Application Preview

Application number: 1-1876-7694 for HLT Stakis IP Limited

Generated on 11 06 2012


Applicant Information


1. Full legal name

HLT Stakis IP Limited

2. Address of the principal place of business


3. Phone number

+1 703 883 5743

4. Fax number

+1 703 883 6188

5. If applicable, website or URL


Primary Contact


6(a). Name

Mr. Matthew Serlin

6(b). Title

Vice President, Domain Management

6(c). Address


6(d). Phone Number

+1 208 685 1864

6(e). Fax Number

+1 208 389 5771

6(f). Email Address

[email protected]

Secondary Contact


7(a). Name

Mr. Steven Dustin Bomar

7(b). Title

VP, Demand Generation, Hilton Worldwide, Inc.

7(c). Address


7(d). Phone Number

+1 703 883 5246

7(e). Fax Number

+1 703 883 6188

7(f). Email Address

[email protected]

Proof of Legal Establishment


8(a). Legal form of the Applicant

Private Limited Company

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

England and Wales

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

Not Available

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.

HLT Owned X-A Holding Limited

9(c). If the applying entity is a joint venture, list all joint venture partners.


Applicant Background


11(a). Name(s) and position(s) of all directors

Brian M. WilsonDirector
Elizabeth Jane RabinDirector
Hilton Corporate Director LLCDirector
Mark Jonathan WayDirector

11(b). Name(s) and position(s) of all officers and partners

Brian M. WilsonDirector
Elizabeth Jane RabinDirector
HLT Secretary LimitedSecretary
Mark Jonathan WayDirector

11(c). Name(s) and position(s) of all shareholders holding at least 15% of shares

HLT Owned X-A Holding LimitedNot Applicable

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.

hilton

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.

Not Available

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.

Applicant has consulted with its registry service operator concerning any potential rendering or operational problems with the applied-for gTLD and have been assured there are no known or likely operational or rendering problems with the proposed string.

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


Mission/Purpose


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

Every day, HLT Stakis IP Limited (“HLT”) and its Affiliate Hilton Worldwide Inc. (collectively, “Hilton”) strive to be the preeminent global hospitality company, which means being the first choice of our guests, our hotel owners, and our employees. Combined, Hilton’s ten world-class hotel brands comprise more than 3,800 hotels and time share properties, with 630,000 rooms in 88 countries around the world. Hilton is the fastest growing major hotel company – we’ve added more than 950 hotels since June 2007 and one in six of all hotel rooms being built in Europe today carries a Hilton brand. Our business is becoming even more global – the majority of our rooms under construction are outside the United States. Over 30 million people belong to Hilton’s loyalty program, making it one of the largest brand-loyalty programs in the world. Hilton continues to expand to reach more people across the world; we recently announced partnerships with The Global Soap Project, Good360, Global Kids, and the Sundance Institute as a part of our global corporate responsibility platform, and we led corporate fundraising initiatives to support humanitarian and educational efforts in Japan, East Africa, Turkey, and Thailand through GlobalGiving.org and DonorsChoose.org.

Hilton has always been an innovator, whether as a brick and mortar hospitality brand or an internet brand. In 1995, Hilton became one of the first major hospitality companies to introduce a website allowing guests to book hotel rooms securely without picking up a phone or meeting with a travel agent. Hilton’s online presence and innovation has not stopped since. In fact, Hilton recently announced a new online venture owned by six of the world’s leading hotel companies, Roomkey.com, which will provide consumers with simplicity, transparency, and breadth of choice in booking hotel rooms directly from the companies themselves, rather than through a third-part intermediary.

Through the principal Hilton website, which is associated with the hilton.com domain name, consumers and Internet users can locate and book accommodations and meeting space, check their HHonors point balances and redeem rewards, and obtain travel guides for many destinations. In the past eighteen years, the hilton.com website has received more than 1.2 billion unique visitors.

We have invested significant resources in protecting the Hilton® mark, which is the subject of almost 700 trademark registrations in most of the countries of the world. Collectively, Hilton owns almost 3000 trademark registrations in nearly every country in the world for our hotel brands and related services. In addition, we have registered more than 2,495 second-level domain names that contain or consist of the Hilton mark, although many are defensive registrations against cybersquatting that now resolve to hilton.com.

As the internet evolves, so does Hilton. Continuing our history of innovation, the mission of the .hilton registry is to provide guests with a more secure and authentic experience when searching for and booking accommodations; to protect, strengthen and expand the famous Hilton brand; and to promote Hilton by expanding our online global footprint as we expand our physical one.

We anticipate that consumers will come to recognize and rely upon the .hilton TLD as a sign of authenticity that the .hilton website that they use to obtain information about and to book accommodations at any of the properties in the Hilton portfolio, is created by and associated with us – the Hilton brand that they know and trust. We await the opportunity to use the .hilton TLD to enhance our consumers’ trust in their online interactions with all Hilton branded properties and to assist us in fulfilling our brand promise.

18(b). How proposed gTLD will benefit registrants, Internet users, and others

We expect that the proposed .hilton gTLD will benefit Internet users and others if we are able to provide consumers with a secure and authentic experience when searching for and booking accommodations online. We anticipate that HLT and its Affiliates will be the only registrants and users of second-level names in the .hilton gTLD registry. 

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

The goals of the proposed .hilton registry are to provide Internet users and consumers who use our hilton.com website with a trustworthy and secure online experience, to protect the famous Hilton brand, and to promote Hilton.

Hilton is the leading global hospitality company, spanning the lodging sector from luxurious full-service hotels and resorts to extended-stay suites and mid-priced hotels. For 93 years, Hilton has offered business and leisure travelers the finest in accommodations, service, amenities and value. The company is dedicated to continuing its tradition of providing exceptional guest experiences across its global brands. Its brands are comprised of more than 3,800 hotels and timeshare properties, with 630,000 rooms in 88 countries and include Waldorf Astoria Hotels & Resorts, Conrad Hotels & Resorts, Hilton Hotels & Resorts, DoubleTree by Hilton, Embassy Suites Hotels, Hilton Garden Inn, Hampton Hotels, Homewood Suites by Hilton, Home2 Suites by Hilton and Hilton Grand Vacations. The company also manages the world-class guest reward program Hilton HHonors®. For more information about the company, visit www.hiltonworldwide.com.
In fact, Hilton and all properties in its global portfolio achieved ISO 9001:2008 Certification for Quality Management and ISO 14001:2004 Certification for Environment Management, which is one of the largest ever volume certifications of commercial buildups across any industry.

Additionally, Hilton has received a number of awards attesting to our reputation and the importance we place on offering the highest quality services. Such awards include “Top 50 Organizations for Multicultural Business Opportunities,” “Top 50 Corporations for Supplier Diversity,” “People’s Choice for Sales & Customer Service,” “Best of the Best 2010 - Top Hospitality Companies,” “Hotel Company of the Year,” and, among many others, “Favorite Customer Service in Leisure and Tourism.”

The service levels and reputation of our proposed .hilton TLD will be commensurate with everything that our guests and the general public have come to expect from the Hilton brand. We anticipate that our .hilton TLD will provide another platform through which we can actualize our corporate mission of being the preeminent global hospitality company - the first choice of guests, team members, and owners alike.

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

We anticipate that our proposed .hilton gTLD has the potential to add competition to the current space if Internet users and consumers come to recognize and rely upon the .hilton TLD as a sign of authenticity that a .hilton website is associated with, created by, and controlled by us, and the greater security that may come with this authenticity. Our proposed .hilton gTLD will be differentiated from the current space because there are no .brand registries operated by the brand owner – let alone a .brand registry in the hospitality industry. We look forward to the opportunity to use a .hilton gTLD to build a unique platform for all of our brands. In time, we hope that the opportunity to operate a .hilton gTLD registry will create a foundation on which we can create further innovations designed to enhance the authenticity, security, and safety of consumers who wish to search for and book accommodations at a Hilton-portfolio property.

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

Hilton’s guests, Hilton HHonors members, and the general public expect that they can trust the principal Hilton website (located at www.hilton.com) to locate and book accommodations and meeting space, to check their HHonors points and redeem rewards, and to obtain travel guides for many destinations. Having the option to operate a .hilton gTLD registry will allow us to provide consumers with easier, more intuitive access to all Hilton services. In addition, we are hopeful that a .hilton registry will give us the opportunity to enhance for Internet users the reliability, trustworthiness, and security of their online interactions with us. We anticipate that the proposed .hilton gTLD will enhance our flexibility to transform and extend our online presence globally to reflect the changing needs of our guests and the traveling public.

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

We intend to implement a .hilton Domain Name Policy (the “.hilton Policy”) for the registration and use of .hilton domain names. We expect to update and revise the .hilton Policy to correspond with HLT’s business interests as well as ICANN Consensus Policy and Temporary Policy developments. The .hilton Policy will encompass eligibility requirements to register, use, or control domain name registrations in the .hilton gTLD; naming criteria; and permitted use criteria.

As a threshold matter, only HLT and its Affiliates will be eligible to register, use or control second-level domain names in the .hilton registry.

All .hilton domain names will be verified to ensure that they comply with the naming criteria of the .hilton registry. More specifically, except to the extent that ICANN otherwise expressly authorizes in writing, .hilton domain names shall comply with the following requirements:

- The label “EXAMPLE” will be reserved at the second level and at all other levels within the TLD at which we make registrations.
- All second-level .hilton domain names must be at least three characters long, unless we reach a specific agreement with a government and country-code manager to register and use a two-character label or our proposal to allow registration and use of such names based on implementation of measures to avoid confusion with the corresponding country codes is approved. No .hilton domain name may be longer than 63 characters.
- All .hilton domain names shall consist only of the letters a - z, the digits 0-9, and a hyphen.
- No .hilton domain name can start or end with a hyphen, but must start and end with an alphanumeric character.
- .hilton domain names shall not include hyphens in the third and fourth position unless they represent valid internationalized domain names in their ASCII encoding (tagging).
- .hilton domain names shall not be country and territory names contained in the internationally recognized lists set forth in Specification 5 to the New gTLD Registry Agreement, unless Hilton reaches agreement with the applicable government(s) or pursuant to review and approval by ICANN’s Governmental Advisory Committee and ICANN.
- .hilton domain names shall not be ICANN-reserved strings.

Hilton will require that the WHOIS data for all .hilton domain names is accurate and complete.
Internationalized Domain Names (IDN) may be supported at the second level.
All .hilton domain names shall be used solely for purposes that are, in Hilton’s judgment and discretion, consistent with its mission statement and core values. .hilton domains may not be used to knowingly infringe, violate, or misappropriate the intellectual property rights of any third party.

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.

We strive to deliver outstanding products, services, and experiences everywhere we do business, including online. We value our guests’ business and their loyalty, and we recognize that privacy is an important issue to guests and potential guests who interact with us online.
HLT, the operator of the .hilton registry, is a company organized in England and Wales, and will comply with all applicable data collection and privacy laws. Moreover, Hilton intends to fully comply with the Personal Data obligations outlined in Section 2.17 of the new gTLD Registry Agreement.

Also, describe whether and in what ways outreach and communications will help to achieve your projected benefits.

Hilton anticipates that it will actively pursue an outreach and communications campaign commensurate with the objectives, standards and policies described in this gTLD application and consistent with a .brand TLD where the registry operator and its Affiliates are the only registrants and users of domain names. Such outreach and communications may be directed to Hilton’s guests, business partners and the general public.


18(c). Describe operating rules to eliminate or minimize social costs or financial resource costs, various types of consumer vulnerabilities.

We anticipate that our operation of a TLD registry that only reflects the most recognized name in the hospitality industry is unlikely to have any social costs and negative consequences⁄costs imposed on consumers. We expect that our decision to operate the .hilton TLD registry on a single-registrant, single-user model should eliminate or minimize any social costs and negative consequences⁄costs imposed on consumers that may arise. 

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

Multiple applications for a particular domain name will not be received because HLT and its Affiliates will be the only registrants of domain names in the .hilton registry and, accordingly, conflict between competing applications for a particular domain name will not occur.

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

As HLT and its Affiliates will be the only registrants of domain names in the .hilton registry, we do not intend to implement any cost benefits for registrants.

iii. Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.

HLT and its Affiliates will be the only registrants of domain names in the .hilton registry. Accordingly, we do not intend to make contractual commitments to registrants regarding length of registration or price escalations. HLT will fully comply with Section 2.10 of the new gTLD Registry Agreement.

Community-based Designation


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

No

20(a). Provide the name and full description of the community that the applicant is committing to serve.


20(b). Explain the applicant's relationship to the community identified in 20(a).


20(c). Provide a description of the community-based purpose of the applied-for gTLD.


20(d). Explain the relationship between the applied-for gTLD string and the community identified in 20(a).


20(e). Provide a description of the applicant's intended registration policies in support of the community-based purpose of the applied-for gTLD.


20(f). Attach any written endorsements from institutions/groups representative of the community identified in 20(a).

Not Available

Geographic Names


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

No

Protection of Geographic Names


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

HLT Stakis IP Limited (“HLT Stakis”) shall follow the advice of ICANN’s Governmental Advisory Committee and adhere to the requirements set forth in Specification 5 of the Registry Agreement by initially reserving from registration at no cost the country and territory names that appear on the following internationally recognized lists:

A. The short form (in English) of all country and territory names contained on the ISO 3166-1, as updated from time to time, including the European Union;
B. The United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardization of Geographical Names, Part III Names and Countries of the World; and
C. The list of United Nations member states in 6 official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names.

HLT Stakis is working with its technical service provider, Neustar, Inc., to finalize the procedure for reserving these names. Neustar has agreed to, and is technically able to, implement such reservations.

Only HLT Stakis and its Affiliates will be permitted to register and use .hilton domain names. Accordingly, the country and territory names that will be reserved in the .hilton registry will not be available to third parties. HLT Stakis may, however, seek to release and register at the second level country and territory names for its own use upon agreement with the applicable government or governments, or pursuant to a proposal reviewed by the Governmental Advisory Committee and approved by ICANN.

Registry Services


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

23.1 Introduction 

HLT Stakis IP Limited (“HLT Stakis”) has elected to partner with Neustar, Inc to provide back-end services for the .hilton registry. In making this decision, HLT Stakis 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 .hilton 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. HLT Stakis will use Neustar’s Registry Services platform to deploy the .hilton registry, by providing the following Registry Services (none of these services are offered in a manner that is unique to .hilton:

- Registry-Registrar Shared Registration Service (SRS)
- Extensible Provisioning Protocol (EPP)
- Domain Name System (DNS)
- WHOIS
- DNSSEC
- Data Escrow
- Dissemination of Zone Files using Dynamic Updates
- Access to Bulk Zone Files
- Dynamic WHOIS Updates
- IPv6 Support
- Rights Protection Mechanisms
- Internationalized Domain Names (IDN). [Optional – should be deleted if not being offered].

The following is a description of each of the services.

SRS

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

EPP

The .hilton 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.

DNS

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

WHOIS

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

Standard WHOIS (Port 43)
Standard WHOIS (Web)
Searchable WHOIS (Web)

DNSSEC

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

Data Escrow

Data escrow will be performed in compliance with all ICANN requirements in conjunction with an approved data escrow provider. The data escrow service will:

- Protect against data loss
- Follow industry best practices
- Ensure easy, accurate, and timely retrieval and restore capability in the event of a hardware failure
- Minimizes the impact of software or business failure.

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

Dissemination of Zone Files using Dynamic Updates

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

Access to Bulk Zone Files

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

Dynamic WHOIS Updates

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

IPv6 Support

The .hilton 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 of IPv6 is presented in the response to Question 36.

Required Rights Protection Mechanisms

HLT Stakis will provide all ICANN required Rights Mechanisms, including:

- Trademark Claims Service
- Trademark Post-Delegation Dispute Resolution Procedure (PDDRP)
- Registration Restriction Dispute Resolution Procedure (RRDRP)
- UDRP
- URS
- Sunrise service.

More information is presented in the response to Question 29.

Internationalized Domain Names (IDN)

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

23.3 Unique Services

HLT Stakis will not be offering services that are unique to .hilton.

23.4 Security or Stability Concerns

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


Demonstration of Technical & Operational Capability


24. Shared Registration System (SRS) Performance

24.1 Introduction

HLT Stakis IP Limited (“HLT Stakis”) has partnered with Neustar, Inc, an experienced TLD registry operator, for the operation of the .hilton Registry. HLT Stakis 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 criteria established by ICANN.

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

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

24.2 The Plan for Operation of a Robust and Reliable SRS

High-level SRS System Description

The SRS to be used for .hilton 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, HLT Stakis is mitigating the significant risks and costs associated with the development of a new system. Highlights of the SRS include:

- State-of-the-art, production proven multi-layer design
- Ability to rapidly and easily scale from low to high volume as a TLD grows
- Fully redundant architecture at two sites
- Support for IDN registrations in compliance with all standards
- Use by over 300 Registrars
- EPP connectivity over IPv6
- Performance being measured using 100% of all production transactions (not sampling).

SRS Systems, Software, Hardware, and Interoperability

The systems and software that the registry operates on are a critical element to providing a high quality of service. If the systems are of poor quality, if they are difficult to maintain and operate, or if the registry personnel are unfamiliar with them, the registry will be prone to outages. Neustar has a decade of experience operating registry infrastructure to extremely high service level requirements. The infrastructure is designed using best of breed systems and software. Much of the application software that performs registry-specific operations was developed by the current engineering team and a result the team is intimately familiar with its operations.

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

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

All interaction with the Registry is recorded in log files. Log files are generated at each layer of the system. These log files record at a minimum:

- The IP address of the client
- Timestamp
- Transaction Details
- Processing Time.

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

SRS Design

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

- Protocol Layer
- Business Policy Layer
- Database.

Each of the layers is described below.

Protocol Layer

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

The EPP servers authenticate against a series of security controls before granting service, as follows:

- The registrar’s host exchanges keys to initiates a TLS handshake session with the EPP server.
- The registrar’s host must provide credentials to determine proper access levels.
- The registrar’s IP address must be preregistered in the network firewalls and traffic-shapers.

Business Policy Layer

The Business Policy Layer is the “brain” of the registry system. Within this layer, the policy engine servers perform rules-based processing as defined through configurable attributes. This process takes individual transactions, applies various validation and policy rules, 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.

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

Figure 24-1 depicts the overall SRS architecture including network components.

Number of Servers

As depicted in the SRS architecture diagram 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 runs with dual pairs as do the databases. For the .hilton registry, the SRS will operate with 8 protocol servers and 6 policy engine servers. These expand horizontally as volume increases due to additional TLDs, increased load, and through organic growth. In addition to the SRS servers described above, there are multiple backend servers for services such as DNS and WHOIS. These are discussed in detail within those respective response sections.

Description of Interconnectivity with Other Registry Systems

The core SRS service interfaces with other external systems via Neustar’s external systems layer. The services that the SRS interfaces with include:

- WHOIS
- DNS
- Billing
- Data Warehouse (Reporting and Data Escrow).

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

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

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

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

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

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

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

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

Compliance with Specification 6 Section 1.2
The SRS implementation for .hilton 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.

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 .hilton Registry. The following section describes Neustar’s experience and its capabilities to meet the requirements in the new agreement.

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

Neustar’s ability to commit and meet such high performance standards is a direct result of its 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:

- Development⁄Engineering
- Database Administration
- Systems Administration
- Network Engineering.

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

The necessary resources will be pulled from the pool of operational resources described in detail in the response to Question 31. Neustar’s SRS implementation is very mature, and has been in production for over 10 years. As such, very little new development related to the SRS will be required for the implementation of the .hilton 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 .hilton registry.

25. Extensible Provisioning Protocol (EPP)

25.1 Introduction

HLT Stakis IP Limited’s (“HLT Stakis”) back-end registry operator, Neustar, has over 10 years of experience operating EPP based registries. It deployed one of the first EPP registries in 2001 with the launch of .biz. In 2004, .biz wasthe 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 broad experience to ensure HLT Stakis is provided with an unparalleled EPP-based registry. The following discussion explains the EPP interface that will be used for the .hilton 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 .hilton 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 excellent 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 Neustar’s ability to perform at these levels can be found in the .biz monthly progress reports found on the ICANN website.

EPP Toolkits

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

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

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

25.3 Proprietary EPP Extensions

The .hilton 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 .hilton 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 .hilton registry is attached in the document titled “EPP Schema.”

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

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

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

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

26. Whois

26.1 Introduction

HLT Stakis IP Limited (“HLT Stakis”) 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. .hilton’s back-end registry services provider, Neustar, has extensive experience providing ICANN and RFC-compliant WHOIS services for each of the TLDs that it operates – both as a Registry Operator for gTLDs and ccTLDs, and as a back-end registry services provider. As one of the first “thick” WHOIS registry operators in the gTLD space, Neustar’s WHOIS service has been designed from the ground up to display as much information as required by a TLD and to respond to a very stringent availability and performance requirement.

Some of the key features of .hilton’s solution include:

- Fully compliant with all relevant RFCs including 3912
- Production-proven, highly flexible, and scalable with a track record of 100% availability over the past 10 years
- Exceeds current and proposed performance specifications
- Supports dynamic updates with the capability of doing bulk updates
- Geographically distributed sites to provide greater stability and performance
- In addition, .hilton’s thick WHOIS solution also provides for additional search capabilities and mechanisms to mitigate potential forms of abuse as discussed below. (e.g., IDN, registrant data).

26.2 Software Components

The WHOIS architecture comprises the following components:

- An in-memory database local to each WHOIS node: To provide for the performance needs, the WHOIS data is served from an in-memory database indexed by searchable keys.
- Redundant servers: To provide for redundancy, the WHOIS updates are propagated to a cluster of WHOIS servers that maintain an independent copy of the database.
- Attack resistant: To ensure that the WHOIS system cannot be abused using malicious queries or DOS attacks, the WHOIS server is only allowed to query the local database and rate limits on queries based on IPs and IP ranges can be readily applied.
- Accuracy auditor: To ensure the accuracy of the information served by the WHOIS servers, a daily audit is done between the SRS information and the WHOIS responses for the domain names which are updated during the last 24-hour period. Any discrepancies are resolved proactively.
- Modular design: The WHOIS system allows for filtering and translation of data elements between the SRS and the WHOIS database to allow for customizations.
- Scalable architecture: The WHOIS system is scalable and has a very small footprint. Depending on the query volume, the deployment size can grow and shrink quickly.
- Flexible: It is flexible enough to accommodate thin, thick, or modified thick models and can accommodate any future ICANN policy, such as different information display levels based on user categorization.
- SRS master database: The SRS database is the main persistent store of the Registry information. The Update Agent computes what WHOIS updates need to be pushed out. A publish-subscribe mechanism then takes these incremental updates and pushes to all the WHOIS slaves that answer queries.

26.3 Compliance with RFC and Specifications 4 and 10

Neustar has been running thick-WHOIS Services for over 10+ years in full compliance with RFC 3912 and with Specifications 4 and 10 of the Registry Agreement. RFC 3912 is a simple text based protocol over TCP that describes the interaction between the server and client on port 43. Neustar built a home-grown solution for this service. It processes millions of WHOIS queries daily.

Table 26-1 attached describes Neustar’s compliance with Specifications 4 and 10.

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

26.4 High-level WHOIS System Description

26.4.1 WHOIS Service (port 43)

The WHOIS service is responsible for handling port 43 queries. Our WHOIS is optimized for speed using an in-memory database and master-slave architecture between the SRS and WHOIS slaves.

The WHOIS service also has built-in support for IDN domain names. If the domain name being queried is an IDN, the returned results include the language of the domain name, the domain name’s UTF-8 encoded representation along with the Unicode code page.

26.4.2 Web Page for WHOIS queries

In addition to the WHOIS Service on port 43, Neustar provides a web based WHOIS application (www.whois.hilton). 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
- Nameservers
- Registrant, Technical and Administrative Contacts
- Registrars

It also provides features not available on the port 43 service. These include:
1. Redemption Grace Period calculation: Based on the registry’s policy, domains in pendingDelete can be restorable or scheduled for release depending on the date⁄time the domain went into pendingDelete. For these domains, the web based WHOIS displays “Restorable” or “Scheduled for Release” to clearly show this additional status to the user.
2. Extensive support for international domain names (IDN)
3. Ability to perform WHOIS lookups on the actual Unicode IDN
4. Display of the actual Unicode IDN in addition to the ACE-encoded name
5. A Unicode to Punycode and Punycode to Unicode translator
6. An extensive FAQ
7. A list of upcoming domain deletions

26.5 IT and Infrastructure Resources

As described above the WHOIS architecture uses a workflow that decouples the update process from the SRS. This ensures SRS performance is not adversely affected by the load requirements of dynamic updates. It is also decoupled from the WHOIS lookup agent to ensure the WHOIS service is always available and performing well for users. Each of Neustar’s geographically diverse WHOIS sites use:

- Firewalls, to protect this sensitive data
- Dedicated servers for MQ Series, to ensure guaranteed delivery of WHOIS updates
- Packetshaper for source IP address-based bandwidth limiting
- Load balancers to distribute query load
- Multiple WHOIS servers for maximizing the performance of WHOIS service.

The WHOIS service uses HP BL 460C servers, each with 2 X Quad Core CPU and a 64GB of RAM. The existing infrastructure has 6 servers, but is designed to be easily scaled with additional servers should it be needed.

Figure 26-1 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% ≤ 60 minutes. Please note that Neustar’s current architecture is built towards the stricter SLAs (95% ≤ 15 minutes) of .BIZ. The vast majority of updates tend to happen within 2-3 minutes.

26.8 Provision for Searchable WHOIS Capabilities

Neustar will create a new web-based service to address the new search features based on requirements specified in Specification 4 Section 1.8. The application will enable users to search the WHOIS directory using any one or more of the following fields:

- Domain name
- Registrar ID
- Contacts and registrant’s name
- Contact and registrant’s postal address, including all the sub-fields described in EPP (e.g., street, city, state or province, etc.)
- 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.

Neustar will offer partial match capabilities, at least, on the following fields: domain name, contacts and registrant’s name, and contact and registrant’s postal address, including all the sub-fields described in EPP (e.g., street, city, state or province, etc.).
Neustar will also offer exact -match capabilities, at least, on the following fields: registrar id, name server name, and name server IP address (only applies to IP addresses stored by the registry, which are known as glue records)

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 applicable privacy laws and policies of the .hilton registry.

26.9 Resourcing Plans

As with the SRS, the development, customization, and on-going support of the WHOIS service is the responsibility of a combination of technical and operational teams. The primary groups responsible for managing the service include:

- Development⁄Engineering – 19 employees
- Database Administration – 10 employees
- Systems Administration – 24 employees
- Network Engineering – 5 employees

Additionally, if customization or modifications are required, the Product Management and Quality Assurance teams will also be involved. Finally, the Network Operations and Information Security play an important role in ensuring the systems involved are operating securely and reliably. The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. Neustar’s WHOIS implementation is very mature, and has been in production for over 10 years.
As such, very little new development will be required to support the implementation of the .hilton registry. The resources are more than adequate to support the WHOIS needs of all the TLDs operated by Neustar, including the .hilton registry.

27. Registration Life Cycle

27.1 Registration Life Cycle

Introduction

HLT Stakis IP Limited (“HLT Stakis”) will follow the lifecycle and business rules found in the majority of gTLDs today. Our back-end operator, Neustar, has over ten years of experience managing numerous TLDs that utilize standard and unique business rules and lifecycles. This section describes the business rules, registration states, and the overall domain lifecycle that will be used for the .hilton registry.

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 .hilton registry per the defined .hilton 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 .hilton 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 .hilton 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 .hilton registry.
- Hold – Removes the domain from the DNS zone.
- UpdateProhibted – Prevents the object from being modified by an Update command.
- TransferProhibted – Prevents the object from being transferred to another Registrar by the Transfer command.
- RenewProhibted – Prevents a domain from being renewed by a Renew command.
- DeleteProhibted – Prevents the object from being deleted by a Delete command.

The lifecycle of a domain begins with the registration of the domain. All registrations must follow the EPP standard, as well as the specific business rules described in the response to Question 18 above. Upon registration a domain will either be in an active or inactive state. Domains in an active state are delegated and have their delegation information published to the zone. Inactive domains either have no delegation information or their delegation information in not published in the zone. Following the initial registration of a domain, one of five actions may occur during its lifecycle:

- Domain may be updated
- Domain may be deleted, either within or after the add-grace period
- Domain may be renewed at anytime during the term
- Domain may be auto-renewed by the Registry
- Domain may be transferred to another registrar.

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

27.1.1 Registration States

Domain Lifecycle – Registration States

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

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

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

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

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

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

Pending Delete State
The Pending Delete State occurs when a Delete command has been sent to the Registry after the first 5 days (120 hours) of registration. The Pending Delete period is 35 days during which the first 30 days the name enters the Redemption Grace Period (RGP) and the last 5 days guarantee that the domain will be purged from the Registry Database and available to public pool for registration on a first-come, first-serve basis.

27.1.2 Typical Registration Lifecycle Activities

Domain Creation Process

The creation (registration) of domain names is the fundamental registry operation. All other operations are designed to support or complement a domain creation. The following steps occur when a domain is created.

1. Contact objects are created in the SRS database. The same contact object may be used for each contact type, or they may all be different. If the contacts already exist in the database this step may be skipped.
2. Nameservers are created in the SRS database. Nameservers are not required to complete the registration process; however any domain with less than 2 name servers will not be resolvable.
3. The domain is created using the each of the objects created in the previous steps. In addition, the term and any client statuses may be assigned at the time of creation.

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

Update Process

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

For example, the Update operation on a domain name will only allow the following attributes to be updated:

- Domain statuses
- Registrant ID
- Administrative Contact ID
- Billing Contact ID
- Technical Contact ID
- Nameservers
- AuthInfo
- Additional Registrar provided fields.

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

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

Transfer Process
The EPP Transfer command is used for several domain transfer related operations:

- Initiate a domain transfer
- Cancel a domain transfer
- Approve a domain transfer
- Reject a domain transfer.

To transfer a domain from one Registrar to another the following process is followed:
1. The gaining (new) Registrar submits a Transfer command, which includes the AuthInfo code of the domain name.
2. If the AuthInfo code is valid and the domain is not in a status that does not allow transfers, the domain is placed into pendingTransfer status
3. A poll message notifying the losing Registrar of the pending transfer is sent to the Registrar’s message queue
4. The domain remains in pendingTransfer status for up to 120 hours, or until the losing (current) Registrar Acks (approves) or Nack (rejects) the transfer request
5. If the losing Registrar has not Acked or Nacked the transfer request within the 120 hour timeframe, the Registry auto-approves the transfer
6. The requesting Registrar may cancel the original request up until the transfer has been completed.

A transfer adds an additional year to the term of the domain. In the event that a transfer will cause the domain to exceed the 10 year maximum term, the Registry will add a partial term up to the 10 year limit. Unlike with the Renew operation, the Registry will not reject a transfer operation.

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.

27.1.3 Applicable Time Elements

The following section explains the time elements that are involved.

Grace Periods

There are six grace periods:

- Add-Delete Grace Period (AGP)
- Renew-Delete Grace Period
- Transfer-Delete Grace Period
- Auto-Renew-Delete Grace Period
- Auto-Renew Grace Period
- Redemption Grace Period (RGP).

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

The following describes each of these grace periods in detail.

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

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

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

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

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

Redemption Grace Period
The RGP is a special grace period that enables Registrars to restore domains that have been inadvertently deleted but are still in pendingDelete status within the Redemption Grace Period. All domains enter the RGP except those deleted during the AGP.
The RGP period is 30 days, during which time the domain may be restored using the EPP RenewDomain command as described below. Following the 30-day RGP period, the domain will remain in pendingDelete status for an additional five days, during which time the domain may NOT be restored. The domain is released from the SRS at the end of the 5 day non-restore period. A restore fee applies and is detailed in the Billing Section. A renewal fee will be automatically applied for any domain past expiration.

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

27.2 State Diagram
Figure 27-1 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 27.1.1 for detail description of each of these states. The lines between the states represent triggers that transition a domain from one state to another.

The details of each trigger are described below:

- Create: Registry receives a create domain EPP command.
- WithNS: The domain has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
- WithOutNS: The domain has not met the minimum number of nameservers required by registry policy. The domain will not be in the DNS zone.
- Remove Nameservers: Domainʹs nameserver(s) is removed as part of an update domain EPP command. The total nameserver is below the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
- Add Nameservers: Nameserver(s) has been added to domain as part of an update domain EPP command. The total number of nameservers has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
- Delete: Registry receives a delete domain EPP command.
- DeleteAfterGrace: Domain deletion does not fall within the add grace period.
- DeleteWithinAddGrace: Domain deletion falls within add grace period.
- Restore: Domain is restored. Domain goes back to its original state prior to the delete command.
- Transfer: Transfer request EPP command is received.
- Transfer Approve⁄Cancel⁄Reject: Transfer requested is approved or cancel or rejected.
- TransferProhibited: The domain is in clientTransferProhibited and⁄or serverTranferProhibited status. This will cause the transfer request to fail. The domain goes back to its original state.
- DeleteProhibited: The domain is in clientDeleteProhibited and⁄or serverDeleteProhibited status. This will cause the delete command to fail. The domain goes back to its original state.

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

27.2.1 EPP RFC Consistency

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

27.3 Resources

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

The .hilton registry will be using standard lifecycle rules, and as such no customization is anticipated. However should modifications be required in the future, the necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:

Development⁄Engineering – 19 employees
Registry Product Management – 4 employees

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

28. Abuse Prevention and Mitigation

28.1 Abuse Prevention and Mitigation

Strong abuse prevention in a new gTLD is an important benefit to the Internet community. HLT Stakis and its back-end registry services provider, Neustar, agree that a registry should aim for the highest standards of technical and operational competence, but should also 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, and will leverage this experience to help HLT Stakis combat abusive and malicious domain activity within the new .hilton space.

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
- Spam
- Phishing
- Pharming
- Distribution of malware
- Fast flux hosting
- Botnets
- 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 a 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, HLT Stakis’ 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 HLT Stakis’ registry services provider for .hilton, 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. Neustar also believes that a strong program is essential because registrants have a reasonable expectation that they are in control of the data associated with their domains, especially the data’s 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. HLT Stakis will use in the .hilton TLD a documented process for taking the necessary action of removing a domain from the zone when its presence in the zone poses a threat to the security and stability of the infrastructure of the Internet or the registry.

Abuse Point of Contact
As required by the Registry Agreement, HLT Stakis will establish and publish on its principal .hilton website a single abuse point of contact responsible for addressing inquiries from law enforcement and the public related to malicious and abusive conduct. HLT Stakis will also provide such information to ICANN prior to the delegation of any domain names in the .hilton 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. HLT Stakis will keep this information accurate and up to date, and will provide updates to ICANN if and when changes are made. In addition, with respect to inquiries from ICANN-accredited registrars, the .hilton 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 to prevent any changes to the contact and nameserver information associated with the domain name, placing the domain name “on hold” to render 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.

HLT Stakis will adopt for its .hilton TLD an Acceptable Use Policy that clearly defines the types of activities that will not be permitted in .hilton and reserves is right to lock, cancel, transfer or otherwise suspend or take down domain names violating the Acceptable Use Policy and allow Stakis to share information with law enforcement as appropriate. Because there will be no resellers in .hilton and there will be no market in .hilton domains, opportunities for abuse and malicious conduct are inherently limited. Below is the HLT Stakis’ initial Acceptable Use Policy that it will use in connection with the .hilton registry.

It is important to note that registration and use of .hilton domains will be restricted to HLT Stakis and its Affiliates. Accordingly , the potential for abusive registrations and other activities that have a negative impact on Internet users is minimal. In the unlikely event that such abuse occurs, HLT Stakis and its registry service provider, Neustar, will implement the following policies and processes to manage such activities.

--.hilton Acceptable Use Policy--

This Acceptable Use Policy gives HLT Stakis the ability to quickly lock, cancel, transfer or take ownership of any .hilton 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 .hilton, 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 HLT Stakis 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 HLT Stakis or its partners. In all cases, HLT Stakis or its designees will alert its 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 .hilton’s own.
- Pharming: the redirection of Internet users to websites other than those the user intends to visit, usually through unauthorized changes to the Hosts file on a victim’s computer or DNS records in DNS servers.
- Dissemination of Malware: the intentional creation and distribution of ʺmaliciousʺ software designed to infiltrate a computer system without the owner’s consent, including, without limitation, computer viruses, worms, key loggers, and Trojans.
- Fast Flux Hosting: a technique used to shelter Phishing, Pharming and Malware sites and networks from detection and to frustrate methods employed to defend against such practices, whereby the IP address associated with fraudulent websites are changed rapidly so as to make the true location of the sites difficult to find.
- Botnetting: the development and use of a command, agent, motor, service, or software which is implemented: (1) to remotely control the computer or computer system of an Internet user without their knowledge or consent, (2) to generate direct denial of service (DDOS) attacks.
- Malicious Hacking: the attempt to gain unauthorized access (or exceed the level of authorized access) to a computer, information system, user account or profile, database, or security system.
- Child Pornography: the storage, publication, display and⁄or dissemination of pornographic materials depicting individuals under the age of majority in the relevant jurisdiction.

HLT Stakis 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, HLT Stakis 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 HLT Stakis 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 HLT Stakis or any registrar in connection with a domain name registration. HLT Stakis 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
HLT Stakis 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 .hilton, 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 HLT Stakis, HLT Stakis 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 HLT Stakis, 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 HLT Stakis 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), HLT Stakis will place the domain on “ServerHold”. This is unlikely to be necessary, as HLT Stakis will be using a single, gateway registrar with whom it has a contract reflecting these policies. Although this action removes the domain name from the .hilton zone, the domain name record still appears in the .hilton 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, HLT Stakis 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. HLT Stakis 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 HLT Stakis for rapid resolution of the request.

In the event such request involves any of the activities which can be validated by HLT Stakis 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), HLT Stakis will place the domain on “serverHold”.

Continued Hilton Anti-Abuse Activities
HLT Stakis’ Affiliate, Hilton Worldwide (collectively, “Hilton”), currently uses MarkMonitor’s daily brand protection services for nine of the Hilton-owned brands, and will likely continue to do so after the launch of the .hilton registry. Current services include website monitoring, enforcement, and monthly compliance reports.

MarkMonitor’s website monitoring addresses traffic diversion, affiliate abuse, partner abuse, and, among others, paid search abuse. MarkMonitor reports these abuses to Hilton in a monthly report and takes action against abusive websites upon Hilton’s approval. Such actions include sending cease and desist letters requesting content removal, website removal, and⁄or a domain transfer. MarkMonitor also provides quarterly reviews of Hilton-owned domains, which involves reviewing sites for compliance with set anti-abuse criteria.

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

In addition, if either HLT Stakis 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 Authentication of Registrant Information
As stated in its response to Question 18, it is anticipated that only HLT Stakis and its Affiliates (the “Eligible .hilton Registrants”) will be permitted to register and use .hilton domain names. Before any .hilton domain name is registered, HLT Stakis will confirm through certain procedures that all registrants are Eligible .hilton Registrants and that only Eligible .hilton Registrants are permitted to register .hilton domain names.

HLT Stakis will coordinate with its Affiliates to compile a list of the entities that are Eligible .hilton Registrants and the persons authorized to register .hilton domain names on their behalf. HLT Stakis will require all registrars that wish to enter into a Registry-Registrar Agreement to agree to abide by strict domain name registration guidelines. Each qualified registrar must validate certain contact information to determine if a potential registrant is an Eligible .hilton Registrant before proceeding with a .hilton registration.

Registrars may use a number of procedures for eligibility verification such as:
1. An automated authentication process to authenticate that the prospective registrant is an Eligible .hilton Registrant;
2. Registrar-conducted authentication of whether a prospective registrant’s e-mail address is included in a pre-approved registrant list;
3. Contacting HLT Stakis if the registrar is unable to verify that a prospective registrant is an Eligible .hilton Registrant; and
4. Requiring each prospective registrant to represent and warrant that it is an Eligible .hilton Registrant, that it will comply will all .hilton policies, and that neither the registration of the domain name nor its use infringes or will infringe the legal rights of third parties.

28.5 Measures to Promote Whois Accuracy
HLT Stakis will implement several measures to promote Whois accuracy. HLT Stakis will retain essential contact details for each .hilton domain name in a system that facilitates access to the domain contact information. HLT Stakis intends to implement internal checks and procedures so that Whois data is accurate and complete.

As noted above, HLT Stakis will authenticate that all registrants of .hilton domains are Eligible .hilton Registrants and that only Eligible .hilton Registrants register .hilton domains. Many of the procedures applicable to eligibility verification may also be applied to Whois accuracy.

HLT Stakis will, and its registrars will be contractually required to, periodically check the Whois records of a certain percentage of .hilton domains. More specifically, contact details and relevant .hilton registrant information will be verified, and such information shall be compared against previous Whois records and contact information. HLT Stakis anticipates that Whois records of approximately 25% of .hilton domains will be checked quarterly. If such checks disclose that Whois data is inaccurate, the registrant of the relevant .hilton domain name will be notified and provided with a reasonable period of time within which the inaccuracy must be corrected. A .hilton registrant’s failure to do so will affect its continued use of the .hilton domain in question.

HLT Stakis intends to comply with ICANN’s Whois policies and requirements and to require its registrars to do so. Although the restricted number of Eligible .hilton Registrants makes it quite unlikely that .hilton domains will be the subject of Whois Data Problem Reports, registrars of .hilton domains will be required to promptly and thoroughly respond to such reports. In addition, .hilton-accredited registrars must comply with the Whois Data Reminder Policy and may be requested to provide HLT Stakis with documentation of their compliance efforts.

28.6 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 .hilton registry.

29. Rights Protection Mechanisms

HLT Stakis IP Limited (“HLT Stakis”) is firmly committed to protecting intellectual property rights and to implementing the mandatory Rights Protection Mechanisms (“RPMs”) contained in the Applicant Guidebook and detailed in Specification 7 of the Registry Agreement. Indeed, as a “.brand” registry, intellectual property rights protection is a core objective of the .hilton registry. Neustar, which HLT Stakis has selected as the .hilton registry services provider, has meaningful experience in successfully launching a number of TLDs with diverse RPMs, including many of those required for new gTLDs.

As an initial matter, it is important to understand the context in which HLT Stakis will implement its RPMs. HLT Stakis plans to limit registration and use of .hilton domains to itself and its Affiliates. HLT Stakis believes that this significant restriction will also serve as a de facto RPM.

HLT Stakis will implement the following RPMs in accordance with the Applicant Guidebook as further described below:

- Pre-Authorization and Authentication of Eligible Registrants

- Trademark Clearinghouse: a centralized database to document, authenticate, and disseminate information about claimed trademark rights that is intended to make participation in new gTLD RPMs faster, easier and less expensive.

- Sunrise and Trademark Claims processes for the TLD.

- Uniform Dispute Resolution Policy (“UDRP”) to act against domain names that have been registered and used in bad faith in the TLD.

- Uniform Rapid Suspension System (“URS”): a faster, more efficient, and less expensive alternative to the UDRP to address clear cut cases of cybersquatting.

- Implementation of thick Whois to make it easier for rights holders to identify and locate infringing parties

- Trademark Post Delegation Dispute Resolution Procedure

A. Pre-Authorization and Authentication
As stated in its response to Question 18, it is anticipated that only HLT Stakis and its Affiliates (the “Eligible .hilton Registrants”) will be permitted to register and use .hilton domain names. Before any .hilton domain name is registered, HLT Stakis will confirm through certain procedures that all registrants are Eligible .hilton Registrants and that only Eligible .hilton Registrants are permitted to register .hilton domain names.

HLT Stakis will coordinate with its Affiliates to compile a list of the entities that are Eligible .hilton Registrants and the persons authorized to register .hilton domain names on their behalf. HLT Stakis will require all registrars that wish to enter into a Registry-
Registrar Agreement to agree to abide by strict domain name registration guidelines. Each qualified registrar must validate certain contact information to determine if a potential registrant is an Eligible .hilton Registrant before proceeding with a .hilton registration.

Registrars may use a variety of automated and manual procedures may be utilized for verification by the registrar as specified below:

1. An automated authentication process will authenticate that the prospective registrant is an Eligible .hilton Registrant;
2. Registrar-conducted authentication of whether a prospective registrant’s email address is on a list of authorized email addresses;
3. If authenticated, the prospective registrant will be allowed to submit and complete registrations;
4. If the prospective registrant cannot be verified by the registrar, the registrar will contact HLT Stakis to determine eligibility;
5. The prospective registrant must represent and warrant that neither the registration of the desired .hilton domain name, nor the manner in which the registration will be used, infringes the legal rights of third parties.

B. Trademark Clearinghouse Including Sunrise and Trademark Claims

HLT Stakis, in conjunction with its registry service provider, will interact with the Trademark Clearinghouse to support implementation of RPMs in .hilton. 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 Trademark Clearinghouse will support and facilitate other RPMs, including the mandatory Sunrise Period and Trademark Claims service.

HLT Stakis’ counsel participated in an monitored the Implementation Assistance Group, which ICANN convened to assist ICANN staff in implementing the specific processes to be supported by the Trademark Clearinghouse. Personnel from Neustar, the back-end registry services provider for .hilton, also participated in the IAG. Notwithstanding numerous active IAG participants, ICANN has disclosed virtually no details of how registry operators such as HLT Stakis and registry service providers such as Neustar will interact with the Trademark Clearinghouse. Accordingly, HLT Stakis is unable to provide the level of specificity in this response that it would have preferred to do.

Using the Trademark Clearinghouse, HLT Stakis will offer in the .hilton registry Sunrise and Trademark Claims processes. The sunrise registration service, which will be offered for at least 30 days during the pre-launch phase, will (i) allow eligible owners of qualified trademarks the opportunity to register second-level .hilton domains that are identical matches to their qualified trademarks; and (ii) provide notice to all trademark owners in the Trademark Clearinghouse if someone is seeking a Sunrise registration. The Trademark Claims service, which will be offered for at least the first 60 days after the .hilton registry launches to eligible registrants, will provide (i) “clear notice” to a potential registrant of the existence of an identical trademark in the Trademark Clearinghouse and the rights of a trademark owner show qualifying trademark rights have been documented with and authenticated by the Trademark Clearinghouse; and (ii) I that potential registrant proceeds to registration, provide “clear notice” to the owners of the trademarks about which the registrant received notice prior to registration.

HLT Stakis’ registry service provider for .hilton, Neustar, has already implemented Sunrise and⁄or Trademark Claims programs for numerous TLDs including .biz, .us, .travel, .tel and .co and will implement both of these services for the .hilton registry. HLT Stakis expects to benefit from Neustar’s prior experience.

HLT Stakis plans to limit registration and use of .hilton domains to itself and its Affiliates. These eligibility restrictions carry over to the Sunrise and Trademark Claims processes. In other words, only HLT Stakis and its Affiliates will be permitted to participate in the Sunrise process for the .hilton registry and they will be the only Claimants under the .hilton Trademark Claims process that are entitled to register domain names in the .hilton registry. Nonetheless, HLT Stakis intends to operate its Sunrise and Trademark Claims processes in full compliance with ICANN’s policies.

HLT Stakis’ proposed Sunrise and Trademark Claims service is currently anticipated to be introduced according to the following timetable:

Day One: Announcement of registry launch and publication of registry website with details of the Sunrise and Trademark Claim Service
Day 30: Sunrise process opens for 30 days on a first-come, first served basis. Once registrations are approved, they will be entered into the SRS and published in the .hilton thick Whois database.
Day 60-75: .hilton registry opens, domains applied for during Sunrise are registered, and the Trademark Claims process starts and runs for at least 60 days
Day 120-135: Trademark Claims process ends and normal operations continue.

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 before the .us space opened 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 processes. Those processes are very similar to the Sunrise process required in new gTLDs.

Neustar’s implementation of Sunrise in .co and its implementation of Trademark Claims in .biz demonstrates Neustar’s experience and ability in implementing a Sunrise and Trademark Claims processes very similar to those required in new gTLDs. Neustar’s experience in each of these rights protection mechanisms will enable it to seamlessly provide these services on behalf of .hilton as required by ICANN.

a) Sunrise and .co

The Sunrise process for .co was divided into two sub-phases:
- Local Sunrise that gave owners of eligible trademarks registered with the Colombian Trademark Office the opportunity to apply for the .CO domain names corresponding to their marks
- Global Sunrise program giving owners of eligible registered trademarks of national effect the opportunity to apply for the .CO domain names corresponding with their marks for a period of time before registration opened to the general public.

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

Applicants and⁄or their designated agents could pursue an optional “pre-validation process” and interact directly with the Clearinghouse to ensure their Sunrise applications were accurate and complete before submitting them to the Registry. All Sunrise applicants were required to submit their Sunrise applications through an accredited registrar. Pre-validated applicants were each given an approval number for submission to the Registry. Sunrise applicants that were not pre-validated were required to submit the trademark right documentation to the Registry via their registrar.

As the registry level, Neustar, subsequently either delivered the:

- Approval number and domain name registration information to the Clearinghouse; or
- If 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).

The .co Clearinghouse used the information either to further validate pre-validated applications to validate those applications that were not pre-validated. If the applicant was validated and their trademark matched the applied-for domain name, the Clearinghouse communicated that fact to the Registry via EPP.

If there was only one validated Sunrise application, that Sunrise application registered when the .co TLD launched. Multiple validated applications were included in the .co Sunrise auction process. Neustar tracked all information it received and each Sunrise application’s status. Neustar posted that status on a secure website so each trademark owner could view the status of its Sunrise application.

The Sunrise process for new gTLDs and the interaction among the trademark owner, registry, registrar, and Trademark Clearinghouse are not fully delineated in the Applicant Guidebook. Moreover, the process and interaction depend on the current RFI issued by ICANN in its selection of a Trademark Clearinghouse provider. Nonetheless, Neustar’s expertise in launching multiple Sunrise processes and its established software should result in a smooth and compliant Sunrise process for the new gTLDs.

b) Trademark Claims Service Experience

Neustar’s .biz TLD became the first TLD with a Trademark Claims service when it launched in 2001. Neustar’s .biz Trademark Claims Service allowed by allowing trademark owners to assert claims against .biz domain names that matched their trademarks before .biz launched to the general public.

During the .biz Trademark Claim process, Neustar received over 80,000 Trademark Claims from entities around the world. Because Neustar recognized that multiple intellectual property owners can have trademark rights in the same mark, Neustar accepted multiple Trademark Claims for the same .biz domain name. All Trademark Claims were logged into a Trademark Claims database managed by Neustar.

Every Trademark Claimant provided information about their trademark rights, including the:
- Trademark or service mark on which the Trademark Claim was based;
- Trademark application filing date and trademark registration issue date, if applicable;
- Country in which trademark registration, if any, issued;
- 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.

After Neustar collected all Trademark Claims and domain name applications, Neustar compared its database of all Trademark Claims against its database of all .biz domain name applications. If a domain name application matched a Trademark Claim, the domain name applicant received an e-mail message that notified it of the existing Trademark Claim. The e-mail also stressed that, if the applicant continued the process and became 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 could proceed with the application or cancel it. Proceeding meant that the applicant wanted to pursue the registration even though it had 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.

The application was not processed, making the applicant ineligible to register the domain name, if the applicant did not respond to Neustar’s e-mail notification or cancelled the application. If the applicant continued the application process after being notified of the claimant’s (or claimants’) alleged trademark rights in the applied-for domain name, Neustar processed the application.

Neustar’s Trademark Claims process for .biz is very similar to the Trademark Claims process incorporated in the latest version of the Applicant Guidebook, which makes Neustar uniquely qualified to implement the new gTLD Trademark Claims process.

C.Uniform Dispute Resolution Policy (UDRP) and Uniform Rapid Suspension (URS)

1. UDRP

The UDRP is ICANN’s first “Consensus Policy” and all gTLD registries are required to implement it. A domain name registry generally does not have an active role in UDRP implementation. However, Neustar monitors UDRP decisions that involve the TLDs for which it supports and ensures that the decisions are properly and timely implemented by registrars supporting its TLDs. When a trademark owner alerts Neustar to a registrar’s failure to implement a UDRP decision, Neustar either proactively implements the decisions itself or reminds the offending registrar of its obligations to implement the decision.

HLT Stakis is committed to protecting intellectual property rights in .hilton and values the UDRP. Nevertheless, HLT Stakis believes it is unlikely that .hilton domains will be the subject of UDRP proceedings because Eligible .hilton Registrants are unlikely to engage in bad faith registration and use. In the unlikely event that a UDRP proceeding is brought against a .hilton domain name and the even more unlikely event that a trademark owner prevails in that proceeding, cancellation of the disputed .hilton domain name is the only remedy because only HLT Stakis and its Affiliates can register and use .hilton domains.

2. URS

All new gTLD registries must take part in the Uniform Rapid Suspension System (“URS”). The URS is intended to provide a mechanism, more cost effective and timely than the UDRP, for brand owners to protect their trademarks and to promote consumer protection on the Internet. The URS is not meant to address questionable cases of alleged cybersquatting (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 cybersquatting and abuse that is taking place.

Unlike the UDRP, the URS envisages a much more active role for the registry. For example, the registry – not the registrar – must lock the disputed domain within 24 hours of receiving the complaint from the URS Provider in order to restrict all changes to the registration data, including transfer and deletion of the disputed domain names. If the URS Complainant prevails, the registry must suspend the domain name registration and keep it suspended until the domain name registration expires. During the suspension, the domain name’s nameservers are redirected to an informational web page provided by the URS Provider about the URS. A successful URS Complainant may extend the registration period (and the suspension) for an additional year at commercial rates. Additionally, the Whois for the domain name(s) must reflect that the domain name cannot be transferred, deleted, or modified for the life of the registration.

Neustar, HLT Stakis’ registry service provider, is committed to supporting the URS for the .hilton registry. HLT Stakis is fully aware of each of these requirements and will have the capability to implement these requirements for new gTLDs. HLT Stakis appreciates the importance of the URS process. However, HLT Stakis believes it is extremely unlikely that any .hilton domain will be the subject of a URS proceeding because only HLT Stakis and its Affiliates can register and use .hilton domain names, and it is extremely unlikely that .hilton registrants would engage in the conduct targeted by the URS.

D. Implementation of Thick WHOIS

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

E. Trademark Post Delegation Dispute Resolution Procedure (“Trademark PDDRP”)

The Trademark PDDRP is a mandatory administrative proceeding that is intended to address complaints by trademark owners that one or more of their marks have been infringed, and the trademark owner has been harmed by, the Registry Operator’s manner of operation or use of the TLD at issue. The Applicant Guidebook sets out the grounds for a Trademark PDDRP complaint at the top and second levels.

At the top level, a Trademark PDDRP Complainant must prove, by clear and convincing evidence, that “the registry operator’s affirmative conduct in its operation or use of its gTLD string that is identical or confusingly similar to the complainant’s mark, causes or materially contributes to the gTLD doing one of the following: (a) taking unfair advantage of the distinctive character or the reputation of the complainant’s mark; or (b) impairing the distinctive character or the reputation of the complainant’s mark; or (c) creating a likelihood of confusion with the complainant’s mark.”

At the second level, a Trademark PDDRP Complainant must prove, also by clear and convincing evidence, that “through the registry operator’s affirmative conduct (a) there is a substantial pattern of practice of specific bad faith intent by the registry operator to profit from the sale of trademark infringing domain names; and (b) the registry operator’s bad faith intent to profit from the systematic registration of domain names within the gTLD that are identical or confusingly similar to the complainant’s mark, which (i) takes unfair advantage of the distinctive character or the reputation of the complainant’s mark; or (ii) impairs the distinctive character or the reputation of the complainant’s mark; or (iii) creates a likelihood of confusion with the complainant’s mark.”

HLT Stakis will participate in any Trademark PDDRP complaints brought against it. However, HLT Stakis believes that the likelihood of any such complaints is low and the prospects for success of such complaints are even lower. This is true at the top level because the .hilton registry is a .brand registry and, as discussed in the Question 18 response, HLT Stakis’ Affiliates own over 700 trademark registrations worldwide for the famous HILTON mark. These extensive legitimate rights render a successful Trademark PDDRP top-level complaint against HLT Stakis virtually impossible. A second-level Trademark PDDRP complaint against HLT Stakis is equally likely to fail. HLT Stakis has no current intention of selling .hilton domains (which makes profiting from the sale of .hilton domains and associated bad faith intent to do so impossible). Moreover, as discussed above, HLT Stakis’ registration policy prohibits the use of a .hilton domain name in a way that knowingly infringes any third-party intellectual property rights.

F. Policies Handling Complaints Regarding Abuse

In addition to the RPMs described above, HLT Stakis will implement a number of measures that are described in its response to Q28 to handle complaints regarding the abusive registration of .hilton domain names. HLT Stakis does not anticipate abusive registration or malicious conduct in the .hilton registry because HLT Stakis plans that only itself and its Affiliates will register and use .hilton domains.
Registry Acceptable Use Policy

HLT Stakis’ Acceptable Use Policy for .hilton, set forth in the response to Question 28, will include prohibitions on phishing, pharming, dissemination of malware, fast flux hosting, hacking, and child pornography. HLT Stakis retains the right under its .hilton Acceptable Use Policy to take action necessary to deny, cancel, suspend, lock, or transfer any registration in violation of the policy.

Monitoring for Malicious Activity

HLT Stakis 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, which includes taking action against those domain names that are being used to threaten the stability and security of the .hilton 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 HLT Stakis, the registry will use best efforts to verify the information in the complaint. After that information is verified to the best of HLT Stakis’ ability, the sponsoring registrar will have 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 HLT Stakis to keep the name in the zone. If the registrar has not acted within the 12-hour period (i.e., is unresponsive to the request or refuses to take action), HLT Stakis will place the domain on “ServerHold”. Although this action would remove the domain name from the .hilton zone, the domain name record will still appear in the .hilton Whois database so that the name and entities can be investigated by law enforcement if circumstances warrant.

29.2 Resourcing Plans
The RPMs 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. The Engineering Team is primarily responsible for developing applications such as Sunrise and Trademark Claims, 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 RPMs of the .hilton registry.

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

HLT Stakis IP Limited (“HLT Stakis”) and its back-end operator, Neustar, recognize the vital need to secure the systems and the integrity of the data in commercial solutions. The .hilton registry solution will leverage industry-best security practices including the consideration of physical, network, server, and application elements. 

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

The following is a summary of the security policies that will be used in the .hilton 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 .hilton
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 .hilton registry.

30.(a).1 Summary of Security Policies

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

The Program defines:

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

The following policies are included in the Program:

1. Acceptable Use Policy

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

2. Information Risk Management Policy

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

3. Data Protection Policy

The Data Protection Policy provides the requirements for creating, storing, transmitting, disclosing, and disposing of sensitive information, including data classification and labeling requirements, the requirements for data retention. Encryption and related t
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.

8. Privacy Policy

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

9. Identity and Access Management Policy

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

10. Network Security Policy

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

11. Platform Security Policy

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

12. Mobile Device Security Policy

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

13. Vulnerability and Threat Management Policy

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

14. Monitoring and Audit Policy

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

15. Project and System Development and Maintenance Policy

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

30. (a).2 Independent Assessment Reports

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

External Penetration Test is conducted by a third party on a yearly basis. As authorized by Neustar, the third party performs an external Penetration Test to review potential security weaknesses of network devices and hosts and demonstrate the impact to the environment. The assessment is conducted remotely from the Internet with testing divided into four phases:

- A network survey is performed in order to gain a better knowledge of the network that was being tested
- Vulnerability scanning is initiated with all the hosts that are discovered in the previous phase
- Identification of key systems for further exploitation is conducted
- Exploitation of the identified systems is attempted.

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

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

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

A key to Neustar’s operational success is Neustar’s highly structured operations practices. The standards and governance of these processes:

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

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

30.(a).4 Commitments and Security Levels

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

Compliance with High Security Standards

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

Highly Developed and Document Security Policies

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

High Levels of Registry Security

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




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