ultimately selected as the registrant, the applicant would be subject to Neustar’s dispute proceedings if challenged by the Trademark Claimant for that particular domain name.
The domain name applicant had the option to proceed with the application or cancel the application. Proceeding on an application meant that the applicant wanted to go forward and have the application proceed to registration despite having been notified of an existing Trademark Claim. By choosing to “cancel,” the applicant made a decision in light of an existing Trademark Claim notification to not proceed.
If the applicant did not respond to the e-mail notification from Neustar, or elected to cancel the application, the application was not processed. This resulted in making the applicant ineligible to register the actual domain name. If the applicant affirmatively elected to continue the application process after being notified of the claimant’s (or claimants’) alleged trademark rights to the desired domain name, Neustar processed the application.
This process is very similar to the one ultimately adopted by ICANN and incorporated in the latest version of the Applicant Guidebook. Although the collection of Trademark Claims for new gTLDs will be by the Trademark Clearinghouse, many of the aspects of Neustar’s Trademark Claims process in 2001 are similar to those in the Applicant Guidebook. This makes Neustar uniquely qualified to implement the new gTLD Trademark Claims process.
B. UNIFORM DISPUTE RESOLUTION POLICY (UDRP) AND UNIFORM RAPID SUSPENSION (URS)
Prior to joining Neustar, Mr. Neuman was a key contributor to the development of the Uniform Dispute Resolution Policy (“UDRP”) in 1998. This became the first “Consensus Policy” of ICANN and has been required to be implemented by all domain name registries since that time. The UDRP is intended as an alternative dispute resolution process to transfer domain names from those that have registered and used domain names in bad faith. Although there is not much of an active role that the domain name registry plays in the implementation of the UDRP, Neustar has closely monitored UDRP decisions that have involved the TLDs for which it supports and ensures that the decisions are implemented by the registrars supporting its TLDs. When alerted by trademark owners of failures to implement UDRP decisions by its registrars, Neustar either proactively implements the decisions itself or reminds the offending registrar of its obligations to implement the decision.
In response to complaints by trademark owners that the UDRP was too cost prohibitive and slow, and the fact that more than 70 percent of UDRP cases were “clear cut” cases of cybersquatting, ICANN adopted the IRT’s recommendation that all new gTLD registries be required, pursuant to their contracts with ICANN, to take part in a Uniform Rapid Suspension System (“URS”). The purpose of the URS is to provide a more cost effective and timely mechanism for brand owners than the UDRP to protect their trademarks and to promote consumer protection on the Internet.
The URS is not meant to address Questionable cases of alleged infringement (e.g., use of terms in a generic sense) or for anti-competitive purposes or denial of free speech, but rather for those cases in which there is no genuine contestable issue as to the infringement and abuse that is taking place.
Unlike the UDRP which requires little involvement of gTLD registries, the URS envisages much more of an active role at the registry-level. For example, rather than requiring the registrar to lock down a domain name subject to a UDRP dispute, it is the registry under the URS that must lock the domain within 24hours of receipt of the complaint from the URS Provider to restrict all changes to the registration data, including transfer and deletion of the domain names.
In addition, in the event of a determination in favor of the complainant, the registry is required to suspend the domain name. This suspension remains for the balance of the registration period and would not resolve the original website. Rather, the nameservers would be redirected to an informational web page provided by the URS Provider about the URS.
Additionally, the WHOIS reflects that the domain name will not be able to be transferred, deleted, or modified for the life of the registration. Finally, there is an option for a successful complainant to extend the registration period for one additional year at commercial rates. Cisco’s back end registry operator, Neustar, is fully aware of each of these requirements and will have the capability to implement these requirements for the new TLD’s.
In fact, during the IRT’s development of the URS, Neustar began examining the implications of the URS on its registry operations and provided the IRT with feedback on whether the recommendations from the IRT would be feasible for registries to implement.
Although there have been a few changes to the URS since the IRT recommendations, Neustar continued to participate in the development of the URS by providing comments to ICANN, many of which were adopted. As a result, Neustar is committed to supporting the URS for all of the registries that it provides back-end registry services.
C. IMPLEMENTATION OF THICK WHOIS
The .cisco registry will include a thick WHOIS database as required in Specification 4 of the Registry agreement. A thick WHOIS provides numerous advantages including a centralized location of registrant information, the ability to more easily manage and control the accuracy of data, and a consistent user experience.
D. POLICIES HANDLING COMPLAINTS REGARDING ABUSE
In addition the Rights Protection mechanisms addressed above, Cisco will implement a number of measures to handle complaints regarding the abusive registration of domain names in its TLD as described in .cisco‘s response to Question 28.
REGISTRY ACCEPTABLE USE POLICY
One of the key policies each new gTLD registry is the need to have is an Acceptable Use Policy that clearly delineates the types of activities that constitute “abuse” and the repercussions associated with an abusive domain name registration. The policy must be incorporated into the applicable Registry-Registrar Agreement and reserve the right for the registry to take the appropriate actions based on the type of abuse. This may include locking down the domain name preventing any changes to the contact and nameserver information associated with the domain name, placing the domain name “on hold” rendering the domain name non-resolvable, transferring to the domain name to another registrar, and⁄or in cases in which the domain name is associated with an existing law enforcement investigation, substituting name servers to collect information about the DNS queries to assist the investigation. .cisco’s Acceptable Use Policy, set forth in our response to Question 28, will include prohibitions on phishing, pharming, dissemination of malware, fast flux hosting, hacking, and child pornography. In addition, the policy will include the right of the registry to take action necessary to deny, cancel, suspend, lock, or transfer any registration in violation of the policy.
MONITORING FOR MALICIOUS ACTIVITY
.cisco is committed to ensuring that those domain names associated with abuse or malicious conduct in violation of the Acceptable Use Policy are dealt with in a timely and decisive manner. These include taking action against those domain names that are being used to threaten the stability and security of the TLD, or is part of a real-time investigation by law enforcement.
Once a complaint is received from a trusted source, third-party, or detected by the Registry, the Registry will use commercially reasonable efforts to verify the information in the complaint. If that information can be verified to the best of the ability of the Registry, the sponsoring registrar will be notified and be given 12 hours to investigate the activity and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the Registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), the Registry will place the domain on “ServerHold”. Although this action removes the domain name from the TLD zone, the domain name record still appears in the TLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved.
29.2 SAFEGUARDS AGAINST UNQUALIFIED REGISTRATIONS
Registration of domain names under the .cisco domain space will be made in accordance with the eligibility criteria as set out in the registration policy contained in Question 28. As a restricted registry, no unauthorized third parties and⁄or unqualified registrants will be able to register domain names under .cisco domain space.
29.3 RESOURCING PLANS
The rights protection mechanisms described in the response above involve a wide range of tasks, procedures, and systems. The responsibility for each mechanism varies based on the specific requirements. In general the development of applications such as sunrise and IP claims is the responsibility of the Engineering team, with guidance from the Product Management team. Customer Support and Legal play a critical role in enforcing certain policies such as the rapid suspension process. These teams have years of experience implementing these or similar processes.
The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:
- Development⁄Engineering – 19 employees
- Product Management- 4 employees
- Customer Support – 12 employees
The resources are more than adequate to support the rights protection mechanisms of the .cisco registry.
30(a). Security Policy: Summary of the security policy for the proposed registry
30.(a).1 SECURITY POLICIES
Cisco and our back-end operator, Neustar recognize the vital need to secure the systems and the integrity of the data in commercial solutions. The .cisco registry solution will leverage industry-best security practices including the consideration of physical, network, server, and application elements.
Neustarʹs approach to information security starts with comprehensive information security policies. These are based on the industry best practices for security including SANS (SysAdmin, Audit, Network, Security) Institute, NIST (National Institute of Standards and Technology), and CIS (Center for Internet Security). Policies are reviewed annually by Neustarʹs information security team.
The following is a summary of the security policies that will be used in the .cisco registry, including:
1. Summary of the security policies used in the registry operations
2. Description of independent security assessments
3. Description of security features that are appropriate for .cisco
4. List of commitments made to registrants regarding security levels
All of the security policies and levels described in this section are appropriate for the .cisco registry.
30.(a).2 SUMMARY OF SECURITY POLICIES
Neustar has developed a comprehensive Information Security Program in order to create effective administrative, technical, and physical safeguards for the protection of its information assets, and to comply with Neustarʹs obligations under applicable law, regulations, and contracts. This Program establishes Neustarʹs policies for accessing, collecting, storing, using, transmitting, and protecting electronic, paper, and other records containing sensitive information.
- The policies for internal users and our clients to ensure the safe, organized and fair use of information resources.
- The rights that can be expected with that use.
- The standards that must be met to effectively comply with policy.
- The responsibilities of the owners, maintainers, and users of Neustarʹs information resources.
- Rules and principles used at Neustar to approach information security issues.
The following policies are included in the Program:
1. Acceptable Use Policy
The Acceptable Use Policy provides the rules of behavior covering all Neustar Associates for using Neustar resources or accessing sensitive information.
2. Information Risk Management Policy
The Information Risk Management Policy describes the requirements for the on-going information security risk management program, including defining roles and responsibilities for conducting and evaluating risk assessments, assessments of technologies used to provide information security and monitoring procedures used to measure policy compliance.
3. Data Protection Policy
The Data Protection Policy provides the requirements for creating, storing, transmitting, disclosing, and disposing of sensitive information, including data classification and labeling requirements, the requirements for data retention. Encryption and related technologies such as digital certificates are also covered under this policy.
4. Third Party Policy
The Third Party Policy provides the requirements for handling service provider contracts, including specifically the vetting process, required contract reviews, and on-going monitoring of service providers for policy compliance.
5. Security Awareness and Training Policy
The Security Awareness and Training Policy provide the requirements for managing the on-going awareness and training program at Neustar. This includes awareness and training activities provided to all Neustar Associates.
6. Incident Response Policy
The Incident Response Policy provides the requirements for reacting to reports of potential security policy violations. This policy defines the necessary steps for identifying and reporting security incidents, remediation of problems, and conducting lessons learned post-mortem reviews in order to provide feedback on the effectiveness of this Program. Additionally, this policy contains the requirement for reporting data security breaches to the appropriate authorities and to the public, as required by law, contractual requirements, or regulatory bodies.
7. Physical and Environmental Controls Policy
The Physical and Environment Controls Policy provides the requirements for securely storing sensitive information and the supporting information technology equipment and infrastructure. This policy includes details on the storage of paper records as well as access to computer systems and equipment locations by authorized personnel and visitors.
Neustar supports the right to privacy, including the rights of individuals to control the dissemination and use of personal data that describes them, their personal choices, or life experiences. Neustar supports domestic and international laws and regulations that seek to protect the privacy rights of such individuals.
9. Identity and Access Management Policy
The Identity and Access Management Policy covers user accounts (login ID naming convention, assignment, authoritative source) as well as ID lifecycle (request, approval, creation, use, suspension, deletion, review), including provisions for system⁄application accounts, shared⁄group accounts, guest⁄public accounts, temporary⁄emergency accounts, administrative access, and remote access. This policy also includes the user password policy requirements.
10. Network Security Policy
The Network Security Policy covers aspects of Neustar network infrastructure and the technical controls in place to prevent and detect security policy violations.
11. Platform Security Policy
The Platform Security Policy covers the requirements for configuration management of servers, shared systems, applications, databases, middle-ware, and desktops and laptops owned or operated by Neustar Associates.
12. Mobile Device Security Policy
The Mobile Device Policy covers the requirements specific to mobile devices with information storage or processing capabilities. This policy includes laptop standards, as well as requirements for PDAs, mobile phones, digital cameras and music players, and any other removable device capable of transmitting, processing or storing information.
13. Vulnerability and Threat Management Policy
The Vulnerability and Threat Management Policy provides the requirements for patch management, vulnerability scanning, penetration testing, threat management (modeling and monitoring) and the appropriate ties to the Risk Management Policy.
14. Monitoring and Audit Policy
The Monitoring and Audit Policy covers the details regarding which types of computer events to record, how to maintain the logs, and the roles and responsibilities for how to review, monitor, and respond to log information. This policy also includes the requirements for backup, archival, reporting, forensics use, and retention of audit logs.
15. Project and System Development and Maintenance Policy
The System Development and Maintenance Policy covers the minimum security requirements for all software, application, and system development performed by or on behalf of Neustar and the minimum security requirements for maintaining information systems.
30.(a).3 INDEPENDENT ASSESSMENT REPORTS
Neustar IT Operations is subject to yearly Sarbanes-Oxley (SOX), Statement on Auditing Standards #70 (SAS70) and ISO audits. Testing of controls implemented by Neustar management in the areas of access to programs and data, change management and IT Operations are subject to testing by both internal and external SOX and SAS70 audit groups. Audit Findings are communicated to process owners, Quality Management Group and Executive Management. Actions are taken to make process adjustments where required and remediation of issues is monitored by internal audit and QM groups.
External Penetration Test is conducted by a third party on a yearly basis. As authorized by Neustar, the third party performs an external Penetration Test to review potential security weaknesses of network devices and hosts and demonstrate the impact to the environment. The assessment is conducted remotely from the Internet with testing divided into four phases:
- A network survey is performed in order to gain a better knowledge of the network that was being tested
- Vulnerability scanning is initiated with all the hosts that are discovered in the previous phase
- Identification of key systems for further exploitation is conducted
- Exploitation of the identified systems is attempted.
Each phase of the audit is supported by detailed documentation of audit procedures and results. Identified vulnerabilities are classified as high, medium and low risk to facilitate managementʹs prioritization of remediation efforts. Tactical and strategic recommendations are provided to management supported by reference to industry best practices.
30.(a).4 AUGMENTED SECURITY LEVELS AND CAPABILITIES
There are no increased security levels specific for .cisco. However, Neustar will provide the same high level of security provided across all of the registries it manages.
A key to Neustarʹs Operational success is Neustarʹs highly structured operations practices. The standards and governance of these processes:
- Include annual independent review of information security practices
- Include annual external penetration tests by a third party
- Conform to the ISO 9001 standard (Part of Neustarʹs ISO-based Quality Management System)
- Are aligned to Information Technology Infrastructure Library (ITIL) and CoBIT best practices
- Are aligned with all aspects of ISO IEC 17799
- Are in compliance with Sarbanes-Oxley (SOX) requirements (audited annually)
- Are focused on continuous process improvement (metrics driven with product scorecards reviewed monthly).
A summary view to Neustarʹs security policy in alignment with ISO 17799 can be found in section 30.(a).5 below.
30.(a).5 COMMITMENTS AND SECURITY LEVELS
The .cisco registry commits to high security levels that are consistent with the needs of the TLD. These commitments include:
Compliance with High Security Standards
- Security procedures and practices that are in alignment with ISO 17799
- Annual SOC 2 Audits on all critical registry systems
- Annual third Party Penetration Tests
- Annual Sarbanes Oxley Audits
Highly Developed and Document Security Policies
- Compliance with all provisions described in section 30.(b) and in the attached security policy document
- Resources necessary for providing information security
- Fully documented security policies
- Annual security training for all operations personnel
High Levels of Registry Security
- Multiple redundant data centers
- High Availability Design
- Architecture that includes multiple layers of security
- Diversified firewall and networking hardware vendors
- Multi-factor authentication for accessing registry systems
- Physical security access controls
- A 24x7 manned Network Operations Center that monitors all systems and applications
- A 24x7 manned Security Operations Center that monitors and mitigates DDoS attacks
- DDoS mitigation using traffic scrubbing technologies