ICANN New gTLD Application

New gTLD Application Submitted to ICANN by: A.C.D. LEC Association des Centres Distributeurs Edouard Leclerc

String: LECLERC

Originally Posted: 13 June 2012

Application ID: 1-1251-68491


Applicant Information


1. Full legal name

A.C.D. LEC Association des Centres Distributeurs Edouard Leclerc

2. Address of the principal place of business

26 quai Marcel Boyer
Ivry-sur-Seine 94200
FR

3. Phone number

+33 149 875 100

4. Fax number

+33 149 875 108

5. If applicable, website or URL

http:⁄⁄www.mouvement-leclerc.com

Primary Contact


6(a). Name

Ms. Sophie Boudon Le Goff

6(b). Title

Head of Legal Department

6(c). Address


6(d). Phone Number

+33 149 875 106

6(e). Fax Number

+33 149 875 108

6(f). Email Address

tas-leclerc@prodomaines.com

Secondary Contact


7(a). Name

Ms. Segolene Russel

7(b). Title

IP⁄IT lawyer

7(c). Address


7(d). Phone Number

+33 149 875 760

7(e). Fax Number

+33 149 875 108

7(f). Email Address

tas-leclerc@prodomaines.com

Proof of Legal Establishment


8(a). Legal form of the Applicant

French Association registered under the French law of 1901

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

- French law of July 1st 1901 regarding the association agreement
- Order of August 16th 1901 enacted for the execution of the French law of July 1st 1901 regarding the association agreement

URL (text in French) : 
http:⁄⁄www.legifrance.gouv.fr⁄affichTexte.do?cidTexte=JORFTEXT000000497458&fastPos=1&fastReqId=1761169443&categorieLien=cid&oldAction=rechTexte

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

Attachments are not displayed on this form.

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.


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

Alain THIBAULTAdministrator
André JAUDAdministrator
Bernard BORNANCINSecretary
Camillo DE BERARDINISAdministrator
Gérard VILAINEAdministrator
Michel BUCHARDVice Chairman
Michel CHAUFOURNAISVice Chairman
Michel-Edouard LECLERCChairman
Philippe COUSYNAdministrator
Vincent de GUITARRETreasurer

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

Stéphane DE PRUNELEGeneral Secretary

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


11(d). For an applying entity that does not have directors, officers, partners, or shareholders: Name(s) and position(s) of all individuals having legal or executive responsibility


Applied-for gTLD string


13. Provide the applied-for gTLD string. If an IDN, provide the U-label.

LECLERC

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.

Attachments are not displayed on this form.

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.

According to the applicant, there are no known operational problems concerning the TLD (Top-Level Domain). The string is composed of ASCII characters already used in the existing TLDs.
The .LECLERC registry (and its Registry Back-end Service Provider, AFNIC) ensured that there are no known operational or rendering problems concerning the applied-for gTLD string ʺ.LECLERCʺ.
Since the gTLD string ʺ.LECLERCʺ is an ASCII-only string, it is safe to assume that, just like with existing ASCII-only TLD strings like .com, .net or .de, no operational or rendering problems may be expected. In particular, the name consists only of ASCII characters that are already used for existing top level domains; all the characters in the name are even used in the leftmost position of existing TLD labels. In order to confirm this, .LECLERC Registry Back-end Service Provider has conducted a thorough research regarding whether operational or rendering issues occurred for any existing ASCII-only top level domain in the past. The results of this research confirmed the assumption.
This means that bi-directional issues (like the ones described at http:⁄⁄stupid.domain.name⁄node⁄683) will not occur, also since the TLD string does not contain digits (which behaviour in bi-directional contexts can lead to rendering issues).
As the registry supports right-to-left scripts on the second level, the respective IDN tables were carefully crafted according to IDNA2008 standards to ensure that no rendering issues occur left or right of the dot (ʺ.ʺ) character separating the top and second domain name labels (which are the only labels under the registryʹs control).

Moreover, the gTLD string exclusively uses characters from a single alphabet, does not contain digits or hyphens, and it contains characters that are not subject to homograph issues, which means there is no potential for confusion with regard to the rendering of other TLD strings.

Finally, the .LECLERC Registry Back-end Service Provider set up a testing environment for the .LECLERC TLD using the Leclerc target Registration System, including an EPP SRS, Whois and DNS servers, in order to conduct a series of tests involving typical use cases (like web site operation and e-mail messaging) for a TLD. The tests revealed no operational or rendering issues with any popular software (web browsers, e-mail clients) or operating systems.

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.

The NewgTLD .LECLERC will have multiple goals:
* Represent and place the applicant’s leading and most distinctive brand (LECLERC) at the highest level of the DNS hierarchy
* Provide the community and its members (see question 20) with recognizable and trustworthy identification on the Internet. The TLD will increase the visibility of official communication of the brand.The “E.LECLERC Movement” is composed of independent members. Its current communication varies according to the members. There is no policy of truly shared and applied registration. The .LECLERC domain will have a strong federative role and will allow the creation of new international and “corporate” communication. A.C.D. Lec goes even farther in this sense in choosing the model of single registrant for .LECLERC in order to harmonize the registration of domain names, to build close relationships with the stronger members, provide more visible communication, and achieve of these goals by knowing the members using .LECLERC. The eligibility conditions and the criteria for the registration policies will be detailed in questions 18 and 20.
* Provide a secure applicant-controlled online environment to the community members and end users interested in the assets, services and activities of A.C.D. Lec. Among its services, the applicant has a bank activity known as Edel. The NewgTLD .LECLERC will be more effective in combating phishing attempts and will ensure a secure relationship with end users. In addition, the LECLERC brand has many merchant sites (ex: www.leclercdrive.fr or www.lemanegeabijoux.com) where the clients may be deceived by similar but malicious sites (typo squatting in traditional TLDs, etc.). In 2011, on-line sales through the Drive activity were 405,000,000 EUR for 144 sales points. 730,000,000 EUR for 250 sales points are predicted for 2012. A.C.D. Lec considers the security of payments on the Internet as a fundamental element and therefore wants to develop and finance the NewgTLD .LECLERC in order to reassure end consumers about the ownership of the sites and their security. The NewgTLD .LECLERC will also prevent cybersquatting against the LECLERC brand. In 2011, an on-line brand monitoring among domain names detected 23 domains considered as threatening the rights or harming the activity of the brand. They led to 16 official notifications and 8 UDRP litigations. The UDRP decisions won allowed the transfer of 43 domain names in favor of A.C.D. Lec. The association wishes to reduce the threats made to the LECLERC brand family and thus reduce abuses in which the final web clients of LECLERC may actually be the victims.
* Develop the registration of generic domain names allowing implementing a new type of marketing action. Thanks to the NewgTLD .LECLERC, the strategic directions in communication and marketing of the various companies structuring the community (see question 20) may benefit from new communication media. The generic domain names often being reserved in the TLDs traditionally used in France (.COM, .FR), the NewgTLD will offer the LECLERC entities a supplemental choice for registration of the generic names. This will allow creating a new type of communication for specific actions; creating mini-sites, for example. A.C.D. Lec considers this new opportunity as a means of decreasing the budget dedicated to the purchases of keywords in the sponsored links on Bing, Google, and Yahoo!. This budget represents 1,020,000 EUR in 2011 for the purchase of approximately 290,000 keywords. The budget has been increasing since 2009 with a budget of 670,000 EUR then 876,000 EUR in 2010. The NewgTLD .LECLERC thus allows by thesemeans to increase the visibility of the brand and communicate more directly with end users.

18(b). How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

Table of Contents

1 - Goal in terms of areas of specialty, service levels, or reputation
2 - Added value to the current space, in terms of competition, differentiation, or innovation
3 - Goals in terms of user experience
4 - Registration policies
4.1 - Eligibility of the registrants
4.2 - Domain names authorized at registration
4.3 - Launching of .LECLERC
4.3.1 - Sunrise period
5 - Measures for protecting the privacy or confidential information of registrants or users
6 - Communication

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1 - Goal in terms of areas of specialty, service levels, or reputation

LECLERC is a French distribution brand with sales in 2011 of 39.32 billion Euros, which corresponds to an increase of 8 % compared to 2010. LECLERC is the leader with major distribution on the French market, holding 18 % of the market share in 2011. The E.LECLERC brand market share in France has been increasing in a relatively stable manner (on the average 3% per year) for 4 years. The LECLERC brand is also present on the international market with more than 150 stores in other countries.

The NewgTLD .LECLERC will increase international visibility of the brand and offer strong identification of the community sites to Internet users and clients of the brand. In 2011, 12,000,000 clients had a LECLERC loyalty card. More than 90 % of these cardholders were active customers.

The LECLERC brand is recognized according to a study performed by OC&C, Strategy Consultants, in September 2011, as the second favorite food brand in France. The assets of the brand demonstrated by this study are the commitment to low prices, high quality, and consumer confidence. These values are extremely important within the organization and promoted by A.C.D. Lec. The LECLERC brand is supported by a Movement of independent members, agreeing to comply with the values promoted by the brand. The organization of the Movement and of the LECLERC community is detailed in question 20.

The NewgTLD .LECLERC will make online services more easily identifiable, limiting the internet search times for clients of the brand and facilitating access to information for end users. The sites in .LECLERC will be clearly identified as belonging to the community and related to the brand. Payments will be more secure, and domain abuse of the LECLERC brand will be limited (i.e., eliminated). This new TLD will improve services offered to end-users and thus enhance the general reputation of the brand.


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2 - Added value to the current space, in terms of competition, differentiation, or innovation

As indicated above, the NewgTLD .LECLERC will bring a strong degree of recognition to the community and to sites connected with the LECLERC brand.

The NewgTLD .LECLERC will create a specific space on the Internet for consumers of the brand and will present a new environment identified as representing the community for Internet users and community members. It is also a tool for diversity in the current space with strong specialization on a specific theme and subject.

The TLD created by the ADC Lec will also correspond to a Dotbrand and a community-based TLD. The DotBrands are totally innovative in the current space and create a new type of communication, with new spheres on the Internet. This will bring community members together more easily and facilitate access to information.


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3 - Goals in terms of user experience

Two types of Internet users are identified as potentially interested in the NewgTLD .LECLERC.

First of all, Internet users who are already clients of the brand may use it to display the community of which they are a part, identify the various universes around the brand and interact on various media.

For Internet users who are not LECLERC clients, the TLD will facilitate access to brand-specific information. A.C.D. Lec wishes for Internet users to quickly obtain knowledge and consciousness of the environment they “enter” by clicking on a .LECLERC domain name and easily recognize the brand.

For these two types of end users, .LECLERC represents:
* A communication tool to increase the visibility of official communication, to reflect the brand within the community, and to clearly identify the brand’s digital territory. This allows the community entities to guarantee to the Internet users that they are in a relationship with the LECLERC brand.
* A “Safety and security” label to eliminate the risks of phishing, to reduce the possibility of end users being deceived by unofficial communications and to decrease threats to the brand through domain names (cybersquatting). The NewgTLD .LECLERC contributes to creating a healthier space for Internet users who will instantly be able to identify that a website belongs to the brand community.
* Security of payment. Several sites of the Movement are merchant sites (ex: www.leclercdrive.fr or www.lemanegeabijoux.com). The new gTLD will assure the clients of the site’s reliability and secure the payments online. Domain names in .LECLERC allow to struggle against all kind of online fraud: scamming, identity theft.A.C.D. Lec considers the security of payments on the Internet as a fundamental element and therefore wants to develop and finance the NewgTLD .LECLERC in order to reassure end consumers about the ownership of the sites and their security.
* Affiliation between the LECLERC brand and hundreds of brands and products registered and⁄or used by Leclerc on a daily basis.

The NewgTLD will improve the visibility of the branded products and will help the Internet users to better identify the new products created.

Furthermore, the LECLERC brand owns numerous trademarks (about 630) which do not contain the LECLERC name in their naming. Most of those trademarks are sold on LECLERC e-business websites and used in several information websites. The NewgTLD will improve both LECLERC and Movement LECLERC trademarks identification and recognition.


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4 - Registration policies

To make easier the understanding of the aims and registration policies, all the answers related with these subjects will be repeated in question 20.
The applicant intends to implement the following policies and procedures:

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4.1 - Eligibility of the registrants

The only entity within the community authorized to register domain names in .LECLERC will be A.C.D. Lec (see the description of the community in question 20). The other entities of the community must ask A.C.D. Lec for the use of specific domain names. These delegations will be limited to certain types of domain names determined above. A.C.D. Lec will still be the owner of the domain name, but can delegate the use of the domain name to another entity of the community.

The single registrant system has been chosen in order to reach more easily the goals planned for the TLD, in particular for the identification of the members and its federative role for communication.

A.C.D. Lec represents the community during this application and carries registration conditions which are validated by the members.

The Movement LECLERC members are bound with the A.C.D. Lec by a the tab contract. At present time, the agreement authorizes members to register domain names containing the LECLERC name, in all TLDs. A new the tab contract will involve the NewgTLD .LECLERC. The A.C.D. Lec plans to register 4 domain names by community member, and could then register complementary domain names on request.


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4.2 - Domain names authorized at registration

A.C.D. Lec will be authorized to register all the domain names that may be useful for the promotion of the brand and relevant for the community. Each domain name must comply with the values and basic principles of the “E.LECLERC Movement” and public decency.

These fundamental principles are: members independence, price policy in aid of the consumers, solidarity and security within the movement, social calling of the company, and protection of free-market economy.

The members and other entities of the community will be authorized to request the use of the domain name composed of the geographic location (see question 22 for more details) or business name.

Domain names in .LECLERC will have to be composed of at least 3 characters and maximum 63 characters.

The registration of domain names with accented characters (International Domain Names -IDN) will be authorized in .LECLERC. Non-ASCII characters must appear in the Latin-1 Character set (ISO-8859-1).

This character set includes:
* 0, 1, 2, 3, 4, 5, 6, 7, 8, 9
* a, b, c, d, e, f, g, h, i, j, k, l, m, n, o, p, q, r, s, t, u, v, w, x, y, z
* à, á, â, ã, ä, å, æ
* ç
* è, é, ê, ë,
* ì, í, î, ï,
* ò, ó, ô, õ, ö,
* ñ,
* ù, ú, û, ü,
* ý, ÿ
* ß

The “oe” character will be also accepted since it is used in the French language. The following three symbols and characters will, however, be removed: “þ, Đ, Ø.”

A.C.D. Lec reserves the right to withdraw the use of a domain name from a member or associate if the corresponding website threatens the brand image, the activity of the Movement or public decency.

Specific measures will be set up if a domain name is registered with malicious intentions (see question 28).


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4.3 - Launching of .LECLERC

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4.3.1 - Sunrise period

This allows A.C.D. Lec to register domain names referring to the brands held by the Community. Registration during the sunrise period will be carried out for periods of 1 year to 10 years.

The domain names requested during the “sunrise period” must include the right-holding site in the domain name. For example, the brand “Marque Repère” will allow registration for marquerepere.leclerc, marque-repere.leclerc, marquerepère.leclerc, marque-repère.leclerc…

The supporting evidence must clearly describe the name for which a previous right is invoked. A previous right invoked for a name included in figurative or composed elements (including words, figures, graphics, logos, etc.) will only be accepted if the sign contains only a name, or if the verbal element is predominant and can be clearly separated or distinguished from the figurative element.

When a previous right invoked contains special characters (for example, the ampersand: &), spaces or punctuation marks, these must be eliminated from the corresponding domain name or replaced by hyphens or, when possible, expressed by normal characters. For example, the previous right for the trademark “€co Plus” can become ecoplus.leclerc, écoplus.leclerc, eco-plus.leclerc, éco-plus.leclerc.

For commercial brands, the references “TM,” “SM,” “®” may be omitted in the full name for which the previous right exists.

For names with characters other than the standard Latin characters, the domain name must contain a transliteration in standard Latin characters of the name for which the previous right is invoked. The transliteration must be consistent with the generally accepted transliteration character sets.

The .LECLERC registry agrees to comply with the rights for brands recorded in the “Trademark Clearing House (TMCH).”


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5 - Measures for protecting the privacy or confidential information of registrants or users

The single registrant of the domain names in .LECLERC is A.C.D. Lec where the “whois” information will be publicly available in the “whois.”

The candidate is a French association subject to national and European rules concerning the protection of privacy and confidential data. The French National Commission called “Commission Nationale de lʹInformatique et des Libertés” or CNIL (National Commission of Computers and Freedom) imposes strict rules concerning the protection of the confidential individual information. Furthermore, the candidate has a corresponding internal CNIL within A.C.D. Lec.


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6 - Communication

The applicant is an association structuring the Movement LECLERC and permitting the development of the LECLERC brand. The Movement LECLERC gathers independent members using the LECLERC brand. It makes possible to set up common commercial, governmental, marketing and advertising strategies.

All of its members refer to domain names including the LECLERC brand. The candidate has developed a strong online presence by multiplying its websites (informative such as: www.movement-leclerc.com, specialized on a specific theme such as www.mon-pouvoir-dachat.fr or merchant sites such as www.leclercdrive.fr, www.leclercvoyages.com, and www.lemanegeabijoux.com), sponsored links campaigns, and it dedicates a significant portion of its budget for its global communications. A.C.D. Lec wants to use the resources already in place to communicate heavily on the new extension to progressively educate users to the NewgTLD .LECLERC.

In 2011 the turnover realized on line by the Drive activity reached 405,000,000 EUR for 144 selling points. A prediction of 730,000,000 EUR for 250 selling points is anticipated for 2012. These predictions include only Drive activities but none of the annex activities such as the travel agency, or the jewellery...

The LECLERC brand devoted in 2011 269,095,000 EUR to its global communication, divided between the purchase of advertising spaces in the press (68,523,000 EUR), on the radio (129,974,000 EUR), on television (44,557,000 EUR), on other displays (21,192,000 EUR) and on the Internet (21,192,000 EUR).

Budgets devoted to global communication gradually has increased each year since 2007 (214,970,000 EUR in 2007, 231,123,000 EUR in 2008, 209,828,000 EUR in 2009 and 247,279,000 EUR in 2010). Thus, A.C.D. Lec expects to benefit from the already existing visibility to communicate the NewgTLD .LECLERC to the end-users.

In consequence, the applicant has several means of informing the community members of the creation of the new gTLD .LECLERC and its consequences (transfer of the domain names to e-leclerc.com in the TLD .LECLERC, etc.…).

These means include, but are not limited to, the following:
* Publicity campaigns TV and Radio communications on the new TLD
* Online campaigns
* Redirection of the current domain names in e-leclerc to the new domain names in .LECLERC.
* Email marketing campaigns
* Communication to the members and associates (see the description of the community) and promotion within the new gTLD.
* Press
* Other publicity campaigns...

18(c). What operating rules will you adopt to eliminate or minimize social costs?

Table of Contents

1 - Multiple applications
2 - Cost benefits for registrants
3 - Increase prices

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1 - Multiple applications

Since the applicant decided to choose the model of single registrant, the risk of having multiple applications for the same domain name is reduced to a minimum.

However, A.C.D. Lec could receive several applications for the use of a domain name. In this case, the attribution of .LECLERC will be on a first come, first served basis.


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2 - Cost benefits for registrants

A.C.D. Lec chose the single registrant model. Only this entity will be able to register domain names in .LECLERC. Community members will then be able to ask for the use and the delegation of domain names but they will remain A.C.D. Lec propriety.

For this reason, the applicant does not want to finance the new extension with the domain names users funds (the community members). .LECLERC registry will be entirely financed by on-hand equity and will not generate any income for A.C.D. Lec. Financial capacities are explained in the financial questions, in particular in question 48.

Thus, members wanting to use a .LECLERC domain name will not have any further cost to support.

As a registry, A.C.D. Lec plans to offer for free its domain names to selected registrars. A selling price of 0 EUR already exists for some TLDs such as the .MC, ccTLD of Monaco (see http:⁄⁄www.nic.mc⁄mcNicMain-us.html). The final registration costs for .LECLERC domain names for the A.C.D. Lec (as a registrant) will be low.

The registration in .LECLERC may be carried out for a period of 1 to 10 years.


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3 - Increase prices

As explained above, the .LECLERC registry does not wish to ask for financial compensation to members of the community for the use of a .LECLERC domain name. Thus, the .LECLERC registry does not plan any price increases.

Community-based Designation


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

Yes

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

Table of Contents

1 - How the community is delineated from Internet
2 - Structure of the community
3 - History of the community
4 - Estimated size of the community

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1 - How the community is delineated from Internet

The LECLERC community is composed of all entities or end users having a commercial relationship with the “E.LECLERC Movement”, commonly known under the LECLERC brand. This group was created in 1949 by Edouard Leclerc to develop mass distribution activities. 

It is composed of independent members that must comply with certain basic rules to be authorized to use the “Leclerc” brand. These basic principles are: the independence of its members, price policies to benefit consumers and consumerism, solidarity and security within the movement, social vocation of the company, and defense of free competition.

The “E.LECLERC Movement” is based on the following main structures:
 * A.C.D. Lec (Association of the E.LECLERC Distributor Centers) where the role is to determine the strategic policies for the brand. This institution is the candidate for the NewGTLD and will be the registry of .LECLERC.
 * Galec refers to the main suppliers for the group and its members on a national level.
 * 16 regional cooperatives negotiate with the suppliers in order to adapt the products to the specific consumption of the region
 * SIPLEC is in charge of importing petroleum as well as food and manufactured products.
 * SCAMARK’s mission is to develop and market the distributors’ brands
 * National and international stores held by the members and affiliates. 

Additionally, the group is composed of independent members that pay fees and agree to comply with the policies of the movement. Those members are linked to the A.C.D. Lec by a tab contract which defines the rules to use the brand name as well as the criteria that members have to meet to be allowed to use the LECLERC brand.  Independent “associates” pay a brand license to be as well authorized to sell Leclerc products within their own structures.

13 Companies were created to develop specific concepts for diversifying the activities of the “E.LECLERC Movement;” for example, the Devinlec - PRESTALEC company is in charge of developing the “Le Manège à Bijoux” jewelry concept.

To become a member, the applicant must have worked for the ʺE.LECLERC Movementʺ for several years and must be sponsored by at least one other member.

The community is also determined by other entities (individuals or business entities) having a commercial relationship with the ʺE.LECLERC Movement.” It includes suppliers, partners, manufacturers, and end users who may have a loyalty card.

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2 - Structure of the community

As specified above, the community is strongly structured and organized around A.C.D. Lec and GALEC. These entities determine the global and local strategies for the other parties constituting the community. They also ensure that the basic principles are respected in their specific domains of activity. 

GALEC, the second most important entity of the Movement LECLERC and closely related with A.C.D. Lec, negotiates with all the suppliers the sales policy enabling the stores to have an efficient, consumer-oriented price policy. 

At a national level all the LECLERC stores are members of GALEC (Groupement d’Achat des Centres E.LECLERC), a Limited Cooperative corporation with a board of directors and a supervisory board, in charge of referencing suppliers. Furthermore, GALEC is a financial contributor and coordinates the specialized subsidiaries (for example Siplec, Scaramark, Leclerc Voyages, EDEL, Devinlec…)

Firms operating under the Leclerc brand in France as members of the A.C.D. LEC are also members of GALEC and are subject to the provisions of the Cooperative. 


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3 - History of the community

The ʺE.LECLERC Movementʺ was created in 1949. A.C.D. Lec was developed in 1964 to define the strategies of the movement. Next, GALEC was added in 1970 and specific companies have been created to meet the needs of the movement since the creation of the GALEC.

The ʺE.LECLERC Movementʺ was founded to develop the distribution activity while respecting the values of the initial E.LECLERC brand. Its primary activities are to pursue its efforts to offer quality services at the best price and defend free competition.


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4 - Estimated size of the community

The number of members and associates in the community can be estimated, but this represents only part of the community. In fact, the other entities are much more difficult to evaluate. The movement had 410 French members, 49 foreign members and 15 associates in 2011. Each of these members and associates can hold several companies using the LECLERC brand.

The movement is also composed of 16 regional cooperatives and 13 specific companies and is not only known in France since several members and associates export the brand image abroad. The E.LECLERC Movement is present in Spain, Italy, Poland, Portugal and Slovenia.

In 2010 the E.LECLERC Movement had approximately 94,000 employees and represented around 18% of the mass distribution market share in France.

In 2011, 12.000.000 customers were in possession of a LECLERC loyalty card. More than 90 % of these cardholders were active customers.

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

As explained in the question 20-A, the candidate is A.C.D. Lec (Association of the E.LECLERC Distribution Centers). This organization determines the strategic orientation of the ʺE.LECLERC Movement” and guarantees that the members and associates respect the basic values.

A.C.D. Lec works primarily in close collaboration with the GALEC in order to create and to manage the brands of the Movement.

A.C.D. Lec was created on 21th July 1964, 15 years after the opening of the first E.LECLERC center by Mr Edouard Leclerc. The association acts in respect with the fundamental principles edicted by Mr Edouard Leclerc : members independence, price policy in aid of the consumers, solidarity and security within the movement, social calling of the company.

Consequently, the association has to guarantee the diffusion of the fundamental principles of the movement, contribute to the customer education, ensure the protection and promote the notoriety and development of the LECLERC brand, by setting up all useful means to reach these aims. 

A.C.D. Lec status shows that the association will be able to contribute to the creation of any oganization promoting the activity, solidarity and security of its members. 

Detailed status of the A.C.D. Lec are available in the attached file named StatutsACDLec and precise the aims of the association, conditions to become a member as well as its resources.

To validate strategic decisions regarding NewgTLD .LECLERC, A.C.D. Lec must consult its strategic committee and its board of directors. 

The internal organization of A.C.D. Lec is structured to include: 
 * A board of directors
 * A strategic committee
 * 6 permanent specialized commissions (price, communication, finance, brand family policies, global quality and sustainable development…) presided over by members recognized for their skills in these areas.
 * Occasional commissions

A.C.D. Lec is thus the organization best representing the interests of the members and associates and the Movement. These commissions and the strategic committee must ensure that A.C.D. Lec continues to fulfill its goals and give priority to shared interests.

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

1 - Intended registrants in .LECLERC
2 - Intended end-users of .LECLERC
3 - Related activities in service of the purpose
4 - Lasting nature of the purpose
------------------------
The answers related to the purpose of the NewgTLD have already been described in Question 18. Here will just be the main purpose, the detail might be found in question 18.

The NewgTLD .LECLERC will have multiple goals:
1.Represent and place the applicant’s leading and most distinctive brand (LECLERC) at the highest level of the DNS hierarchy 

2.Provide the community and its members with recognizable and trustworthy identification on the Internet. The TLD will increase the visibility of official communication of the brand.

3.Provide a secure applicant-controlled online environment to the community members and end users interested in the assets, services and activities of A.C.D. Lec. 

4.Develop the registration of generic domain names allowing implementing a new type of marketing action. 

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1 - Intended registrants in .LECLERC

The only entity within the commun ity authorized to register domain names in .LECLERC will be A.C.D. Lec (see the description of the community in question 20). The other entities of the community must ask A.C.D. Lec for the use of specific domain names. These delegations will be limited to certain types of domain names determined above. A.C.D. Lec will still be the owner of the domain name, but can delegate the use of the domain name to another entity of the community.

The single registrant system has been chosen in order to reach more easily the goals planned for the extension, in particular for the identification of the members and its federative role for communication.

The A.C.D. Lec represents the community during this application and carries registration conditions which are validated by the members.

The Mouvement LECLERC members are bound with the A.C.D. Lec by a tab agreement. At present time, the agreement authorizes to register domain names containing the LECLERC name, for all extensions. A new tab agreement will involve the New gTLD .LECLERC. The A.C.D. Lec plans to register 4 domain names by community member, and could then register complementary domain names on demand.

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2 - Intended end-users of .LECLERC

Two types of end-users are identified as potentially interested in the NewgTLD .LECLERC. 

First of all, Internet users who are already clients of the brand may use it to display the community of which they are a part, identify the various universes around the brand and interact on various media. 

Then for Internet users who are not LECLERC clients, the TLD will facilitate access to brand-specific information. A.C.D. Lec wishes for Internet users to quickly obtain knowledge and consciousness of the environment they “enter” by clicking on a .LECLERC domain name and easily recognize the brand.

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3 - Related activities in service of the purpose

A.C.D. Lec has developed the presence of the LECLERC brand on the Internet. In fact, the ʺE.LECLERC Movementʺ has many websites (without including the members’ websites), either informative (ex: www.movement-leclerc.com), specialized on a specific theme (ex: www.mon-pouvoir--dachat.fr) or merchant sites (ex: www.leclercdrive.fr or www.lemanegeabijoux.com).

A.C.D. Lec continues improving the visibility of “E.LECLERC Movement” activities. Several new websites will be launched in 2012 (at least 3 other websites already in development). sponsored links campaigns).

The applicant has the intention of implementing internal e-communication (meetings, e-mail campaigns ...) in order to inform all the members of this NewgTLD. All the official sites will progressively use the new domain names on .LECLERC. The applicant has the intention of communicating only on the domain names in .LECLERC after its launch so that the Internet users can capture this NewgTLD.

Of course, all the communication media identified in Question 18 will help achieving the purpose of the TLD (publicity on radio, TV, Internet, sponsored links…).
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4 - Lasting nature of the purpose

The “Leclerc Movement” is composed of more than 450 members and associates who share a common interest in continuing to develop the brand, the Movement and its values.

Since 1949, the Movement has not stopped growing and creating new brands and concepts that are now well known by the end users, the competition, and the wider distribution market.

Movement LECLERC owns more than 630 trademarks whose the more famous are “€co plus », « Marque Repère », « Edel », « Nettoyons la nature », « Nos régions ont du talent », « Qui est le moins cher »...

The developed concepts match with the activities which have driven to the creation of specific societies (jewellery for « Le manège à bijou, drive for « LECLERC Drive », fuel selling for « Siplec »...).

The goals presented here will last as long as the LECLERC brand exists. In parallel, the NewgTLD will help to increase the visibility of the brand and assist with support. The new TLD will create a virtuous circle for the Movement.

In 2011, the Movement was a leader of major distribution in France (18 % of market share) and continues to progress in terms of international market share. 
It reached in 2011 about 40 billion of turnover and the evolutions observed on the five last years permit A.C.D. Lec to ensure the results stability. Finally, the community (in terms of number of stores) gradually increases according to the five last years data.

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

The community was created in reference to the name of the founder Edouard “Leclerc.” The spelling of the TLD comes from the name of the community itself. Each entity of the community has a direct line with the LECLERC brand and communicates essentially with this name.

The Leclerc name has spread essentially into other French-speaking countries such as Québec in Canada. 

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

Table of Contents

1 - Eligibility of the registrants
2 - Domain names authorized at registration
3 - Content, use
4 - Enforcement policies

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1 - Eligibility of the registrants

As detailed in Question 18, the only entity within the community authorized to register domain names in .LECLERC will be A.C.D. Lec. Other entities will be able to use domain name in .LECLERC but they will always belong to A.C.D. Lec. 

The single registrant system has been chosen in order to reach more easily the goals planned for the extension, in particular for the identification of the members and its federative role for communication.


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2 - Domain names authorized at registration

A.C.D. Lec will be authorized to register all the domain names that may be useful for the promotion of the brand and relevant for the community. Each domain name must comply with the values and basic principles of the “E.LECLERC Movement” and public decency.  The fundamental principles are : members independance, price policy in aid of the consumers, solidarity and security within the movement, social mandate of the company,and protection of free-market economy.

The members and other entities of the community will be authorized to request the use of the domain name composed of the geographic location (see question 22 for more details) or business name.

Domain names in .LECLERC will have to be composed of at least 3 characters and maximum 63 characters.

The registration of domain names with accented characters (International Domain Names -IDN) will be authorized in .LECLERC. Non-ASCII characters must appear in the Latin-1 Character set (ISO-8859-1).

This character set includes: 
 * 0, 1, 2, 3, 4, 5, 6, 7, 8, 9
 * a, b, c, d, e, f, g, h, i, j, k, l, m, n, o, p, q, r, s, t, u, v, w, x, y, z
 * à, á, â, ã, ä, å, æ
 * ç
 * è, é, ê, ë
 * ì, í, î, ï
 * ò, ó, ô, õ, ö
 * ñ
 * ù, ú, û, ü
 * ý, ÿ
 * ß

The “oe” character will be also accepted since it is used in the French language. The following three symbols and characters will, however, be removed: “þ, Đ, Ø.”

A.C.D. Lec reserves the right to withdraw the use of a domain name from a member or associate if the corresponding website threatens the brand image, the activity of the Movement or public decency. Specific measures will be set up if a domain name is registered with mal-intent. (see question 28).


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3 - Content, use

A.C.D. Lec and the structuring entities of the community will use the majority of the domain names in .LECLERC referring to trademark. The use of other domain names will be delegated to the members and associates. 

The websites visible on a domain name in .LECLERC must comply with the fundamental principles and values of the Movement detailed in Question 18 and 20-A. 

A.C.D. Lec reserves the right to withdraw the use of a domain name from a member or associate if the corresponding website threatens the brand image, the activity of the Movement, or public decency. Specific measures will be set up if a domain name is registered with mal-intent. (see question 28).


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4 - Enforcement policies

Because A.C.D. Lec is the “single registrant” of the NewgTLD .LECLERC, the risk of conflicts will be reduced to a minimum. A.C.D. Lec will delegate the use of domain names to the members and associates on a “first come, first served” basis. 

To implement the policies described above, A.C.D. Lec intends to entrust the development of .LECLERC to a specific department named « GT Internet », which is already responsible for validating the domain name requests from some members, acting as a go-between with the registrars and verifying how domain names that refer to the LECLERC brand are used by community members.

This team is made up today of 10 people, divided into two groups: 
 * The first one is in charge of animating websites and enriching content (editorial and promotional).
 * The second one is in charge of the website creation part, customer relationship, internal and external communication 

It is this last group that today manages the names of domains and which tomorrow will continue this mission extended to NewTLD .Leclerc by instruction of A.C.D. Lec. 

Creation of three positions to respond to the specific needs of the registry is anticipated. The three positions opened correspond to one position in charge of the project, one position as customer support and one technical position. 

At the launch of the TLD, the three people will be involved in receiving the requests for the use of domain names from members and associates, to verify the membership of the applicant and to decide on the request. They will also have to verify that the domain names asked by the A.C.D. Lec on the sunrise period correspond effectively to a trademark and that they respect the rules established in Question 18. During the following years, the customer support will be the only one in charge of this task. 

A.C.D. Lec will monitor the use of domain names randomly and reserves the right to withdraw the use of a domain name if the corresponding website threatens the image of the brand, the activity of the Movement, or public decency. Specific measures will be set up if a domain name is registered with mal-intent. (see question 28).

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

Attachments are not displayed on this form.

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.

However, if these domain names are registered, the applicant will comply with the following limits:
* The domain names will be recorded in the name registry (A.C.D. Lec).
* When consent is required before the registration and use of a cited domain name, pursuant to specification 5 of the Registration Agreement, the applicant shall obtain consent before registration, delegation or use of the domain name.

According with GAC advice on geographic names at the second level, the .LECLERC registry some specific geographical names will not be available for registration.
* All the abbreviations of the country codes and territory names detailed on the 3166-1 list, including the European Union.
http:⁄⁄www.iso.org⁄iso⁄support⁄country_codes⁄iso_3166_code_lists⁄iso-3166-1_decoding_table.htm#EU
* The Technical Reference Manual for the Standardization of Geographical Names, from the United Nations which lists the names of 193 independent States generally recognized by the international community in the language or languages used in an official capacity.
http:⁄⁄unstats.un.org⁄unsd⁄geoinfo⁄ungegn⁄docs⁄pubs⁄UNGEGN%20tech%20ref%20manual_m87_combined.pdf

However, given that the applicant is a mass distribution company, its visitors and clients are primarily seeking offers and activities organized by regional and local LECLERC stores. The applicant can in fact create plans to register domain names that contain geographic names (only the names of cities and regions).

As the A.C.D. Lec decided to choose single registrants model, all the requests to registrars that might be accepted comes from this entity. Then all the domain names will belong to A.C.D. Lec and the registry commits to obtain the validation of proof of non-objection from the relevant public authority.

Registry Services


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

Table of Contents :

1 - Receipt of data from registrars concerning registration of domain names and nameservers : Shared Registration System (SRS)
2 - Operation of the Registry zone servers
3 - Provision to registrars of status information relating to the zone servers for the TLD
3.1 - Standard DNS related status information
3.2 - Emergency DNS related status information
4 - Dissemination of TLD zone files.
4.1 - Incremental updates every 10 minutes
4.2 - Complete publication of the zone
4.3 - Propagation mechanism
4.4 - Zone File Access⁄Distribution
5 - Dissemination of contact or other information concerning domain name registrations (Whois service)
6 - Internationalized Domain Names
7 - DNS Security Extensions (DNSSEC)
7.1 - Registrar Services
7.2 - Signing Activity
8 - Other relevant services
8.1 - Security and Redundancy
8.2 - Consensus Policy Compliance


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1 - Receipt of data from registrars concerning registration of domain names and nameservers : Shared Registration System (SRS)

Operated by AFNIC, the .LECLERC TLD will adapt a domain shared registration system used in production by AFNIC to operate .fr zone and which has been fully functional for the past 15 years. This Extensible Provisioning Protocol (EPP) based Shared Registration System (SRS) has exhibited the ability to meet stringent SLAs as well as to scale from the operational management of an initial thousands of domain names to over 2 million in late 2011.

The SRS exists to interact with the Registrar’s systems, who are responsible for the provisioning of a registrant’s domain name with the .LECLERC TLD registry. Registrars interact with the registry through two primary mechanisms :
* Communication machine to machine via an EPP client (Registrar) to an EPP Server API (Registry).
* A Web Portal Interface that expresses the functionality of the EPP API. The Web Portal also provides access to user configuration and other back-office functions such as report and invoice retrieval.

SRS functionality includes standard functions and features such as :

* Domain Registration : The AFNIC SRS supports synchronous registrations (creations) of domain names through the EPP domain create command. It supports updates of associative status, DNS and DNSSEC delegation information and EPP contact objects with a domain and the deletion of existing domains. This allows Registrars to create domain registrations, modify them and ultimately delete them.

* Domain Renewal : The AFNIC SRS allows registrars to renew sponsored domains using the EPP renew command. The SRS automatically renews domain names upon expiry.

* Transfer : The AFNIC SRS supports the transfer of a given domain between two Registrars in a secure fashion by requiring two party confirmations and the exchange of a token (the EPP authinfo code) associated with the domain.

* Contact Objects : The AFNIC SRS supports the creation, update, association to domain objects, and deletion of EPP contact objects. This functionality supports the required information to supply contact data displayed in Registration Data Directory Services (RDDS) (Whois) systems.

* Hosts : A subordinate object of the domain object in an EPP based SRS, internal hosts are supported in the AFNIC SRS. These hosts cannot be removed when other 2nd level domains within the .LECLERC TLD zone are delegated to these nameservers. Delegation must be removed prior to the removal of the child hosts and a parent domain name to a given host in turn cannot be removed prior to the deletion of the related child host.

* Redemption Grace Period (RGP) & Restoring deleted domain name registrations : AFNIC SRS supports the RGP for the purpose of retrieving erroneously deleted domain names prior to being made available again for public registration.

Other features include :

* Additional EPP commands in order to manage and update both domain and contact objects in the registry which are EPP info, check, delete and update commands.

* An inline billing system which is synchronised with the SRS. Actions can be taken daily from simple alerts to concrete account blocking.

* Grace Periods and Refunds : the AFNIC SRS will support standard grace periods such as Add, Renew, Autorenew, Transfer and RGP grace periods. Refunds issued will reflect actual values deducted from registrar’s balance in consideration of any rebates issued conjunctively or separately for the relevant domain registration.

* The capacity to deal with reserved domain name registration. Reserved names are stored in a specific back office tool. Specific authorisations codes can be delivered out of band by support team to “unlock” creation of these reserved names. SRS uses standard EPP auth_info field in conformity with EPP RFCs to prevent or allow the registration of the domain name.

[see attached diagram Q23_1_authorisation_code_workflow.pdf]
Diagram : Reserved names unlock
Description : This diagram illustrates process to unlock registration of reserved names. An out of band email process is used to deliver a specific authorisation_code, that can be used in EPP or through the web interface to register the domain name.

SRS EPP functions are compatible with the following list of RFCs :
RFCs 5910, 5730, 5731, 5732, 5733 and 5734. Since AFNIC will implement the Registry Grace Period (RGP), it will comply with RFC 3915 and the successors of the aforementioned RFCs.


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2 - Operation of the Registry zone servers

The DNS resolution service is a core business of the Registry Operator. It is an essential function that must be provided with a very high level of service quality to satisfy queries concerning a zone 100% of the time with a response time as short as possible.

As the registry back-end service provider for the .LECLERC TLD, AFNIC has a set of sites, distributed internationally, to answer these queries. The high availability of responses is ensured by the number of servers that host the zone information; the response time is in turn linked to the geographical location of the servers (as near as possible to the exchange points and as a result to users).

To ensure a very high level of availability of information and a response time as short as possible to a DNS query for a given zone, AFNIC has chosen to deploy its own DNS architecture, operated by our teams, while also relying on a set of internationally recognized service providers in order to significantly increase the number of servers hosting the zone to be published.

The AFNIC DNS service is based on the standards of RFCs (RFCs 1034, 1035, 1982, 2181, 2182, 2671, 3226, 3596, 3597, 4343, and 5966 and any future successors), related to the Internet, and the DNS in particular.

In addition, special attention has been paid to the security component of the DNS servers and services in order to maintain a very high level of availability of the information, for example in the event of attacks or the denial of services. At present, a series of national and international servers are deployed as close as possible to the exchange points to ensure the DNS resolution service. To ensure a high level of availability, Anycast technology is applied to overcome the issues involved in the geographical location of sensitive servers. Through an effective pooling of DNS server resources, it ensures better resistance to denial of service attacks as the number of physical servers to attack is very high, and the geographical attraction of traffic by each server is very strong. Maintenance of the nodes is also improved since interventions on a given server have no effect on the visibility of the Anycast cloud for users.
As explained in the answer to Question 34 (Geographic Diversity), the registry also relies on two operators of Anycast clouds to expand the international coverage of the DNS nodes which must respond to queries for the domain extensions hosted on them. The two operators are Netnod Autonomica and PCH (Packet Clearing House) who are both known for their high quality services; in addition, Netnod Autonomica hosts one the root server i.root-servers.net.


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3 - Provision to registrars of status information relating to the zone servers for the TLD

Registrars interactions with the Registry Systems in two states in regards to the state of the TLD zone servers :
* an operational state where normal registry transactions and operational policies⁄practices result in a cause and effect in resolution of relevant domains AND
* an emergency state where resolution could be threatened by operational problems due to either internal or external factors to the DNS services.

------------------------
3.1 - Standard DNS related status information

The SRS supports related updates to domain objects that allow a Registrar to populate internal (glue record) and or external DNS hosts associated with the domain. External hosts result in the correct associated NS records being inserted into the current TLD zone file, this in turns results in DNS resolution being delegated to the identified external hosts. The SRS expresses this status to the Registrar as “Active” in both the EPP API and the SRS Web Portal. The registrar may suspend the NS records associated with the external hosts by applying an EPP client HOLD in the system, which will also be displayed as a status in the same manner. This holds true of the Registry when it applied “Server Hold”. Internal hosts follow the same behaviour with one exception, IP addresses must also be provided to the SRS by the registrar for Internal hosts, resulting in A records or⁄and AAAA records for IPv6 (also known as glue records) being added to the zone file.

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3.2 - Emergency DNS related status information

AFNIC registry services maintain emergency Network Operation Center (NOC) and Customer Service personnel on a 24⁄7⁄365 basis to address escalation and customer issue management. Part of these teams responsibility is to maintain contact lists for technical notification of regular or emergency situations including email lists, names and contact numbers. In the unlikely event that DNS resolution or DNS updates were or were expected to fall out of ICANN mandated SLAs, registrars will be contacted proactively by their email lists, status alerts will be posted to the Registry Operator’s Registrar Relations Web Portals and Customer Service personnel will be prepared to take and address calls on the current DNS status.


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4 - Dissemination of TLD zone files.

Publication of DNS resolution data to the TLD DNS nodes serving resolution :
One of the main challenges of DNS resolution is to provide updated information about the resources associated with a registered domain name. As soon as information is updated by a registrar on behalf of a customer, the latter expects the server to be accessible to its users as soon as possible.
For this reason, updates of DNS resolution data (publication) are entered into the AFNIC SRS, subsequently generated into incremented zone files, and are distributed to the authoritative DNS servers using the two following methods :
* Incremental updates every 10 minutes
and
* Complete publication of the zone.

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4.1 - Incremental updates every 10 minutes

The principle of publication by Dynamic Update (RFC 2136 and 2137) is designed to publish only the changes to the zone that have occurred since the last update. At the registry level, we have opted to propagate every 10 minutes the changes made during the last 10 minutes on all the zones managed. In this way, any changes made will naturally be published in the next 10 minutes.

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4.2 - Complete publication of the zone

In addition to the publication described above, the registry’s DNS operations team produces a complete publication of all the data for all the zones once a week by running a series of computer scripts which regenerates zonefile from database, through the same validation and integrity mechanisms as dynamic publication. This is used as a training for eventual recovery measures to be triggered.

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4.3 - Propagation mechanism

Whether during the publication by Dynamic Update or complete publication, the propagation mechanism is the same. The process involving the generation of the various zone files is triggered, without blocking any operation on the registration system.
These zone files are then transmitted in full to the authoritative server, via the AXFR protocol in conformance with RFC 5936. Once received and processed by the authoritative server, notifications are sent to secondary servers that will retrieve the changes in the different zones via the IXFR protocol in conformity with RFC 1995. The choice of an incremental (rather than complete) update of the zone files to the secondary servers during the dissemination process has been made to avoid sending large amounts of data to remote sites.

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4.4 - Zone File Access⁄Distribution

In compliance with Specification 4, Section 2, AFNIC registry services will offer a subscription service for qualifying applicants to download a stateful copy of the TLD zone file no more than once per 24 hours period. Distribution of the zone file will occur through the ICANN authorized Centralized Zone Data Access Provider.


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5 - Dissemination of contact or other information concerning domain name registrations (Whois service)

The AFNIC RDDS (Whois) service is in direct connection with the database of the Shared Registration System and offers access to the public administrative and technical data of the TLD. Contact data associated with registrations in the SRS is accessible both on port 43 (following specifications of RFC 3912) and through web access.

Data that can be accessed through the RDDS include:
* contact data : holder, administrative, technical, billing
* domain data : domain name, status
* host data : name servers, IP addresses
* ephemeris : creation, expiration dates
* registrar data
These data elements are fully compliant to the mapping of RFCs 5730 to 5734 and an example of standard port 43 output is given at the end of answer to Question 26 (WHOIS).

Both web and port 43 RDDS offer natively compliance with privacy law with a “restricted diffusion” flag. This option is activated through EPP (see Question 25 (EPP)) while creating or updating a contact and automatically understood by the Whois server to anonymize the data. The choice to activate restricted diffusion is made in compliance with the policy and the local rules of the TLD.

This service is accessible both in IPv4 and IPv6. The AFNIC RDDS service access is rate limited to ensure performance in the event of extreme query volumes generated in the cases of distributed denial of service (DDOS) and⁄or RDDS data-mining activities.


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6 - Internationalized Domain Names


Based on AFNIC’s Back-end registry’s operation experience, the .LECLERC TLD will allow registration of IDN domain names in full compliance with RFCs 5890 to 5893 and based on the character set described in detail in our answer to Question 44 (IDN). This feature will be available upon launch of the TLD and will be implemented following the policies presented in detail in our answer to Question 44 (IDN). For the purpose of clarity, a brief summary of this information is presented below.

The list of characters includes the French language as well as several other regional languages in use in France : Occitan, Breton, Frankish, Reunion Creole, Catalan, Corsican and Guadeloupe Creole. The list consists of some of the characters of the Latin1 standard (ISO-8859-1) and the Latin9 standard (ISO-8859-15), respectively in Unicode Latin-1 Supplement and Latin Extended-A blocks.

Each domain name registration is autonomous : the registration of an ASCII domain name and the registration of one of its diacritic variants are independent. The actual registered domain name is the only one to be effectively registered and published by the Whois and DNS Services.

However, the registration of a given ASCII or IDN domain name leads to a default preference to its registrant (original registrant) for the subsequent registration of any of its diacritics variants. Any of these variants can be registered normally by the original registrant at any time. Other registrants are required to request a specific authorization code delivered by the Registry Operator before they can proceed to the registration of such names. This policy applies whether the original registrant initially applies for an ASCII domain name or a diacritic variant of that ASCII domain name. In the latter case, the ASCII name is subject to the same preference policy than the other diacritic variants of the domain name.


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7 - DNS Security Extensions (DNSSEC).

AFNIC registry services fully support DNSSEC and will sign the .LECLERC TLD zone from initiation into the root servers.

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7.1 - Registrar Services

Operations are available for registrars through EPP with the SecDNS EPP extension version 1.1 exclusively (as defined in RFC 5910) or through registrars extranet (with a web form). Among the two interfaces defined in the RFC 5910, AFNIC chose the “dsData” interface : domain names keys are solely under registrars management and are not exchanged, only the keys hashes (DS records) are sent by the registrars to the registry back-end service provider. Each domain name can be associated to 6 distinct key materials at most.

Zonecheck : A complementary monitoring and validation service.
AFNIC notes that “Zonecheck” is a DNS monitoring and validation service that is outside standard registry services and could be offered by third parties other than a Registry Operator. In respect of DNSSEC monitoring, each change of DS data related to a domain name is verified by the AFNIC ZoneCheck tool, out of band of standard EPP registry functions. Registrar are notified via email of detected errors. This helps Registrars ensure the DNSSEC validation will operate correctly, for example by avoiding the “Security Lameness” scenario outlined in section 4.4.3 of RFC 4641.

Registrar transfer by default removes DS data from the zonefile. This is done to cover cases when a current signed domain names goes from a DNSSEC enabled registrar to another registrar that is not yet prepared to handle DNSSEC materials (the registrar can also be the DNS hoster or not, but in both cases DS data of the domain name has to flow from the registrar to the registry, hence the registrar must have the technical capabilities to do so).

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7.2 - Signing Activity


Each public-facing DNS server operated by AFNIC or through its anycast providers is fully DNSSEC enabled through RFC 4033, 4034, and 4035 by virtue of using standard open source software (BIND & NSD) that are developed according to these RFCs.

Each zone uses a standard Key Signing Key (KSK)⁄Zone Signing Key (ZSK) split (as defined in RFC 4641, section 3.1), which enables longer KSKs and frequent re-signing of zone content to deter DNSSEC-related brute force attacks and to make sure that keys rollovers are part of registry staff operational habits. All keys are created using RSA algorithms, as defined in RFC 4641 section 3.4 : KSKs are 2048 bits long (as recommended for “high value domains” in section 3.5 of RFC 4641), and ZSKs are 1024 bits. Algorithm SHA-256 (as defined in RFC 4509) is used for DS generations. Signatures of zone resources records are done using SHA-2 and more specifically RSA⁄SHA-256 as defined by RFC 5702.

Each zone has its set of dedicated KSKs and ZSKs: one of each is active at all time, while a second of each is ready to be used at next rollover. A third ZSK may be kept in the zone after being inactive (not used any more for signing) to ease transitions and make sure DNS caches can still use it to verify old resource records signatures. Following recommendations in section 4.1.1 “Time considerations” of RFC 4641, with a zone maximum TTL being 2 days and a zone minimum TTL of 1.5 hour, ZSK rollovers are done each 2 months, KSK rollovers are done each 2 years. Their expirations are monitored. Rollovers are operated according to the “Pre-Publish Key Rollover” procedure detailed in section 4.2.1.1 of RFC 4641.

1 year worth of key materials is generated in advance. Encrypted backup of keys is made on Hardware Security Module (HSM) cards (Storage Master Key), which are securely stored physically.


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8 - Other relevant services

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8.1 - Security and Redundancy

AFNIC maintains primary and secondary datacenter locations as well as redundant key personal operating locations. High availability of AFNIC Registry infrastructure is provided through the implementation of either load‐balancing, or fail­‐over capacity in various layers of the architecture. It also enables fast scalability through expertise in virtualization technologies. AFNIC’s infrastructure is globally virtualized apart from services requiring very high performance rate and⁄or specific access to dedicated CPU for demanding computation such as DNSSEC zone signing or databases.
AFNIC maintains robust secure policies, protocols and third party testing and certification of security measures and practises. Systems involved in the AFNIC registry services used standard multi-factor authentication, high encryption transmission of data and are kept current with industry advancement in security technologies and best practices in prevention of data breaches. Registry systems follow standard EPP practices including required passphrases associated with each domain object and the use of those passphrases to successfully negotiate and verify domain transfers. Registrars are networked source restricted (2 IP addresses authorized by registrar) for SRS access in addition to the use of digital certificates and contact to Customer Service is restricted to registered Registrar personnel only (identified by personal passphrases⁄credentials listed on file).

------------------------
8.2 - Consensus Policy Compliance

AFNIC registry services will fully comply with Specification 1 of the Application Guidebook, below is a list of current consensus policies that have cause and effect on the systems of a registry operator. This list will be updated from time to time as per the ICANN process and the AFNIC registry services will be adjusted to maintain and support full compliance.

* Uniform Domain Name Dispute Resolution Policy (adopted by ICANN Board 26 August 1999; form of implementation documents approved 24 October 1999).
* Inter-Registrar Transfer Policy (effective on 12 November 2004, adopted by ICANN Board 25 April 2003; implementation documents issued 13 July 2004).
* Registry Services Evaluation Policy (effective on 15 August 2006, adopted by ICANN Board 8 November 2005; implementation documents posted 25 July 2006)
* AGP Limits Policy (effective on 1 April 2009, adopted by ICANN Board on 26 June 2008; implementation documents posted 17 December 2008)

Demonstration of Technical & Operational Capability


24. Shared Registration System (SRS) Performance

Table of Contents

1 - Global description
2 - Shared Registration System (SRS) architecture
3 - SRS architecture diagram
4 - Detailed infrastructure
5 - Rate limitation
6 - Interconnectivity and synchronization with other systems
7 - Performance and scalability
8 - Resources
8.1 - Initial implementation
8.2 - On-going maintenance


------------------------
1 - Global description

As one of the critical registry functions, the SRS is part of the core of AFNIC back-end registry solution as deployed to fit the needs of the .LECLERC TLD.
It both provides services for registrars and generates the data used for DNS publication and resolution service. In that aspect, it is responsible for most of the SLA’s to be respected. The following description will provide full and detailed description of the architecture of the SRS both from an application and from an infrastructure point of view.
This architecture is the same as the one used in production by AFNIC to operate .fr zone and has been fully functional for the last 15 years, with the ability to meet stringent SLAs as well as to scale from the management of a few thousands domain names in operations to over 2 million in late 2011.


------------------------
2 - Shared Registration System (SRS) architecture

AFNIC SRS is based on a three-layer architecture : front-end, business logic, middleware.
These three layers are supported by the data layer which is described in detail in Question 33 (Database Capabilities).

= Front end : Extensible Provisioning Protocol (EPP) and extranet =

The automated front-end of the SRS is EPP.
The EPP interface and implementation complies with RFCs 3735 and 5730-5734. It is itself described in detail in Question 25 (EPP).
An extranet web interface also offers the same functions as the EPP interface.
Both theses interfaces are supported by the same middleware layer.

= Business logic : flexible policies =

The Business logic enables configurability in order to allow for the adjustment of registry systems to the chosen registry policies. Various policy-related parameters such as delay for redemption, access rate-limiting and penalties can be configured in this layer.
The Business logic also incorporates a scheduler which provides for semi-automated processes with human validation in order to address specific policy needs which cannot or should not be fully automated.

= Middleware : a guaranty for evolution and scalability =

The Middleware layer guarantees a consistent and registry oriented access for all the TLD data. All registry applications operate through this layer in order to centralize object management rules. It enables access through different programming languages (Java, php and Perl in AFNIC solution) with same rules and ease of switching from one language to another in case of application refactoring or migration.

= Data =

The Data layer is the structured data repository for domain, contact, operations, historization of transactions, as well as registrars and contracts data. It provides all the necessary resilient mechanisms to ensure 100% uptime and full recovery and backup.
It also provides a complete toolbox for the fine tuning of the various applications. This layer is described in more details in Question 33 (Database capacities).


------------------------
3 - SRS architecture diagram

[see attached diagram Q24_3_SRS_architecture_diagram.pdf]
Diagram : SRS architecture diagram
Description : This diagram shows global interaction between Internet, DMZ (Demilitarized Zone) and private network zones. Topology of network and servers is illustrated including dedicated IP address scheme and network flows.

This diagram does not shows additional sandbox and preproduction services. These services are offered respectively for registrars and back-end developer team to stabilize developments before production delivery. They are fully iso-functional to the SRS description above.

= SRS logical diagram =

Our robust infrastructure shows dual Internet Service Provider (ISP) connectivity both in IPv4 and IPv6 (Jaguar and RENATER), redundant firewall and switching infrastructure. This part of the architecture is mutualised for all TLDs hosted.

The networking architecture dedicates LAN for administration, backup and production.

Servers are hosted on different network zones : database for database, private for servers not visible on the internet and public for external servers visible on the DMZ. Dedicated zones are also set up for monitoring servers, administration servers or desktop and backup servers.
Each server is load balanced and the service is not impacted by the loss of one server, the capacity of each server being sized to be able to host the whole traffic.

Servers are fully dedicated to the .LECLERC TLD, based on a virtualized hardware infrastructure shared among up to an estimated number of 5 TLDs of comparable scale and use case.

= SRS physical diagram =

The IP scheme used is the following :

2001:67c:2218:1::4:0⁄64 for IPv6 Internet homing
192.134.4.0⁄24 for Ipv4 Internet homing

= Production LAN =

192.134.4.0⁄24 for public network IP range
10.1.50.0⁄24, 10.1.30.0⁄24 for private network IP ranges distributed on the zones described above.


= Backup LAN =

172.x.y.0⁄24 : x is different on each network zone. y is fixed to the value of the associated production LAN in the same zone (for example Private zone production LAN being 10.1.”50”.0⁄24, Private zone backup LAN is 172.16.”50”.0⁄24)

= Administration LAN =

172.z.y.0⁄24 : z is the value of x+1, x being the digit chosen for the corresponding Backup LAN in the same zone. y is fixed to the value of the associated production LAN in the same zone (for example Private zone production LAN being 10.1.”50”.0⁄24, Private zone administration LAN is 172.17.”50”.0⁄24).

Hot standby of the production database is automatically taken into account by the SRS Oracle Transparent Network Substrate configuration. Therefore if the database are migrated in hot standby due to failure of part of the system, the SRS access is automatically swapped to the new base.


------------------------
4 - Detailed infrastructure

The SRS modules play a central role in the back-end registry infrastructure. This is highlighted in terms of capacity expenditures (CAPEX) by the fact that SRS modules account for approximately 30% of the global CAPEX of the solution.

In the following description “server” will refer to either a physical or a virtual server.
Due to very fast growth of performance in storage and processors technologies, the infrastructure described below could be replaced by more powerful one available at the time of the set up for the same cost.

It is important to note that at the applicative and system level, AFNIC’s SRS is fully dedicated to the .LECLERC TLD.

AFNIC has invested in very efficient VMWare Vsphere virtualization infrastructure. It provides a flexible approach to recovery both through quick activation of a new fresh server in case of local failure (cold standby) and through global failover to a mirrored infrastructure on another site.
This comes in addition to natural redundancy provided by the load balanced servers.

Nevertheless, internal protocols and best practices for server virtualization have shown that very high I⁄O-intensive (Input⁄Output) application servers are not good clients for virtualization. The SRS is therefore hosted on virtualized infrastructure to the exception of the database, which presents very high rate of I⁄O, and is hosted on a dedicated physical infrastructure.

The whole SRS service is located in the primary datacenter used by AFNIC in production, the secondary datacenter serves as failover capacity.

The Front end is hosted on two load balanced virtual servers and two load balanced reverse proxies ensuring authentication of registrars.

The Business logic is hosted on two load balanced dedicated virtual servers. Scalability of these servers is ensured by quick resizing offered by virtualization technology if needed.

The Middleware is hosted on two load balanced dedicated virtual servers. It can be extended to any amount of servers needed to ensure performance commensurate with the amount of traffic expected. The dual use of Apache HAproxy and of a centralized lock mechanism ensure good queuing of each request in the system despite heavy load and parallelized middleware data access.

Scalability of all these servers are ensured by quick resizing offered by virtualization technology if needed.

All databases are based on Oracle technologies. The main database is replicated logically on two sites. Full local recovery processes are in place in case of loss of integrity through the Oracle redolog functions which provides full recovery by replay of historized logged requests.

The whole SRS service is located in the primary Tier 3 datacenter used by AFNIC in production, the secondary datacenter serves as failover capacity. Continuity mechanisms at a datacenter level are described in Questions 34 (Geographic Diversity), 39 (Registry Continuity) and 41 (Failover testing).

The detailed list of infrastructures involved can be described as follows :

This infrastructure is designed to host up to an estimated number of 5 TLDs of comparable scale and use case.

= Virtual servers =

EPP proxy : 2 servers
* Processor: 1 bi-core CPU
* Main memory: 8 GB of RAM
* Operating system: RedHat RHEL 6
* Disk space: 500 GB

EPP service : 2 servers
* Processor: 1 quad-core CPU
* Main memory: 16 GB of RAM
* Operating system: RedHat RHEL 6
* Disk space: 1 TB

Business logic : 2 servers
* Processor: 1 bi-core CPU
* Main memory: 16 GB of RAM
* Operating system: RedHat RHEL 6
* Disk space: 500 GB

Data Gateway : 2 servers
* Processor: 1 quad-core CPU
* Main memory: 16 GB of RAM
* Operating system: RedHat RHEL 6
* Disk space: 1 TB

= Data storage : see Question 33 (Database Capabilities) =

= Physical server =

Rate limiting database : 1 server
* Processor: 1 bi-core CPU
* Main memory: 8 GB of RAM
* Operating system: RedHat RHEL 6
* Disk space: 500 GB

Back up servers, backup libraries, Web whois server : mutualized with the global registry service provider infrastructure

= Additionnal infrastructure =

Failover infrastructure : 6 servers
* 1 bi-core CPU, 8 GB of RAM, RedHat RHEL 6, 500 GB

Sandbox infrastructure : 6 servers
* 1 bi-core CPU, 8 GB of RAM, RedHat RHEL 6, 500 GB

Preproduction infrastructure : 1 server
* 1 quad-core CPU, 16 GB of RAM, RedHat RHEL 6, 1 TB


------------------------
5 - Rate limitation

To ensure resiliency of the SRS a rate limitation and penalty mechanisms are in place.
Rate limitation and penalties are directly implemented on the front end server.

Access is rate limited through token-bucket algorithms with rate-limiting IP data stored on a dedicated database.
Penalties are applied as follow :
* Any command that follows a login command is immediately executed but the next one is only taken into account 2 seconds later. The following commands are not penalized (unless they do not follow one of the limitation rules).
* For the same domain name, the domain:check commands will not be able to follow themselves more than 2 times every 4 seconds. Beyond this rate, a 2 second penalty will be applied on the following domain:check commands (for the same domain name). For instance, it is possible to have a domain:check follow a domain:create command that already followed a first domain:check on a same domain name without any penalty.
* On the other hand, a customer making several domain:check commands on a same domain name will need to respect a 4 second delay between the first and the third call if he wishes not to be penalized.
* Any domain:create command on an already existing domain name induce an additional 2 seconds in the answer time of this command.
* Any domain:info command on a domain name that is not in your portfolio and for which you do not indicate the auth_info induce an additional 1 second in the answer time of this command.

The rate limiting database is hosted on one physical dedicated physical server. This server represents no failure point as a failure of the rate limiting system doesn’t affect the service (a standard uniform limitation is then applied instead of intelligent rate limiting).


------------------------
6 - Interconnectivity and synchronization with other systems

= Whois (RDDS) =

The whois service will be described in detail in question 27. It is hosted on two servers directly connected to the main production database through read only API. Data updated by the SRS are immediately visible in the Whois with no further synchronisation needed. Rate limitation is applied on RDDS service to avoid any load on the database due to Whois direct access. Hot standby of the production database is automatically taken into account by the Whois Oracle Transparent Network Substrate configuration. Therefore if SRS and database are migrated in hot standby due to failure of part of the system, the Whois service is automatically swapped to the new architecture.

= Back office⁄billing⁄Escrow =

Back-office, escrow and billing system is hosted on mutualized server. It operates directly on production data through the middleware layer to ensure integrity of data. These can be considered as fully synchronous applications. Hot standby of the production database is automatically taken into account by the Middleware layer Transparent Network Substrate configuration. Therefore if SRS and database are migrated in hot standby due to failure of part of the system, the back office and billing service are automatically swapped to the new architecture.

= Monitoring =

Monitoring is operated through probes and agents scanning systems with a 5 minutes period. The monitoring system gets snmp data from all servers described in the SRS architecture and also from dedicated Oracle monitoring agent for the database. A specific prove for EPP simulating a full domain creation is also activated, still with the 5 minutes period.

= Dispute resolution =

Any operation on domain names triggered in the context of a dispute resolution is made through a back-office tool (see Back office)

= DNS publication =

DNS publication relies on a specific table of the production database hosted on the same oracle instance. These data are directly generated by the SRS system. Dynamic Update batches are generated at each operation. The use of theses batches for DNS Dynamic update or of the whole data for full zonefile generation are made directly from these production data. No further synchronization is needed. The detail of frequency and workflow for dns publication is described in Question 35 (DNS) and Question 32 (Architecture). Hot standby of the production database is automatically taken into account by the DNS publication Transparent Network Substrate configuration. Therefore if SRS and database are migrated in hot standby due to failure of part of the system, the dns publication is automatically swapped to the new architecture.


------------------------
7 - Performance and scalability

The Registry’s SRS offers high level production SLAs and derives from the branch of systems that have evolved over the last 15 years to successfully operate a set of french ccTLDs.

The Registry’s SRS is used to operate .fr, .re, .yt, .pm, .tf, .wf TLDs. It is used by more than 800 registrars in parallel managing more than 2 millions domain names.

AFNIC’s SRS is designed to meet ICANN’s Service-level requirements as specified in Specification 10 (SLA Matrix) attached to the Registry Agreement.

Actual and current average performance of AFNIC’s SRS is :
* SRS availability : 99,4%
* SRS session-command RTT : 400ms for 99,4% of requests
* SRS query command RTT : 500ms
* SRS transform command RTT : 1,4 s on availability period
* SRS max downtime : 2 hours⁄month

As described in Question 31 (Technical Overview) in relation to each of the phases of the TLD’s operations, the following transaction loads are expected on the SRS :
* Launch phase : up to 2,400 queries⁄hour
* Routine ongoing operations : up to 2,500 queries⁄hour

The system is designed to handle up to 400,000 domain names and up to 10 requests per second.

The targeted TLD size being approximately 10,000 domain names after 3 years of operations and the expected peak transaction rate being 2,500 queries⁄hour, this ensures that enough capacity is available to handle the launch phase, unexpected demand peaks, as well as rapid scalability needs.

Capacity planning indicators are set up to anticipate exceptional growth of the TLD.
Technologies used enables quick upgrade on all fields :
* Servers : virtual resizing to add CPUs or disk space if resource is available on the production ESX servers. If not, 2 spare additional ESX servers can be brought live if additional performance is needed.
* Database : database capacity has been greatly oversized to avoid need of replacement of this physical highly capable server. Precise capacity planning will ensure that sufficient delay will be available to acquire new server if needed. A threshold of 40% of CPU use or total storage capacity triggers alert for acquisition.


------------------------
8 - Resources

Four categories of profiles are needed to run the Registry’s Technical Operations : Registry Operations Specialists (I), Registry Systems Administrators (II), Registry Software Developer (III) and Registry Expert Engineers (IV). These categories, skillset and global availability of resources have been detailed in Question 31 (Technical Overview of Proposed Registry) including specific resources set and organisation to provide 24⁄7 coverage and maintenance capacity.
Specific workload for SRS management is detailed below.

------------------------
8.1 - Initial implementation

The set up is operated on the pre-installed virtualization infrastructure. It implies actions by system, database and network administrators to create the virtual servers and install the applicative packages.

Then, developers, assisted by a team of experts and senior staff members apply proper configuration for the given TLD. Specific policy rules are configured and tested.

The initial implementation effort is estimated as follows :

Database Administrator 0.10 man.day
Network Administrator 0.10 man.day
System Administrator 0.10 man.day
Software Developer 0.40 man.day
Database Engineer 0.40 man.day
Software Engineer 0.80 man.day
DNS Expert Engineer 0.40 man.day

------------------------
8.2 - On-going maintenance

On-going maintenance on the SRS includes integration of new policy rules, evolution of technology, bug fixing, infrastructure evolution, failover testing.

Although all the defined technical profiles are needed for such on-going maintenance operations, on a regular basis, it is mainly a workload handled by monitoring and development teams for alert management and new functional developments, respectively.

The on-going maintenance effort per year is estimated as follows, on a yearly basis :

Operations Specialist 1.60 man.day
Database Administrator 0.40 man.day
Network Administrator 0.40 man.day
System Administrator 0.40 man.day
Software Developer 2.40 man.day
Database Engineer 0.20 man.day
Network Engineer 0.20 man.day
System Engineer 0.20 man.day
Software Engineer 0.20 man.day

25. Extensible Provisioning Protocol (EPP)

Table of Contents

1 - Global description
2 - Description of commands
2.1 - Introduction
2.2 - Global commands
2.2.1 - session management commands ‘greeting’, ‘hello’, ‘login’, ‘logout’
2.2.2 - poll command ‘poll’
2.3 - domain commands
2.3.1 - query commands ‘check’, ‘info’
2.3.2 - transform commands
2.4 - contact command
2.5 - Return Codes
3 - Compliance to RFCs
3.1 - Delivery process
3.2 - XML validation
3.3 - Cross checking
4 - Specific extensions
4.1 - Specific extension : DNSSEC
4.2 - Specific extension : IDN
4.3 - Specific extension : Sunrise period
4.3.1 - New objects
4.3.2 - Command extensions
4.3.2.1 - EPP Query Commands
4.3.2.2 - EPP Transform Commands
4.3.2.2.1 - EPP ʹcreateʹ Command
4.3.2.2.2 - EPP ʹupdateʹ Command
4.3.2.2.3 - EPP ʹdeleteʹ Command
5 - Resources
5.1 - Initial implementation
5.2 - On-going maintenance


------------------------
1 - Global description

The main service of the Shared Registration System (SRS) for its registrars is the Extensible Provisioning Protocol (EPP) interface. The interface has been developed and is maintained in full compliance with the relevant standards RFCs 5730-5732 and with RFCs 5910 and 3735 for the standard registration interface. Contacts are handled as described in RFC 5733. Transport is guaranteed according to RFC 5734. In addition, AFNIC’s EPP implementation is also compliant with RFCs 4034, 5730 and 5731 for DNSSEC support and with RFCs 5890 and 5891 for Internationalized Domain Name (IDN) support.

The EPP service is available through IPv4 and IPv6, based on a SSL certificate authentication.
No specific extension is used.

Note : Throughout the document we write the XML markups describing the EPP requests between the two characters ʹ and ʹ.

For contact management, the registry service provider uses a dedicated “Repository Identifier” for each TLD, this Repository identifier being declared to IANA prior to the launch of the TLD. It is also used as a post-extension to contact nic-handles, each contact for a given TLD being then identified by a unique code XX1234-REPID. An example of this declaration can be found for .fr extension (2008-05-10) at IANA epp repository identifier’s page :

[...]
NORID, #x004E #x004F #x0052 #x0049 #x0044 UNINETT Norid AS 2007-12-10 info&norid.no
FRNIC, #x0046 #x0052 #x004e #x0049 #x0043 AFNIC 2008-05-29 tld-tech&afnic.fr
CIRA, #x0043 #x0049 #x0052 #x0041 Canadian Internet Registration Authority 2009-07-22 info&cira.ca
[...]


------------------------
2 - Description of commands

------------------------
2.1 - Introduction

The EPP interface, based on a double system of real-time answer by the server and asynchronous notifications, implements all standard operations : ‘domain:create’ (1 to 10 years), ‘domain:info’, ‘domain:checkʹ, ‘domain:transfer’, ‘domain:update’, ‘domain:renew’. Similar commands are available concerning contact objects.
The registry’s EPP server implement name servers management as domain name attributes in conformity with RFC 5732.

[see attached diagram Q25_2.1_EPP_xsd_main_schema.pdf]
Diagram : EPP xsd main schema
Description : Registry service provider SRS EPP interface is based on standard xsd schema as defined in RFC 5730.

In the following description of the commands, an example of client command and server answer has been added only for the create command as an example. All other commands work in the same way in full compliance with descriptions and schema of RFCs 5730-5734 and same examples can be found in the RFCs text.

------------------------
2.2 - Global commands

------------------------
2.2.1 - session management commands ‘greeting’, ‘hello’, ‘login’, ‘logout’

As all of these commands are basic and totally compliant with the IETF’s STD69 (RFCs 5730 to 5734), they have not be described again here.

Focus points are :
* Enforcing a limit of 2 simultaneous connection per registrar (checked at login), ensuring equitable access for all registrars.
* List of namespaces announced in ʹgreetingʹ is strictly checked in registrar ʹloginʹ command.
* ʹhelloʹ can be used by registrars as a keepalive command, otherwise inactive sessions are closed by server after 20 minutes.

------------------------
2.2.2 - poll command ʹpollʹ

For some operation on objects, notifications are added in a queue that can be read by using the ʹpollʹ command. The use of the ʹpollʹ command will retrieve the oldest message in the queue. The number of messages awaiting in the queue is indicated at each command answer with the ʹmsgQʹ element. To delete a message from the queue, the ʹpollʹ command should be used with the message number as indicated in RFC 5730.

------------------------
2.3 - domain commands

------------------------
2.3.1 - query commands ʹcheckʹ, ʹinfoʹ

ʹcheckʹ command allows the client to check if a domain object is available.
ʹinfoʹ command allows the client to retrieve information on any objects (domain names or contacts) that are indicated in the command. Registrars can only use this command for objects they already manage in their portfolio. This command can also be used for domain names outside the registrar’s portfolio if the ʹauth_infoʹ code that protects the domain is given as well.

------------------------
2.3.2 - transform commands

In compliance with RFCs 5730 (commands presentation), 5731 (domain objects), 5732 (contact objects) and 5910 (DNSSEC specifications) AFNIC’s Registry solution use the following commands that allow for objects updates :

= ʹcreateʹ =

The EPP protocol (RFC 5730) allows domain name creation (RFC 5731). The registry service provider allows two types of creations: direct domain creations (with auth_info freely determined by the registrar) and domain names creation “with authorization code” (the correct auth_info value must be sent for the creation to succeed)

Both are standard domain:create command as defined in the RFCs.

[see attached diagram Q25_2.3.2_EPP_create_command_example.pdf]
Diagram : EPP client create command and server answer example
Description : This is a standard EPP client create command following RFC 5731. Parameters sent in the following example are domain name, period of registration, registrant identifier, administrative, technical and billing identifier, and auth_info password followed by standard EPP server create command answer compliant with RFC 5731. Parameters sent in the answer are result code, message, creation and expiry date, and client and server transaction ID.

Creation “with authorization code” enables the registry service provider to manage protected names or names under specific registration conditions. An authorization code is associated to three items (the registrar, the domain name and the holder nic-handle ) and is delivered outside the automated process through a manual process defined by a specific policy rule. The registry-generated authorization code must be present in the ʹdomain:authInfoʹ item of the creation request. No registrar-computed value is permitted.
In every case, domain creation proceeds through standard EPP command.

[see attached diagram Q25_2.3.2_SRS_authorisation_code.pdf]
Diagram : SRS authorisation code
Description : The EPP auth_info field that can usually be freely filled in by the registrar has a specific use for registration of reserved names : an authorisation_code is delivered through an out of band process and must be used in the create command for the answer to be successful.

= ʹupdateʹ =

The registry offers EPP ʹdomain:updateʹ command to :
* update the administrative, technical, registrant contacts of a domain name
* update the DNS and DNSsec configuration of a domain name
* update the status of a domain name or its auth_info

This command is also used to add or delete signed delegations (DS records), through a ʹsecDNS:updateʹ extension if DNSSEC operations are wanted and if the secDNS extension was chosen by the client at login.

When requested the status of domain name is changed to “pendingUpdate”.

= ʹdeleteʹ =

The whole deletion process (including redemption grace period and pending delete) of a domain name comes with a restoration mechanism (restore). This mechanism, based on RFC 3915, is applied to the deletion operation only.

The status of the domain name is switched to ʺpendingDeleteʺ for the total duration of the ʺredemption grace periodʺ and as long as the domain is not restored or totally deleted.

= ʹtransferʹ =

The registry offers standard EPP ʹdomain:transferʹ command to allow a change of registrar to the registrant.

A transfer can be initiated only by an incoming registrar and using the auth_info that the registrant has given him. This standard mechanism acts as a security and associates the triggering of transfer to the acceptance of the owner of the domain.
The transfer operation can be triggered only if the domain is not protected by a clientTransferProhibited lock.

The transfer implementation follows RFC 5730 section 2.9.3.4 and its lifecycle follow the inter registrar transfer policy as revised by the ICANN in 2008.

------------------------
2.4 - contact command

Postal addresses are managed as indicated in RFC 5731 with the following specific rules : only the type “loc” for postal addresses is accepted and only one element of type ʹcontact:postalInfoʹ can be indicated for the contact .

ʹdiscloseʹ parameters is implemented and enables to activate restricted publication in the RDDS.
The choice to activate restricted diffusion is made in compliance with the policy and the local rules of the TLD towards privacy law.

------------------------
2.5 - Return Codes

Some operations under normal working conditions of the SRS will answer with a 1000 return code. Otherwise, two different levels of return codes have been chosen according to the two different types of problems that can happen on the SRS :
* minor problems answer with Return code 1001 : Minor problems do not affect requests reception. This code indicates the command was taken into account but that its complete execution is delayed. The final result will be known later on and will be sent in a message placed in the notification queue of the concerned registrar(s).
* blocking problems answer with Return code 2400 “command failed” : no operations that transform a domain name can be taken into account.


------------------------
3 - Compliance to RFCs

The system has been launched compliant with RFCs. Mechanisms are in place to ensure that ongoing maintenance and new functional delivery stay compliant with RFCs.

------------------------
3.1 - Delivery process

The SRS evolutions are developed on the development environment.
The development process implies strict coding rules and use of shared best practices. Pair programming is standard practice. Unit test are developed prior to function development to ensure resiliency of the produced code.

Delivery process take place in four steps :
* 1st step : XML validation and RFC compliance is checked through automated tools. A 100% compliance signal must be received to be able to proceed to second step.
* 2nd step : delivery to the pre-production environment. The development is delivered on the preproduction environment. This environment is available for internal testing team. They proceed through a standard Operational Test which goes through a full lifecycle of a domain name. Specific tests are made on new functions in any.
* 3rd step : delivery to the sandbox environment. This sandbox environment is opened for registrar where they have two accounts to validate their clients before production activation.
* 4th step : the new release is delivered in production.

------------------------
3.2 - XML validation

EPP RFC compliance is reached through three mechanisms :
* a batch of unitary tests on each operation, each answer of the server being validated through the XSD schema.
* XML validation through perl XML::LibXML::Schema library
* fuzzy testing, by sending garbage input and checking error return codes.

------------------------
3.3 - Cross checking

EPP cross checking partnership is established with .at Registry operator to validate in sandbox environment prior to delivery in production through mutual agreement.


------------------------
4 - Specific extensions

------------------------
4.1 - Specific extension : DNSSEC

The EPP server provides the secDNS-1-1 extension as described in RFC 5910. Implementation specifications are as follows :
* The server only supports “the DS data interface” (ʹsecDNS:dsDataʹ); section 4.1 of RFC 5910, without information on the associated key (the ʹsecDNS:keyDataʹ element is not included); if information on the key is indicated the server will answer with a 2102 error code.
* DNSSEC elements are only accepted during an update operation request. If included during a create operation the server will answer with a 2103 error code.
* Each domain name can have up to 6 associated DS records : the number of elements ʹsecDNS:dsDataʹ present in the ʹsecDNS:addʹ section during an update operation is therefore limited in order to have the domain name’s final status with no more than 6 DS records.
* The maxSigLife attribute is not supported, its presence inside a client request will generate a 2102 error code.
* The urgent attribute is not supported, its presence inside a client request will generate a 2102 error code.

[see attached diagram Q25_4.1_EPP_xsd_dnssec_extension_schema.pdf]
Diagram : EPP xsd dnssec extension schema
Description : Registry service provider DNSsec EPP secDNS-1-1 extension is based on standard xsd schema as defined in RFC 5910.

------------------------
4.2 - Specific extension : IDN

No specific IDN extension has been used. The script used for the TLD is declared in the greetings and no further indication is needed in the following transaction. Usage is in full compliance with RFCs 5890, 5891, 5892, 5893, and 5894. This may be a pending situation : if a standard IDN extension was to be produced in the months to come it would be added to the EPP schema in order to deal more precisely with each specific language management policies.

----------------------
4.3. Specific extension : Sunrise period

Sunrise period is managed through a specific EPP extension. The sunrise registration workflow is described in Question 29 (Right Protection Mechanism).

The extension used is described below but will follow work in progress at the IETF initiated by Cloud Registry (draft-tan-epp-launchphase-01.txt). The xsd schema has been designed by AFNIC’s partner CORE and is fully in accordance with the draft. It could be modified before the launch if the IETF draft was to be accepted as an RFC with modifications.

AFNIC Registry extension is fully compatible with extension mechanism described in RFC 5730. It offers trademark holders a specific mapping to provide information related to trademarks. It also enables query function to keep the sunrise process transparent to everybody.

For illustration and further information purposes, please refer to the Q25_4.3_EPP_xsd_sunrise_extension_schema.pdf file attached (EPP XSD sunrise extension schema) which describes the registry back-end services provider’s EPP extension XSD schema used to deal with sunrise period. This schema is designed based on the work in progress at IETF, as initiated by Cloud Registry (draft-tan-epp-launchphase-01.txt). This extension is fully compatible with extension mechanism described in RFC 5730.

----------------------
4.3.1 New objects

application : to deal with multiple demands on same domain name. The server creates an application object corresponding to the request and assigns an identifier for the application and returns it to the client. This mapping defines an ʹlp:applicationIDʹ element which is used to specify an ID to this object.

phase : optional element ʹlp:phaseʹ to be used in case of multiple sunrise phases.

status : status of each application in link with internal state of the process of the application. The ʹlp:statusʹ values that can be used in order to process the applications are pending, invalid, validated, allocated, rejected. These statuses have to be mapped with the sunrise workflow described in Question 29 (Right Protection Mechanism).

claim : claim object contains the details needed to applicantʹs prior right to the domain name.
The ʹlp:claimʹ element has the boolean ʺpreValidatedʺ attribute, which indicates whether a third party validation agency has already validated the claim in case of inter connection with the IP clearing house.

Several child elements of the ʹlp:claimʹ element are defined :
* ʹlp:pvrcʹ, the Pre-Validation Result Code, is a string issued by a third-party validation agent. * ʹlp:claimIssuerʹ contains the ID of a contact object (as described in RFC 5733) identifying the contact information of the authority which issued the right (for example, a trade mark office or company registration bureau).
* ʹlp:claimNameʹ identifies the text string in which the applicant is claiming a prior right. * ʹlp:claimNumberʹ contains the registration number of the right (i.e. trademark number or company registration number).
* ʹlp:claimTypeʹ indicates the type of claim being made (e.g. trademark, symbol, combined mark,
company name).
* ʹlp:claimEntitlementʹ indicates the applicantʹs entitlement to the claim (i.e. owner or licensee).
* ʹlp:claimRegDateʹ contains the date of registration of the claim.
* ʹlp:claimExDateʹ contains the date of expiration of the claim.
* ʹlp:claimCountryʹ indicates the country in which the claim is valid.
* ʹlp:claimRegionʹ indicates the name of a city, state, province or other geographic region in which the claim is valid. This may be a two-character code from WIPO standard ST.3.

----------------------
4.3.2 command extensions

----------------------
4.3.2.1 EPP Query Commands

ʹinfoʹ command is the only extended query command.

In order to indicate that the query is meant for an application object, an ʹlp:infoʹ element is sent along with the regular ʹinfoʹ domain command.

The ʹlp:infoʹ element contains the following child elements :
ʹlp:applicationIDʹ, the application identifier for which the client wishes to query, and ʹlp:phaseʹ (optional), the phase the application is associated with.
If the query was successful, the server replies with an ʹlp:infDataʹ element along with the regular EPP ʹresDataʹ. The ʹlp:infData contains the following child elements:
* ʹlp:applicationIDʹ the application identifier of the returned application.
* ʹlp:phaseʹ (optional) the phase during which the application was submitted or is associated with.
* ʹlp:statusʹ (optional) status of the application.
* ʹlp:claimʹ (optional) one or more ʹlp:claimʹ elements.
If present, the ʹlp:claimʹ elements may contain the child elements as described above in the claim object description.

----------------------
4.3.2.2 EPP Transform Commands
There are three extended EPP transform commands : ʹcreateʹ, ʹdeleteʹ and ʹrenewʹ

----------------------
4.3.2.2.1 EPP ʹcreateʹ Command

The EPP ʹcreateʹ command is used to create an application. Additional information is required to submit a domain name application during a launch phase :
* ʹlp:phaseʹ (optional), the phase the application should be associated with
* ʹlp:claimʹ (optional) elements to substantiate the prior rights of the applicant.

When such a ʹcreateʹ command has been processed successfully, the EPP ʹextensionʹ element in the response contains a child ʹlp:creDataʹ element that identifies the registry launchphase namespace and the location of the registry launchphase schema. The ʹlp:creDataʹ element contains a child ʹlp:applicationIDʹ element, which informs the registrar about the application ID the server has assigned.

----------------------
4.3.2.2.2 EPP ʹupdateʹ Command

This extension defines additional elements to extend the EPP ʹupdateʹ command to be used in conjunction with the domain name mapping.
Registry policies permitting, clients may update an application object by submitting an EPP ʹupdateʹ command along with an ʹlp:updateʹ element to indicate the application object to be updated.
The ʹlp:updateʹ element contains the following child elements:
* ʹlp:applicationIDʹ the application identifier for which the client wishes to update.
* ʹlp:phaseʹ (optional) the phase during which the application was submitted or is associated with.

----------------------
4.3.2.2.3 EPP ʹdeleteʹ Command

Registry policies permitting, clients may withdraw an application by submitting an EPP ʹdeleteʹ command along with an ʹlp:deleteʹ element to indicate the application object to be deleted. The ʹlp:deleteʹ element contains the following child elements:
* ʹlp:applicationIDʹ the application identifier for which the client wishes to delete.
* ʹlp:phaseʹ (optional) the phase during which the application was submitted or is associated with.


------------------------
5 - Resources

Four categories of profiles are needed to run the Registry’s Technical Operations : Registry Operations Specialists (I), Registry Systems Administrators (II), Registry Software Developer (III) and Registry Expert Engineers (IV). These categories, skill set and global availability of resources have been detailed in Question 31 (Technical Overview of Proposed Registry) including specific resources set and organisation to provide 24⁄7 coverage and maintenance capacity.
Specific workload for EPP management is detailed below.

------------------------
5.1 - Initial implementation

The set up is operated on the pre-installed virtualization infrastructure. It implies actions by system, database and network administrators to create the virtual servers and install the applicative packages.

Then, developers, assisted by a senior staff member expert in internet technologies and RFCs apply proper configuration for the given TLD. Compliance is strictly tested.

The initial implementation effort is estimated as follows :

Database Administrator 0.10 man.day
Network Administrator 0.10 man.day
System Administrator 0.10 man.day
Software Developer 0.40 man.day
Software Engineer 0.80 man.day
------------------------
5.2 - On-going maintenance

On-going maintenance on the SRS includes integration of new policy rules, evolution of technology, bug fixing, infrastructure evolution, failover testing.

Although all the defined technical profiles are needed for such on-going maintenance operations, on a regular basis, it is mainly a workload handled by monitoring and development teams for alert management, new functional developments and RFC compliance checks, respectively.

The on-going maintenance effort per year is estimated as follows, on a yearly basis :

Operations Specialist 0.80 man.day
System Administrator 0.40 man.day
Software Developer 1.60 man.day
Software Engineer 0.40 man.day

26. Whois

Table of Contents

1 - General description
2 - Data access
2.1 Typology of accessible data
2.2 Profiles for data access control
3 - RDDS architecture
4 - RDDS infrastructure
5 - Rate limitation
6 - Reverse lookups
7 - Interconnectivity and synchronization with other systems
8 - Performance and scalability
9 - ICANN Bulk access compliance
10 - RFC compliance
11 - Resources
11.1 - Initial implementation
11.2 - On-going maintenance


------------------------
1 - General description

Registration Data Directory Service (RDDS) is one of the five vital functions of the Registry.
It is in direct connection with the database of the Shared Registration System and offers access to the public administrative and technical data of the registry.
The registry back-end solution implements data access through various interfaces that will be described below as well as their data access policies.

The main focus will be made on Whois on port 43 following RFC 3912 which is the main point of access.
The web Whois offers similar functionalities, is based on the same architecture and will be presented through screenshots.

The following description will provide full and detailed description of the architecture of the RDDS both from an application and from an infrastructure point of view.
This architecture is the same as the one used in production by AFNIC for .FR zone and has been fully functional for the last 15 years, with the ability to meet stringent SLAs as well as to scale from the management of a few thousands domain names in operations to over 2 million in late 2011.


------------------------
2 - Data access

When considering the data access services, we must address :
* the typology of accessible data
* access control : who can access what kind of data
* performance : guarantee of availability and performance for requesting data

Potential limitations to the systems will also be described.
To be able to maintain a good access to everybody (registrar, holders, outside world), our back-end solution provides multiple access with consistent role and access policies.

------------------------
2.1 Typology of accessible data

Data that can be accessed through the RDDS are mainly :
* contact data : holder, administrative, technical, billing
* domain data : domain name, status
* host data : name servers, IP addresses
* ephemeris : creation, expiration dates
* registrar data

These data are all described in the RFCs and fully compliant to the mapping of RFCs 5730 to 5734 and an example of standard port 43 output is given at the end of the present answer.

------------------------
2.2 Profiles for data access control

= Whois for registrars =

The main registrar access tool is our RDDS service accessible both on port 43 following specifications of RFC 3912 and through web access.
Both web and port 43 RDDS offer natively compliance with privacy law with a “restricted disclosure” flag if needed by the TLD. This option is activated through Extensible Provisioning Protocol (EPP) standard ʹdiscloseʹ parameters while creating or updating a contact and automatically understood by the whois server to anonymize the data.
This service is accessible both in IPv4 and IPv6.
RDDS access for registrar is rate limited to ensure performance. (see performance)

= Public whois =

RDDS access is also available on port 43 to everybody through a rate limited access to ensure performance. (see performance)

= Legal requirements =

AFNIC back end solution implements by default French privacy laws with opt-out holder personal data privacy.
This option can be deactivated if necessary to be compliant with the policy of the TLD.


------------------------
3 - RDDS architecture

= RDDS architecture =

RDDS is running on two load balanced front virtual servers directly connected to two databases : the production database for data access, and a rate-limiting service database which applies rate-limiting policies and store IP involved. This server implements token bucket algorithm to flatten traffic on the server.

The two front servers are load balanced using classical round robin implementation.

The network infrastructure is the same as described in the global architecture (referred to below) and no specific dedicated switch or router is to be considered as the rate limiting tool is an applicative one. A global description of the network infrastructure (switch and routers involved) can be found in answers to Question 32 (Architecture).

[see attached diagram Q26_3_RDDS_architecture_diagram.pdf]
Diagram : RDDS architecture diagram
Description : This diagram shows global interaction between Internet, DMZ and private network zones. Topology of network and servers is illustrated including dedicated IP address scheme and network flows.

= RDDS logical diagram =

Our robust infrastructure shows dual Internet Service Provider (ISP) connectivity both in Ipv4 and Ipv6 (Jaguar and RENATER), redundant firewall and switching infrastructure. This part of the architecture is mutualized for all TLDs hosted.

The networking architecture dedicates LAN for administration, backup and production.

Servers are hosted on different network zones : database for database, private for servers not visible on the internet and public for external servers visible on the DMZ. Dedicated zones are also set up for monitoring servers, administration servers or desktop and backup servers.
RDDS servers are directly on the public zone.
Each server is load balanced and the service is not impacted by the loss of one server, the capacity of each server being sized to be able to host the whole traffic.

Servers are fully dedicated to the .LECLERC TLD, based on a virtualized hardware infrastructure shared among up to an estimated number of 5 TLDs of comparable scale and use case.

= RDDS physical diagram =

The IP scheme used is the following :

2001:67c:2218:1::4:0⁄64 for IPv6 Internet homing
192.134.4.0⁄24 for Ipv4 Internet homing

Production LAN
192.134.4.0⁄24 for public network IP range
10.1.50.0⁄24, 10.1.30.0⁄24 for private network IP ranges distributed on the zones described above.

Backup LAN
172.x.y.0⁄24 : x is a different on each network zone. y is fixed to the value of the associated production LAN in the same zone (for example Private zone production LAN being 10.1.”50”.0⁄24, Private zone backup LAN is 172.16.”50”.0⁄24)

Administration LAN
172.z.y.0⁄24 : z is the value of x+1, x being the digit chosen for the corresponding Backup LAN in the same zone. y is fixed to the value of the associated production LAN in the same zone (for example Private zone production LAN being 10.1.”50”.0⁄24, Private zone administration LAN is 172.17.”50”.0⁄24)

Hot standby of the production database is automatically taken into account by the RDDS Oracle Transparent Network Substrate configuration. Therefore if the database are migrated in hot standby due to failure of part of the system, the Registration Data Directory Services (RDDS) access is automatically swapped to the new base.


------------------------
4 - RDDS infrastructure

In the following description “server” will refer to either a physical or a virtual server.
Due to very fast growth of performance in storage and processors technologies, the infrastructure described below could be replaced by more powerful one available at the time of the set up for the same cost.

It is important to note that at the applicative and system level, AFNIC’s SRS is fully dedicated to the .LECLERC TLD .

AFNIC has invested in very efficient VMWare Vsphere virtualization infrastructure. It provides a flexible approach to recovery both through quick activation of a new fresh server in case of local failure (cold standby) and through global failover to a mirrored infrastructure on another site.
This comes in addition to natural redundancy provided by the load balanced servers.

The RDDS is therefore hosted on virtualized infrastructure on the public zone (Demilitarized Zone - MZ) to the exception of the database, which presents very high rate of I⁄O (Input⁄Output), and is hosted on a dedicated physical infrastructure on the private zone.

The rate limiting database is hosted on one physical dedicated physical server. This server represents no failure point as a failure of the rate limiting system doesn’t affect the service (a standard uniform limitation is then applied instead of intelligent rate limiting).
The main database is the production database also used by the SRS and other registry vital functions and is described more in detail in Question 33 (Database Capabilities).

Databases are based on Oracle technologies. The main database is replicated logically on two sites. Full local recovery processes are in place in case of loss of integrity through the Oracle redolog functions which provides full recovery by replay of historized logged requests.

The whole RDDS service is located in the primary Tier 3 datacenter used by AFNIC in production, the
secondary datacenter serves as failover capacity. Continuity mechanisms at a datacenter level are described in Questions 34 (Geographic Diversity), 39 (Registry Continuity) and 41 (Failover testing).

The detailed list of infrastructures involved can be described as follows :

This infrastructure is designed to host up to an estimated number of 5 TLDs of comparable scale and use case.

= Virtual servers =

RDDS server : 2 servers
* Processor: 1 bi-core CPU
* Main memory: 16 GB of RAM
* Operating system: RedHat RHEL 6
* Disk space: 500 GB

= Data storage : see Question 33 (Database Capabilities) =

= Physical server =

Rate limiting database : 1 server
* Processor: 1 bi-core CPU
* Main memory: 8 GB of RAM
* Operating system: RedHat RHEL 6
* Disk space: 500 GB

Back up servers, backup libraries, Web whois server : mutualized with the global registry service provider infrastructure

= Additionnal infrastructure =

Failover, sandbox, preproduction infrastructure : 3 servers
* 1 bi-core CPU, 16 GB of RAM, RedHat RHEL 6, 500 GB


------------------------
5 - Rate limitation

To ensure resiliency of the RDDS a rate limitation mechanism is in place.
RDDS is largely used by various public users and registrars, some of them for domain name drop catching. Potentiality of heavy load on this service is very high.
Therefore a rate limitation is applied with threshold calculated from the level of activity expected in order not to penalize normal use of the service. A double level mechanism enables different threshold for identified IP (white list) from registrar and for the public access.

Rate limitation is directly implemented on the front end server.

Access is rate limited through token-bucket algorithms with rate-limiting IP data stored on a dedicated database.
Penalties are applied as follow :
* any IP : 7,200 request ⁄ 24 hour ⁄ IP.
* white listed IP for registrars : 86,400 requests⁄ 24 hour ⁄IP.


------------------------
6 - Reverse lookups

The web RDDS access offers advanced searchability capacities.
The following functions are available :

= Direct queries =

* Partial match query on domain name, administrative, technical, and billing contact name and address, registrant name and address, registrar name including all the sub-fields described in EPP (e.g., street, city, state or province, etc.).
* Exact match query on registrar id, name server name, and name server’s IP glue records
The result of direct queries is the object queried (contact, domain, ...)

= Reverse queries =

* Partial match query on domain name, administrative, technical, and billing contact name and address, registrant name and address, registrar name including all the sub-fields described in EPP (e.g., street, city, state or province, etc.).
* Exact match query on registrar id, name server name, and name server’s IP glue records including IPv6 queries.
The result of reverse queries is the list of objects of a given type linked with the result object (list of domains with a given contact result, or name server result,...)

This powerful tool is limited in access :
* Captcha system avoids scripting of the interface.
* Direct queries are open to every user but the number of result objects is limited to 1,000 answers for 1 query.
* Reverse queries can only be done by registrars on the extranet interface, and the number of result objects is limited to 10,000 answers for 1 query. The interface cannot be used more than 100 times a day.


------------------------
7 - Interconnectivity and synchronization with other systems

= SRS =

Data updated by the SRS are immediately visible in the RDDS with no further synchronisation needed. Rate limitation is applied both on SRS and RDDS service to avoid any load on the database. SRS and RDDS are partly in the same network zone, both RDDS servers and EPP SSL reverse proxies being in the public network zone (DMZ).

= Main database =

Hot standby of the production database is automatically taken into account by the RDDS Oracle Transparent Network Substrate configuration. Therefore if database are migrated in hot standby due to failure of part of the system, the RDDS service is automatically swapped to the new architecture.

= Rate limiting database =

No standby is implemented on the rate-limiting database. In case of failure, a standard global limitation is applied while, replacement of the database is operated.

= Monitoring =

Monitoring is operated through probes and agents scanning systems with a 5 minutes period. The monitoring system gets snmp data from all servers described in the RDDS architecture and also from dedicated Oracle monitoring agent for the database.
Hot standby is not implemented on monitoring agents.


------------------------
8 - Performance and scalability

The Registry’s RDDS offers high level production SLAs and derives from the branch of systems that have evolved over the last 12 years to successfully operate a set of french ccTLDs.

The Registry’s RDDS is used to publish .fr, .re, .yt, .pm, .tf, .wf TLDs information. It is used by more than 800 registrars in parallel managing more than 2 millions domain names and by a large user community.

AFNIC’s RDDS is designed to meet ICANN’s Service-level requirements as specified in Specification 10 (SLA Matrix) attached to the Registry Agreement.

As described in Question 31 (Technical Overview) in relation to each of the phases of the TLD’s operations, the following transaction loads are expected on the WHOIS servers : 123 queries⁄hour on average for both launch phase and on going operations.

AFNIC’s WHOIS systems can serve up to 10,000 requests⁄min on load balanced service to be compatible with the launch and growth scenario described in Question 31 (Technical Overview).

The targeted TLD objective being around 10,000 domain names with a provision for 123 queries⁄hour on average, this ensures that enough capacity is available to handle the launching period, as well as demand peaks and unexpected overhead.

Capacity planning indicators are set up to anticipate exceptional growth of the TLD.
Technologies used enables quick upgrade on all fields :
* Servers : virtual resizing to add CPUs or disk space if resource is available on the production ESX servers. If not, 2 spare additional ESX servers can be brought live if additional performance is needed.
* Servers (alternate) : additional servers can be added and taken into account immediately through dns round robin algorithm.
* Database : database capacity has been greatly oversized to avoid need of replacement of this physical powerful server. Precise capacity planning will ensure that sufficient delay will be available to acquire new server if needed. A threshold of 40% of CPU use or total storage capacity triggers alert for acquisition.


------------------------
9 - ICANN Bulk access compliance

The Registry Operator will provide both data escrow and ICANN bulk access in a same process.
Data escrow generates data on a daily basis. One file per week is kept for ICANN access to bulk data.


------------------------
10 - RFC compliance

The system has been launched compliant with RFCs. Mechanisms are in place to ensure that on going maintenance and new functional delivery stay compliant with RFCs.

= Delivery process =

The RDDS evolutions are developed on the development environment.
The development process implies strict coding rules and use of shared best practices. Pair programming is standard practice. Unit test are developed prior to function development to ensure resiliency of the produced code.

Delivery process take place in four steps :
* 1st step : RDDS validation and RFC compliance is checked through automated tools. A 100% compliance signal must be received to be able to proceed to second step.
* 2nd step : delivery to the pre-production environment. The development is delivered on the preproduction environment. This environment is available for internal testing team.
* 3rd step : delivery to the sandbox environment. This sandbox environment is opened for registrar where they have two accounts to validate their clients before production activation.
* 4th step : the new release is delivered in production.

= Format validation =

RDDS rfc compliance is reached through a specific RDDS checker which is use for non-regression test before each new release.

= Cross checking =

Whois cross checking partnership is established with .at Registry operator to validate in sandbox environment prior to delivery in production through mutual agreement.

= Whois Output =

Output of a whois query is 100% similar to the whois query example available in RFC 3912.


------------------------
11 - Resources

Four categories of profiles are needed to run the Registry’s Technical Operations : Registry Operations Specialists (I), Registry Systems Administrators (II), Registry Software Developer (III) and Registry Expert Engineers (IV). These categories, skillset and global availability of resources have been detailed in Question 31 (Technical Overview of Proposed Registry) including specific resources set and organisation to provide 24⁄7 coverage and maintenance capacity.
Specific workload for RDDS management is detailed below.

------------------------
11.1 - Initial implementation

The initial implementation effort is estimated as follows :

Database Administrator 0.10 man.day
Network Administrator 0.10 man.day
System Administrator 0.10 man.day
Software Developer 0.40 man.day
Software Engineer 0.20 man.day

------------------------
11.2 - On-going maintenance

On-going maintenance on the RDDS module includes mainly integration of new policy rules, privacy law evolutions, evolution of contracts, infrastructure evolution, failover testing.

Although all the defined technical profiles are needed for such on-going maintenance operations, on a regular basis, it is mainly a workload handled by monitoring and development teams for alert management and new functional developments, respectively.

The on-going maintenance effort per year is estimated as follows, on a yearly basis :

Operations Specialist 0.60 man.day
System Administrator 0.20 man.day
Software Developer 0.80 man.day
Software Engineer 0.40 man.day

27. Registration Life Cycle

Table of Contents

1 - Global description
2 - Data associated with a domain name
2.1 - Technical data
2.2 - Administrative data
3 - Full domain name lifecycle overview
4 - Basic create⁄update⁄delete life cycle
4.1 - create
4.2 - update
4.2.1 - technical update
4.2.2 - administrative update
4.2.3 - context update
4.3 - delete⁄restore
5 - Transfer
6 - Renewal and auto-renewal
7 - Grace period and refund
8 - Resources allocated
8.1 - Initial implementation
8.2 - On-going maintenance


------------------------
1 - Global description

Domain names represents the core technical part of the Domain Name System. The lifecycle of a domain name can have both technical impacts, when it relates to technical data associated with the domain name, and administrative impact when related to the registrant of the domain name.

The following diagrams and descriptions will bring detailed answers to the question of the lifecycle of the domain name in regards to both these aspects


------------------------
2 - Data associated with a domain name

To clearly understand the lifecycle of the domain name, we must first give an exhaustive description of the data involved in the various operations to be made.

------------------------
2.1 - Technical data

A domain name is a technical label used for Domain name resolution. To be effective, it is associated with nameservers -server hosting the configuration of the domain name -, IPv4 and IPv6 addresses - to identify on the network servers independently of the DNS, DNSsec signature information - delegation signer and cryptographic algorithm used-.
Less directly related to the technical basic configuration are :
* = clientHold = label : relates to the DNS or not DNS-publication status of the domain name.
* = auth_info = : a protection code linked with the domain and used by the owner to unlock some operations
* = client*Prohibited = : a list of status activated by the registrar to lock the domain name and prevent some operations
* = server*Prohibited = : a list of status activated by the registry service provider to lock the domain name and prevent some operations

------------------------
2.2 - Administrative data

A domain name has to be managed by his owner. Therefore it comes associated with a list of operational and administrative contacts that can be used to get in relation with the domain name owner or technical staff. The most important are administrative contact, technical contact, billing contact, and of course registrant contact. The last contact object is the registrar object which shows which registrar is in charge of domain name operations at the registry level.

Both these administrative and technical data are modified and used in the lifecycle and we will now describe this in detail.


------------------------
3 - Full domain name lifecycle overview

We have chosen to illustrate the registration lifecycle through a state diagram
This state diagram is joined as a separate file.

[see attached diagram Q27_3_global_lifecycle.pdf]
Diagram : Global Lifecycle
Description : Considering the wide range of the states and transition, the choice has been made to present a linear scenario going through all available operations. In this scenario, impact on registrar objects, registrant objects, domain objects, host objects are described at each step. Also statuses and forbidden operations at each step are indicated.
The following domain states have been introduced to describe the lifecycle major steps :
* registered : the domain name is registered, published in the Registration Data Directory Services (RDDS) but not in the DNS (clientHold label is set or there is no host information)
* active : the domain name is registered, published in the RDDS and in the DNS
redemption : the domain name is registered, published in the RDDS but not in the DNS. It will be - deleted if no action is taken by the registrar.
* locked : specific operations as transfer or delete have been forbidden by the registrar.
Impact on expiry dates has also been indicated though adequate formulas.

All aspects of the registration lifecycle are covered by standard Extensible Provisioning Protocol (EPP) RFCs and the EPP implementation is described in Question 25 (EPP).


------------------------
4 - Basic create⁄update⁄delete life cycle

The basic life cycle is described below without explanation of add grace period. The behavior of add grace period is described in chapter 7.

------------------------
4.1 - create

A domain name is created through a standard EPP domain:create command.
Administrative data linked with the creation are registrant contact, admin contact and technical contact, period before renewal.
Technical data linked with the creation are nameservers host objects, IP address for glue records, auth_info code.
The state of the domain name is REGISTERED if no host objects have been filled.
The state of the domain name is ACTIVE if host objects have been filled.
The state of the domain name can exceptionally be PENDING during the operation if a technical issue makes it asynchronous.
Otherwise this operation is real time and there is no delay elements to be considered.

Elements needed to create a domain are contacts (mandatory), host objects (optional) and auth_code (mandatory).
It can then be managed through domain:update commands.

------------------------
4.2 - update

domain:update commands enables a wide range of fields updates

------------------------
4.2.1 - technical update

Part of the fields of the update enables to update technical configuration. It enables nameserver, IP address, and dnssec options management. It is also used to remove a technical configuration..

The state of the domain name is REGISTERED if no host objects have been filled or have been removed.
The state of the domain name is ACTIVE if host objects have been filled.
The state of the domain name can exceptionally be PENDING during the operation if a technical issue makes it asynchronous.

------------------------
4.2.2 - administrative update

It is used to freely modify the various contacts linked with the domain name : administrative, technical, billing, and registrant contact.
The state of the domain name is not modified if only these fields are used.
The state of the domain name can exceptionally be PENDING during the operation if a technical issue makes it asynchronous.

------------------------
4.2.3 - context update

It is used by the client to modify status of the domain name and⁄or to modify the auth-info code linked with the domain name.
The status that can be changed are the following : clientHold, clientTransferProhibited, clientUpdateProhibited, clientDeleteProhibited, clientRenewProhibited.
The clientHold flag enables to remove the domain name from publication temporarily without deleting its technical configuration.
The other client*Prohibited statuses prevent the corresponding operation to be used.
The state of the domain name is REGISTERED if status is updated to clientHOLD.
The state of the domain name is LOCKED if status is updated to clientTransferProhibited.
The state of the domain name can exceptionally be PENDING during the operation if a technical issue makes it asynchronous.

------------------------
4.3 - delete⁄restore

Deletion can be used only by the registrar in charge of the domain name. It brings the domain name in Redemption grace period for a period of 30 days. It can be restored at any time during this period without any changes to the data. Deletion remove the domain name from the DNS publication service.
The state of the domain name is DELETED during redemption period.
The redemption period lasts 30 days. The domain is destroyed at the end of this period and a notification is sent.


------------------------
5 - Transfer

The transfer is described below without explanation of transfer grace period. The behavior of transfer grace period is described in chapter 7.

A transfer can be initiated only by an incoming registrar and using the auth_info that the owner has given him. This standard mechanism acts as a security and associates the triggering of transfer to the acceptance of the owner of the domain.
The transfer operation can be triggered only if the domain is not protected by a clientTransferProhibited lock.

[see attached diagram Q27_5_transfer_lifecycle.pdf]
Diagram : Transfer lifecycle
Description : Transfer operation includes various steps with impact on both outgoing and incoming registrars.

The outgoing registrar receive a transfer notification and can technically accept or reject the registrar change. Rejection can only be done in specific cases described in ICANN consensus policies.
If the outgoing registrar accepts the transfer, the operation is accepted immediately.
If the outgoing registrar does not validate the transfer, the operation is automatically accepted after 5 days.
If the outgoing registrar rejects the transfer, the operation is automatically cancelled and both registrars are notified of the rejection.
When the transfer succeeds, both registrars are notified through their EPP notification queue.

A reverse transfer can be asked by the losing registrar. The documents and cases where this cancellation of the transfer can be asked follow ICANN consensus policies on transfers. In case of disputes, the ICANN TDRP (Registrar Transfer Dispute Resolution Policy) is followed.

The state of the domain name is PENDING during the operation.


------------------------
6 - Renewal and auto-renewal

Domain:renew command is used by the registrar to increase the period of registration. If a domain name is registered for less than 10 years it can be renewed for a period up to 10 years at any time. The expiry date is updated.
The domain:renew command can be sent at any phase of the lifecycle (exception of add grace period is described in next chapter).

The registry lifecycle works with auto-renewal mechanisms. If a registrar do not renew or delete the name when it reaches the expiration date, a one year auto-renew period is added. As for other commands, a grace period is linked with this action (see chapter 7)

[see attached diagram Q27_6_grace_period_renew_autorenew_lifecycle.pdf]
Diagram : Grace Period renew⁄autorenew lifecycle
Description : This renew⁄autorenew lifecycle sum up impact of operations on domain name availability and statuses.


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7 - Grace period and refund

= Grace period =

The Grace Period mechanism refers to a specified period following an operation or change of status in which the operation may be reversed and a credit may be issued to the Registrar.

= Redemption Grace Period =

The Redemption Grace Period has been described in the delete⁄restore chapter.
During this period, domain name is still registered and can be reactivated through domain:restore command. No specific refund is linked with this period.

= Create - Add Grace Period (AGP) =

The implemented AGP is a five-day period following the domain:create command of a domain name.
The Registrar may delete the domain name at any time during this period and receive a full credit for the registration fee from the Operator. Once a domain name is deleted by the registry at this stage, it is immediately available for registration by any registrant through any Registrar.

= Auto-renew Grace Period =

The auto-renew add grace period is implemented. If during this 45 days period the domain is deleted by the incoming registrar, the ʹdomain:renewʹ command is refunded.

= Renew Grace Period =

The renew grace period is implemented. If during the 5 days period following explicit renew bye the registrar, the domain name is deleted, the renew is then refunded.

= Transfer Grace Period =

The transfer grace period is implemented. If during the 5 days period following a transfer the domain is deleted, the transfer is then refunded.

= AGP Limits Policy =

If too many deletions take place during the AGP from a given registrars, a financial penalty is applied.
The Add Grace Period Limits Policy allows a registrarʹs account to be debited each month for all AGP deletions that exceed the greater of either:
* 50 domain names, or
* 10% of net new adds for the previous month


------------------------
8 - Resources allocated

Four categories of profiles are needed to run the Registry’s Technical Operations : Registry Operations Specialists (I), Registry Systems Administrators (II), Registry Software Developer (III) and Registry Expert Engineers (IV). These categories, skillset and global availability of resources have been detailed in Question 31 (Technical Overview of Proposed Registry). Specific workload for this question is detailed below.

------------------------
8.1 - Initial implementation

The set up of a precise lifecycle implies actions by developers, assisted by a senior staff member expert in internet technologies and RFCs to apply proper configuration for the given TLD. Compliance is strictly tested.

The initial implementation effort is estimated as follows :

Software Developer 1.00 man.day
Software Engineer 1.00 man.day

------------------------
8.2 - On-going maintenance

On-going maintenance on the lifecycle includes mainly integration of new policy rules.
The on-going maintenance effort per year is estimated as follows, on a yearly basis :

Software Developer 1.00 man.day
Software Engineer 1.00 man.day

28. Abuse Prevention and Mitigation

Table of Contents

1 - Overview
2 - Definitions of what constitutes abuse in the TLD
2.1 - Spam
2.2 - Phishing
2.3 - Pharming
2.4 - Willful distribution of malware
2.5 - Fast flux hosting
2.6 - Botnet command and control
2.7 - Distribution of child pornography
2.8 - Unlawful content
3 - Whois abuse prevention policies
3.1 - Whois accuracy
3.1.1 - Syntactic and semantic registration constraints
3.1.2 - Verification tools
3.1.3 - Whois Data Reminder Policy (WDRP)
3.2 - Protection against unfair use of whois service
3.2.1 - Protection against Data mining
3.2.2 - Prevention of Unauthorized data modification
4 - Prevention from other abusive conducts
4.1 - DNSSEC (cache poisoning)
4.2 - Domain name sniping (grabbing)
4.3 - Domain name tasting
5 - Disposal of orphan glue records
6 - Single abuse point of contact
7 - Policies for handling complaints regarding abuse
7.1 - Abuse case response
7.2 - Rapid takedown policies
7.3 - Trademark abuse
8 - Resourcing plans

------------------------
1 - Overview

Our objective in answering question 28 is to provide a thorough explanation of our policies and procedures to minimize abuse registration and other activities that have a negative impact on internet users.

Protection of the internet users is a core value of the project and is key to insure the user experience as described in question 18 (b) iii. By implementing anti-abuse policy the registry will also contribute and protect the integrity, security and stability of the DNS.

In its online presentation of Registration Abuse Policy (RAP - available at http:⁄⁄www.icann.org⁄en⁄resources⁄policy⁄background⁄rap), ICANN offers the following definition:

“In general, the term covers a broad variety of illegal or illegitimate behaviors considered contrary to the intent and design of normal domain registration processes. Registration abuse often involves malicious actors trying to register in ways that avoid lawful authorities or conceal a registrantʹs identity. Registration abuse can also enable other kinds of abuses, such as phishing and spam.”

The .LECLERC registry is committed to create and implement policies and procedure that prevent abusive registrations and other activities that have a negative impact on internet users. According to the industry best practices presented in the Registration Abuse Policies Issues Report (ICANN 2008), the .LECLERC registry will offer a wide range of effective safeguards to prevent abusive uses of domain names such as phishing, spamming, and also unlawful or fraudulent actions. The registry operator will regularly update these policies and procedures in order to maximize its readiness to deal with new threats at all levels and new forms of abuse.

For that purpose, the .LECLERC registry will implement prevention and mitigations policies.

Prevention starts at the time of registration, Whois accuracy (2) is therefore the first and main focus of the .LECLERC prevention policies. The following answer describes in details the mechanisms in place to maximize Whois accuracy. Others mechanisms (3) will be implemented and described here, including management of orphan glue records (4).

A.C.D. Lec has chosen the single registrant model for the .LECLERC TLD. The set of domain names will be registered by the A.C.D. Lec in the name of A.C.D. Lec and after verification that the policies of registry are fully respected. The A.C.D. Lec will be able to delegate the use of domain names to members of the community. The community and the conditions for joining the community are clearly established in question 20. This first element minimizes the risk of domain names abuse and facilitates the implementation of takedown policies.

In addition to strong preventive measure against various forms of abuse, .LECLERC will implement mitigation policies to address actual case of abuse that may eventually occur. This answer will describe these mitigation measures in detail: single abuse point of contact (5), complaint handling policy and takedown procedures (6).

Resources allocated to handle prevention and mitigation (7) will be described at the end of this answer.

The .LECLERC registry will check the use of delegated domain name use on a random basis to ensure that all sites respect the values of the Movement as detailed in questions 18 and 20.


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2 - Definitions of what constitutes abuse in the TLD

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2.1 - Spam

The use of electronic messaging systems to send unsolicited bulk messages. The term applies to e-mail spam and similar abuses such as instant messaging spam, mobile messaging spam, and the spamming of Web sites and Internet forums. An example, for purposes of illustration, would be the use of email in denial-of-service attacks;


------------------------
2.2 - Phishing

The use of counterfeit Web pages that are designed to trick recipients into divulging sensitive data such as usernames, passwords, or financial data;


------------------------
2.3 - Pharming

The redirecting of unknowing users to fraudulent sites or services, typically through DNS hijacking or poisoning;


------------------------
2.4 - Willful distribution of malware

The dissemination of software designed to infiltrate or damage a computer system without the ownerʹs informed consent. Examples include, without limitation, computer viruses, worms, keyloggers, and trojan horses.


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2.5 - Fast flux hosting

Use of fast-flux techniques to disguise the location of Web sites or other Internet services, or to avoid detection and mitigation efforts, or to host illegal activities. Fast-flux techniques use DNS to frequently change the location on the Internet to which the domain name of an Internet host or name server resolves. Fast flux hosting may be used only with prior permission of PIR;


------------------------
2.6 - Botnet command and control

Services run on a domain name that are used to control a collection of compromised computers or ʺzombies,ʺ or to direct denial-of-service attacks (DDoS attacks);


------------------------
2.7 - Distribution of child pornography

Illegal Access to Other Computers or Networks: Illegally accessing computers, accounts, or networks belonging to another party, or attempting to penetrate security measures of another individualʹs system (often known as ʺhackingʺ). Also, any activity that might be used as a precursor to an attempted system penetration (e.g., port scan, stealth scan, or other information gathering activity).


------------------------
2.8 - Unlawful content

Any content that contravene public order according to French law and in particular to Law on the Freedom of the Press of 29 July 1881 (crimes against humanity apology⁄promotion or contestation, incitement to discrimination, hatred or violence).
*http:⁄⁄www.pir.org⁄why⁄anti_abuse_policy


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3 - Whois abuse prevention policies

------------------------
3.1 - Whois accuracy

RFC3912 specifies the Whois protocol and explain it as follows:

Whois is a TCP-based transaction-oriented query⁄response protocol that is widely used to provide information services to Internet users. While originally used to provide ʺwhite pagesʺ services and information about registered domain names, current deployments cover a much broader range of information services. The protocol delivers its content in a human-readable format.

Information about registered domain names is very sensitive. A Registry Operator shall insure the accuracy of the registrant contact information, including administrative, technical and billing contact details. In case of malicious or abusive activity, the Whois contact is usually the first and most important source of information. Whois accuracy is therefore a major step to counter malicious conducts. This information may be required by law-enforcement authorities to identify individuals and organizations responsible for domain names.

A.C.D. Lec, as single registrant agrees to give out the requested contacts in whois and to regularly verify (twice a year) the accuracy of its contact information.


------------------------
3.1.1 - Syntactic and semantic registration constraints

The .LECLERC registry is firmly committed to run a “thick-registry” with high quality of data. The first step to accuracy is achieved through syntactic and semantic checks which are being carried out at the time of registration of the domain name.

Standard EPP checks: a first set of tests is implemented in compliance with standards :
* RFC 5733, the Extensible Provisioning Protocol (EPP) Contact Mapping, requires contact data to contain a name, a city, a country code and an e-mail address in order to allow or perform a syntactically complete EPP request

Additional checks : the following syntactic checks are implemented :
* a test to ensure that the domain name has the proper number of labels (which is two for a traditional registry that allows only second level domains to be registered),
* a test to ensure that no hyphens occur in position 3 and 4 of any of the domainʹs U-labels (to protect ʺxn--ʺ and future ACE prefixes),
* a test to disallow hyphens at the beginning or end of the name,
* a test to find ASCII characters which are neither a letter, nor a digit or a hyphen,
* a test to find invalid IDN characters, i.e. characters not contained in any of the support IDN character tables
* a test to validate IP address format using the following scheme :
* 〈ipv4-addr〉 [1-255](\.[0-255]){3,3}
* 〈ipv6-addr〉 [a-fA-F0-9:]+(:〈ipv4-addr〉)?
* a test to validate telephone and mail format using the following scheme (with specific tests for fr numbers):
* 〈num tel〉 \+[1-9][0-9]{0,3}〈sp〉[1-9]([〈sp〉\.-]?[0-9])+
* 〈num tel fr〉 \+33〈sp〉[1-9]([〈sp〉\.-]?[0-9]){8}
* 〈e-mail〉 (([^\s\(\)\[\]\.\\〉〈,;:ʺ@]+(\.[^\s\(\)\[\]\.\\〉〈,;:ʺ@]+)*)|(ʺ[^ʺ@\\\r\n]+ʺ))@〈label〉(\.〈label〉)*

Additional checks : the following semantic checks are implemented :
* a test to disallow reserved names if authorisation code is not present
* a test to disallow registry reserved names if authorisation code is not present
* a test to disallow ICANN reserved names
* a test to disallow otherwise reserved or unsuitable names
* a test to ensure that at least one address element is given


------------------------
3.1.2 - Verification tools

This verification procedure is designed to guarantee the reliability and the accuracy of the Whois database.

A.C.D. Lec, as single registrant agrees to give out the requested contracts in whois and to regularly verify (twice a year) the accuracy of its contact information.

During the redemption period, the domain name can be reactivated with the same configuration. Once deleted, the domain name will re-enter the public domain and can be registered by a new applicant.


------------------------
3.1.3 - Whois Data Reminder Policy (WDRP)

In 2003, ICANN adopted the ʺWhois Data Reminder Policyʺ (WDRP, http:⁄⁄www.icann.org⁄en⁄registrars⁄wdrp.htm) which obliges ICANN-accredited registrars to send yearly Whois data reminder notices to registrants. These notices contain the Whois data currently on file for the respective domain, as well as instructions for the registrant about ways to correct the data if required. While the .LECLERC Registry does not intend to replicate this reminder procedure on the registry level, however TLD will comply with WDRP as expected from an ICANN accredited registrar.


------------------------
3.2 - Protection against unfair use of whois service

As stated above, Whois Service gives access to sensitive data, including contact details of registrants. The .LECLERC registry is committed to insure the protection of these data against abusive behaviors. Firstly, the .LECLERC registry will implement technical measures to prevent data mining on the Whois, such as automated collection of registrants’ email addresses, which may on their turn be used by third parties for the purposes of spamming. Secondly, the .LECLERC registry and its registry backend service provider, AFNIC, will deploy all necessary means to secure access to its database, specifically by implementing procedures in order to prevent Unauthorized Data Modifications. These procedures will reinforce the security of both EPP and Web-based access to Whois data.


------------------------
3.2.1 - Protection against Data mining

The .LECLERC registry database user commits to using the published data according to the laws and regulations in effect. Besides, the user shall respect the provisions of the French Data Protection Act. Violation of this act carries criminal penalties.

As the user is accessing personal data, he must refrain from any collection, misuse or any act that could lead to invasion of privacy or damaging the reputation of individuals.

The Registry can at any time filter the access to its services in case of malevolent use suspicions.

* Captcha: users shall pass a Captcha before access is granted to the web based RDDS.
* Rate-limiting: The registry has chosen limitation measures for the number of requests in order to prevent abuse in the use of personal data and to guarantee the quality of the service.
By a transparent parameter adjustment policy, the registry guarantees quality of service to occasional users and professionals. The rates and thresholds of this system are described in the registry use case of question Q26.
* White list: The white list mechanism offers specific access for registrars to port 43 of the whois considering that the incoming traffic must come from two pre-defined IP address. This white list access offers higher thresholds of rate limiting for the users.


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3.2.2 - Prevention of Unauthorized data modification

Data modification is managed through strict authentication and access policies.
* SSL⁄TLS protocol is used on all interfaces with clients (both EPP and web based SRS).
* a password policy is applied both on the password itself (minimum length, mandatory digits and non-alphanumerical characters), and on the length of the password
* use of an SSL client certificate pre-installed by the registry for EPP access.
* IP authentication limited to two addresses.


-------------------------
4 - Prevention from other abusive conducts

------------------------
4.1 - DNSSEC (cache poisoning)

One of the main authentication issue encountered on the DNS is the cache poisoning issue. This directly affects DNS service integrity without the attacker having to corrupt or modify data in the registry database.

The answer to this issue is implementation and deployment of DNSSEC. The registry operator already successfully manages DNSSEC-enabled zones: on september, 29th 2010, the .LECLERC registry back-end service provider, AFNIC, finished adding its 6 ccTLDs key materials (DS records) into the IANA root zone, ending with .FR after extensive tests with its other TLDs. Since then, related DNSSEC operations and monitoring are spread inside the organization, alongside all other standard day to day operations, so that DNSSEC is a core service enabled by default.


------------------------
4.2 - Domain name sniping (grabbing)

Domain name sniping refers to the practice of trying to re-register potentially interesting domain names immediately after they are deleted.

The .LECLERC registry prevents this practice in various ways. First, the fact that ACD is the one and only entity that can register a .LECLERC domain name has the consequence that no other member of the community or internet user can retrieve ownership of a domain name, even if it is available.

The .LECLERC Registry supports the Redemption Grace Period as proposed by ICANN and implements it in full compliance with RFC 3915 (ʺDomain Registry Grace Period Mapping for the Extensible Provisioning Protocol (EPP)ʺ). This greatly reduces the possibility of a domain name being “forgotten” by its registrant.


------------------------
4.3 - Domain name tasting

Domain name testing is a practice using the 5-days Add Grace Period (AGP) during which a newly created domain name may be deleted with a refund of the domain fee to check if the domain name is of interest or not. AGP is implemented and therefore domain name testing has to be dealt with. However, considering the fact that the .LECLERC is intended to be a single registrant-TLD, the chances that this process will be effectively used is rather limited, although the AGP is common practice and corresponds to the policies of almost all existing generic top-level domains.

In 2008, ICANN introduced the ʺAGP Limits Policyʺ (http:⁄⁄ www.icann.org⁄en⁄tlds⁄agp-policy-17dec08-en.htm) which addresses these issues resulting from the Add Grace Period. The [-TLD-] TLD, will fully implement this policy by restricting Add Grace Period refunds to registrars according to the limits specified by the policy.

The number of operations concerned are included in ICANN reports and related report columns are :
* number of AGP deletes (ʺdomains-deleted-graceʺ)
* number of exemption requests (ʺagp-exemption-requestsʺ)
* number of exemptions granted (ʺagp-exemptions-grantedʺ)
* number of names affected by granted exemption request (ʺagp- exempted-domainsʺ)


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5 - Disposal of orphan glue records

According to the definition found in the ʺSSAC Comment on the Orphan Glue Records in the Draft Applicant Guidebook”, a glue record becomes an ʺorphanʺ when the delegation point NS record (the ʺparent NS recordʺ) that references is removed while retaining the glue record itself in the zone. Consequently, the glue record becomes ʺorphanedʺ since it no longer has a parent NS record. In such a situation, registrars and registrants usually lose administrative control over the record, and the recordʹs attribution to a certain registrar may become unclear, which makes it a potential vector for abuse.

The glue record policy in effect for the .LECLERC avoids this situation entirely by disallowing orphan glue records altogether. This corresponds to policy #3 mentioned in section 4.3 (page 6) of the SSAC document mentioned above. The technical implementation within the .LECLERC registry and its associated zone generation process ensure this by implementing the following measures:
* Any host object which is a glue record can be created only if the domain name exists and is sponsored by the registrar creating the host;
* A domain name that has subordinate hosts can only be deleted when these hosts have been deleted. If these hosts are used in delegations for other domain names registered in .LECLERC, these delegations have to be removed to delete the host objects before the domain name can be deleted.
If the sponsoring registrar of the domain name is unable to remove these delegations (explicit refusal or inactivity from subordinate host’s registrar), a specific request can be submitted with the Registry Operator. Consequently, the Registry Operator will contact the domain name(s) registrar that has been used in order to delegate the host object(s) and ask them to remove these delegations. By default, registrars have 10 days to remove these delegations. Upon expiry of this term, the delegation is not removed, but the Registry Operator will directly deactivate the DNS configuration of the domain name(s) concerned. At the end of the procedure, the Registry Operator will contact the sponsoring registrar and confirm that the host object(s) and the domain name can be deleted.


-------------------------
6 - Single abuse point of contact

To avoid abusive registration practices, the .LECLERC registry will provide Internet users access to a Single Point of Contact on its website, where all kinds of abuse of the TLD or domain names registered therein can be reported.

This Single Point of Contact includes a contact web interface offering the possibility to internet users to report any abuse concerning a name registered in the .LECLERC registry.

Such contact web interface will be displayed on the registry’s website (phishing, spamming, trademark abuse etc.)

This single point of contact will enable a quicker and better management of complaints and resolution of any issues arising. Complaints will be addressed by filling out a form that will be made available on the .LECLERC registry web site.

This single point of contact will enable quicker and better management of complaints. Complaints will be addressed by filling out form through online services on the .LECLERC registry web site. An e-mail address and a phone number will also be available to inform the registry of any abuse of a domain name.

A specific employee will be in charge of handling these various complaints in a due time. All requests should be acknowledged and processed within one business day. According to the nature of the reported abuse (phishing, spamming, trademark abuse, etc.), an appropriate response and, where possible, even a resolution of the issue will be given by the .LECLERC registry.

Moreover, Internet users will be given access to all necessary information regarding remedies to abusive online conducts on the registry Single Point of Contact webpage. The single abuse point of contact webpage will also contain links to all the relevant organizations addressing these issues.


-------------------------
7 - Policies for handling complaints regarding abuse

------------------------
7.1 - Abuse case response

The registry will process each complaint within 24 hours (no later than ...) and will take all the necessary steps to offer a satisfying answer to the complainants:

Should immediate action be taken by competent authorities, the .LECLERC registry is committed to alert such authorities without delay. The .LECLERC registry will work closely with these authorities. This may include, but is not limited to the following cases:
* Court orders
* Inquiries from law enforcement bodies (e.g, OCLCTIC - The Office central de lutte contre la criminalité liée aux technologies de lʹinformation et de la communication is the French Police unit specialized in cybercrime)
* Anti-phishing groups (e.g, CERTs)


------------------------
7.2 - Rapid takedown policies

The .LECLERC registry agrees to monitor the use of domain names in its TLD and to put in place a rapid takedown policy so they can quickly react if one of the domain names is being used for malicious activities.

The “Rapid Takedown Policies” will determine the means that the .LECLERC Registry may use to detect malicious activities (internal monitoring, specific website...), to define the procedures to set up to notify the member using the domain name and then react proportionally to the abuse against the domain name as soon as possible (time windows to act to be defined depending on the kind of abuses and malicious activities). The “Rapid Takedown Policies” will also define the appeal means that members may use to against a measure taken by the registry. The .LECLERC Registry wants to put in place a long term notification system that will permit suspension of the tab contract signed between the using member and A.C.D. LEC if repeated cases of abuse are detected for the same member. The member may be add to a list of members to monitor.

Depending on the cases and the potential impact of the malicious activity on end-users, the registry will be allowed to notify the member using the domain name, remove it from the .LECLERC zone, delete it or transfer the domain name to another member of the community or recover the use of the domain name.

The .LECLERC Registry will take decision of deleting a domain name with extreme caution as it may have very important consequences.


------------------------
7.3 - Trademark abuse

Detailed and complete Information to right owners on effective safeguards protecting their rights will be provided on the registry website: URS and UDRP procedures.

The whole description of the procedures that the .LECLERC registry will put in place to ensure and protect the right holders will be detailed in Question 29.

The .LECLERC Registry will fully support and interact with the Trademark Clearinghouse. It will propose a Trademark Claims service, and provide support to UDRP, URS and PPDRP procedures.


-------------------------
8 - Resourcing plans

Thanks to the experience and investment of its Registry Service Providers, the .LECLERC Registry already supports technical abuse prevention and mitigation measures cited above at the time of writing. No additional engineering is required for these, which means that no special development resources will be needed.

Continuous audits and surveillance, as well as timely reactions to reports of malicious activity will be provided by the support staff on duty at the Registry operator.

It is estimated that 20 man hours per month will be spent in this area.

29. Rights Protection Mechanisms

Table of Contents

1 - Support and interaction with the trademark clearinghouse
2 - Sunrise: criteria, conflict resolution, mechanisms
3 - Compliance mechanisms, Ongoing registrations
4 - Dispute resolution, Mechanisms involving rights protection
4.1 - Trademark post-delegation dispute resolution procedure (PDDRP)
4.2 - Uniform domain name dispute resolution policy (UDRP)
4.3 - Uniform rapid suspension system (URS)
4.4 - Trademark claims service
5 - Technical implementation details
5.1 - Sunrise
5.1.1 - Sunrise EPP Extension Support
5.1.2 - Trademark Clearinghouse Support
5.1.3 - Support for Multiple Applications for the Same Domain Name
5.1.4 - Issue System
5.2 - Trademark claims
6 - Resourcing plan

------------------------
The .LECLERC registry is committed to ensure that it fully complies and meets or exceeds the requirements of ICANN in terms of security, stability and resiliency, malicious abuse issues, and rights protection in relation to the expansion of the generic Top Level Domain name space by devising and implementing mechanisms in line with ICANN’s Consensus Policies and Temporary Policies. The Registry will provide for an environment for .LECLERC where opportunities for abuse and malevolent conduct will be significantly reduced. To this end, the .LECLERC registry will, inter alia, implement and adhere to all rights protection mechanisms that may be mandated from time to time by ICANN, pursuant to Specification 7 of the Draft New gTLD Agreement.

The .LECLERC back-end registry service provider, AFNIC, has extensive knowledge, awareness and understanding of existing rights protection mechanisms designed by ICANN and it is a core objective of the .LECLERC registry to guarantee effective and timely implementation of said mechanisms. The registry will implement mechanisms designed to prevent abusive registrations, and identify and address the abusive use of registered domain names on an on-going basis.

The Registry Operator has closely followed ICANNʹs policy development in relation to the adequate and effective protection of the legal rights of trade mark owners in the new gTLD environment including the work of the Implementation Recommendation Team (ʺIRTʺ) formed by ICANNʹs Intellectual Property Constituency in accordance with the 6 March 2009 ICANN Board resolution at the request of the community seeking solutions for potential risks to trade mark holders in the implementation of new gTLDs.

As the .LECLERC registry back-end service provider, AFNIC is at the forefront of innovation in the domain name industry and has appointed for that purpose a committee of industry experts and academics (the Scientific Council) to help AFNIC to carry out its mission of innovation, security and high levels of service. AFNIC has contributed to the creation and the implementation of dedicated rights protection mechanisms for the ccTLDs AFNIC is responsible for and has a dedicated Legal and Registration Policy Department with pertinent skills and experience in the field of rights protection mechanisms to prevent abusive registrations and identify and address the abusive use of registered names on an on-going basis.

AFNIC will seek to deploy this experience in the .LECLERC with a view to ensuring effective, timely and sufficient protection of the rights of others.

------------------------
1 - Support and interaction with the trademark clearinghouse

The .LECLERC registry will ensure that it fully supports and interacts with the Trademark Clearinghouse, a central repository for information to be authenticated, stored, and disseminated, pertaining to the rights of trademark holders.
The Registry Operator will use the Trademark Clearinghouse to support its initial launch period rights protection mechanisms which will consist of, at a minimum, a Sunrise process and a Trademark Claims service.


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2 - Sunrise: criteria, conflict resolution, mechanisms

The .LECLERC registry will implement a Sunrise process for registration under .LECLERC for a minimum of 60 days and subject to the .LECLERC sunrise eligibility requirements (SERs). The Sunrise Registration Process will incorporate a Sunrise Dispute Resolution Policy (SDRP).

The Sunrise will be a time enabling A.C.D. Lec to register in priority the trademarks owned by the entities structuring the Movement LECLERC (see question 20), especially the trademarks belonging to A.C.D. Lec and GALEC. The domain names registered during this period must refer to a specific A.C.D. Lec brand and A.C.D. Lec or GALEC must provide proof of ownership of the trademark. Note that the single registrar model prevents other entities from registering .LECLERC domain names.

Each application will be individually validated to be sure that the registered domain names effectively correspond to a trademark.
When rejecting an application, the applicant will have one week to notify its intention to appeal the decision (before an independent Mediation and Arbitration Center).

The registry will also offer the Trademark Claims mechanism as provided by the Trademark Clearinghouse. This service will be provided not just for the Sunrise period, but also afterwards, during the Ongoing Registration Phase.


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3 - Compliance mechanisms, Ongoing registrations

Once in Ongoing (live) Registration mode, the .LECLERC Registry will perform ex-post validation based on Whois data and use of the domain name against the Registrations Policies.

Checks will be performed by a compliance agent both based on complaints and ex-officio, on statistically targeted random checks. Registry will start with 10 random cases per week, and will adapt the practices.

The number of checks is quite low as A.C.D. Lec assumes that the single registrant model choosen will decrease the number of potential abuses.

Checks will be carried both on compliance with .LECLERC policy and at the same time on registrant data accuracy.

In case the compliance agents discover a problem, either on policy compliance or on data accuracy, they will escalate the issue to the Compliance Officers, and the registrant will be contacted to clarify⁄correct the situation. If not solved in due time (30 days), the name will be put on registry hold for 30 additional days.

Unless the situation is corrected by this deadline, the name will be removed.


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4 - Dispute resolution, Mechanisms involving rights protection

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4.1 - Trademark post-delegation dispute resolution procedure (PDDRP)

The .LECLERC registry is committed to prevent the occurrence of the type of circumstances the PDDRP is designed to address. The registry completely understands the PDDRP mechanism and its rationale. and is fully committed to comply with the PDDRP and to implement decisions rendered under the PDDRP on an on-going basis and to fully cooperate in this respect.


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4.2 - Uniform domain name dispute resolution policy (UDRP)

Whilst the role of registry operators is rather limited under the UDRP as responsibility for implementation is primarily placed on registrars, the .LECLERC registry is committed to fully cooperate so as to ensure the implementation of all UDRP decisions.

The UDRP was adopted in 1999 by ICANN as a means of providing trademark owners with a relatively fast and cheap alternative dispute resolution mechanism to tackle cases of abusive use of their trademarks in a domain name. The Registry Operator will monitor and maintain a record of all UDRP decisions involving a domain name registered under the .LECLERC.

As the .LECLERC registry back-end registry service provider, AFNIC has implemented alternative dispute resolution procedures similar to the UDRP, including the so-called SYRELI procedure (Système de Résolution des Litiges), introduced on 21 October 2011 which applies to disputes involving domain names registered within the ccTLDs under the responsibility of AFNIC. This procedure is administered by AFNIC itself and illustrates how the .LECLERC registry back-end service provider is at the forefront of the protection of rights of third parties in the domain name space.

While compliance with the UDRP as it is now lies on registrars’ side, .LECLERC is not willing to accept non-compliant registrars preventing its implementation. In addition to ICANN-applied sanctions, .LECLERC will suspend the ability to register new domain names under .LECLERC forthose registrars failing to implement UDRP decisions.

In order to do this, .LECLERC will implement a specific complaints form for successful UDRP complainants facing non-cooperative registrars for .LECLERC names. Upon evidence of noncompliance the offending registrar would be prevented from registering any new .LECLERC name for three months after effective compliance the first time, and six months in case of repeated failures to comply. This measure is more effective and less harmful for the end users than termination, and will be included in the .LECLERC RRA.


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4.3 - Uniform rapid suspension system (URS)

In light of the anticipated expansion of the Domain Name System with the future delegation of new Top Level Domains, the IRT proposed in its Final Report of 29 May 2009 a new mechanism to tackle those ʺcases in which there is no genuine contestable issue as to the infringement and abuse that is taking placeʺ. This new rights protection mechanism was retained by ICANN and the .LECLERC registry is fully aware of all requirements of the URS and will implement decisions under the URS on an on-going basis and in a timely fashion.

Within 24 hours of receipt of the Notice of Complaint from the URS Provider by email, the .LECLERC registry will lock the disputed domain name thereby restricting all changes to the registration data, including transfer and deletion of the disputed domain name. In such instance, the disputed domain name will continue to resolve. Upon locking the disputed domain name, the Registry Operator will immediately send a Notice of Lock to the URS Provider.

The obligations placed on registry operators by the URS also include an obligation to suspend a disputed domain name immediately upon receipt of a determination in favour of a complainant, so that the disputed domain name remains suspended for the reminder of the registration period and does not resolve to the original website.


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4.4 - Trademark claims service

As the .LECLERC registry back-end registry service provider, AFNIC has experience of similar mechanisms through its use of the Clearing House for Intellectual Property (CHIP) which it appointed to manage the Claims Mechanisms for several of its ccTLDs (.pm, .re, .tf, .wf and .yt). When a domain name is registered in one of said ccTLDs that corresponds to a trademark in the CHIP database, an automatic notification is sent to the trademark owner registered in the CHIP and, provided that the email address of the domain name registrant or administrative contact is available, an additional notification will be sent to these email addresses as well.

his experience will prove very pertinent in the implementation of the Trademark Claims service for .LECLERC.
As noted above, .LECLERC intends to extend the Trademark Claims services beyond the mandatory Sunrise period, and into the Ongoing Registration phase. The purpose of this service is to provide clear notice to a prospective registrant of the scope of a particular trade mark ownerʹs rights in order to minimize the chilling effect on registrants (Trademark Claims Notice).
The .LECLERC registry will comply with all requirements set out by ICANN in relation to the Trademark Claims service and described in clause 6.1 of the Schedule relating to the Trademark Clearinghouse of the New gTLD Applicant Guidebook in its version of 11 January 2012 or in any subsequent version published by ICANN.


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5 - Technical implementation details

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5.1 - Sunrise

The .LECLERC Shared Registration System (SRS) fully supports the requirements of the above mentioned Sunrise policy and phases via features described in this section.

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5.1.1 - Sunrise EPP Extension Support

The system supports an EPP extension for submission of trademark data along with domain applications during launch phases such as Sunrise. Please refer to the answer to question 25 (Extensible Provisioning Protocol) for more information about the extension.

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5.1.2 - Trademark Clearinghouse Support

The .LECLERC Shared Registration System (SRS) is prepared for accessing APIs of the Trademark Clearinghouse in order to validate the trademark information submitted by the registrar during Sunrise.
In addition, the system also contains provisions to make use of the Trademark Clearinghouse APIs for providing a Trademark Claims Service (see below for more information on this service).

Since Trademark Clearinghouse Service Providers have not been assigned by ICANN at the time of writing, the concrete technical specifications for these APIs are not yet known. While basic provisions have been made in the .LECLERC Shared Registration System (SRS), the details will therefore have to be finalized once the Service Providers have been announced. As described below, respective developer resources are allocated to perform this task.


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5.1.3 - Support for Multiple Applications for the Same Domain Name

The .LECLERC Shared Registration System (SRS) is designed to maintain multiple domain objects representing the same domain name at a given point in time. This feature is required to store multiple applications for the same name during launch phases like Sunrise.

To distinguish between the various applications of the name in the database (as well as in external APIs), each application is assigned a unique domain ID. These domain IDs are returned to registrars in the responses to domain applications via EPP and may subsequently be used, among other things, to inquire an applicationʹs review status. Also, review results are reported back to registrars via poll messages carrying the unique domain ID. Registrars can utilize the ID to clearly associate results with their applications.

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5.1.4 - Issue System

When manual review of Sunrise applications is required, this typically involves a specific support team workflow that, among other things, consists of:
* storing application data in a database,
* making application data available to the support staff via a web interface back office tool (BO)
* assigning the task of reviewing applications for a certain domain name to a specific support member (for the purpose of clear responsibilities),
* having the application reviewed by the assigned person, who in the process may request additional information or documentation from the registrant,
* adds such documentation, as well as comments concerning the review, to the application,
* make a decision about the applicationʹs outcome or
* forward the task to a different support person with better insight or higher decision privileges (who may then make the final decision).

To support this workflow, the .LECLERC Shared Registration System (SRS) is equipped with a built-in Issue System integrated in its Back-Office (BO) that offers registry personnel a convenient web interface to review domain name applications and approve or reject them accordingly.

The Issue System:
* offers an SSL-secured web interface accessible by .LECLERC registry staff only;
* allows searching for applications by various criteria (e.g. domain name or current workflow⁄approval state);
* allows a registry support person to find newly submitted or otherwise unassigned applications and take responsibility for them;
* offers a two-level review workflow that allows the delegation of preselection tasks to the first level support staff, after which a final decision - if still required - can be made by second level personnel;
* conveniently displays all application details, including registrant information, the supplied trademark information, as well as the results of the verification of that trademark data with the Trademark Clearinghouse;
* fully tracks and documents application status and history, allowing for a complete audit in case of legal inquiries and
* is fully integrated with the registry backend, i.e. it automatically notifies the SRS about the reviewersʹ decisions and immediately activates the respective domain in case of an approval. The Issue System also triggers the creation of appropriate EPP poll message in order to keep registrars informed about the outcome of their applications.


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5.2 - Trademark claims

As stated above, beyond the requirements set forth by ICANN in Specification 7 of the Registry Agreement, the .LECLERC Registry will implement a continuous Trademark Claims Service to ensure that even after Sunrise, registrants are notified whenever their registered domain name potentially violates a trademark holderʹs rights as stored in the Trademark Clearinghouse. Likewise, the service makes the trademark holder aware of any domain registrations that potentially infringe on his trademarks registered with the Trademark Clearinghouse.

For the purpose of implementing this service, the .LECLERC SRS will interconnect with the API provided by the Trademark Clearinghouse Service Provider once its details are developed and publicized by ICANN.

When a match of a registered name is found via the API provided by the Trademark Clearinghouse, the Trademark Claims Service is supposed to provide clear notice to a prospective registrant of the scope of the mark holderʹs rights. The registrant will in turn be required to provide statement that:
* he received notification that the mark is included in the Trademark Clearinghouse,
* he received and understood the notice and,
* his registration and use of the requested domain name will not infringe on the rights that are subject of the notice.

The registrant will be directed to the Trademark Clearinghouse Database information referenced in the Trademark Claims Notice to enhance understanding of the Trademark rights being claimed by the trademark holder. Also, if a domain name is registered in the Clearinghouse, the Registry will, through an interface with the Clearinghouse, promptly notify the mark holders(s) of the registration after it becomes effective.


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6 - Resourcing plan

The .LECLERC registry, have an adequate level of resources on hand and committed to carry out the implementation of all rights protection mechanisms set out in this response to answer 29.

The .LECLERC registry has a substantial knowledge, awareness and experience of targeted and pragmatic rights protection mechanisms and will deploy this experience to (1) prevent abusive registrations, and (2) identify and address the abusive use of registered domain names on an on-going basis.

The .LECLERC registry considers training to be a major focus of its human resources management policy. It therefore applies an ambitious training policy in line with its strategy, with developments in domain name services and with technology. The Registry Operator is committed to the development of the skills of its employees and the promotion of their efficiency and adaptability by providing training to its employees in order to ensure the most efficient implementation of all right protection mechanisms.

The .LECLERC registry will ensure that suitable resources and staffing are available and committed as described further in answer to question 31.

More specifically, the Registry Operator has a legal⁄compliance department responsible for monitoring and addressing issues of abuse and infringement such as those highlighted above. The Registry Operatorʹs legal⁄compliance department consists of 2 people (part of the position description for the consumer support and technical support).

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

Table of Contents

1 - Background
2 - Organization of security
2.1 - The place of Security in AFNIC’s processes:
2.2 - Security Coordination
2.3 - Assignment of responsibilities
2.3.1 - Organizational chain of responsibility
2.3.2 - Relations with the authorities and groups of specialists
2.4 - Independent security review
2.5 - Relations with third parties
2.5.1 - Risk Management
2.5.2 - Security of sensitive areas
2.5.3 - Sensitive external sites
2.5.4 - Security assurances for domain name registrants
3 - Registry Asset Management
3.1 - Responsibilities for Registry assets
3.1.1 - Inventory of assets
3.1.2 - Qualification of support assets
3.1.3 - Ownership of assets
3.1.4 - Good and fair use of assets
3.2 - Guidelines for the classification of information
4 - Security related to human resources
4.1 - Roles and Responsibilities
4.2 - Background checks conducted on security personnel
5 - Physical and environmental security
5.1 - Secure areas
5.2 - Hardware security
6 - Operations Management and Telecommunications
6.1 - Procedures and responsibilities related to operations
6.2 - Scheduling and acceptance testing of the system
6.3 - Protection against malicious and mobile code
6.4 - Back-up
6.5 - Security management of network services
6.6 - Monitoring operation of the System
7 - Access Control
7.1 - Business requirements for access control
7.2 - Control of network access
7.3 - Control of access to operating systems
8 - Acquisition, development and maintenance of information systems
8.1 - Cryptographic measures
8.2 - Management of technical vulnerabilities
9 - Managing incidents related to information security
9.1 - Managing improvement and incidents related to information security
10 - IT Disaster Recovery Plan
11 - Integrating audits of the information system


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1 - Background

The security policy is designed to ensure proper management of the risks that may significantly impact the services provided, the contexts in which they are implemented, and the key personnel involved in operating the Registry. It also defines security level for the scalability ⁄ responsiveness to security incidents, the Registry Data integrity and the confidentiality of personal data of domain name owners.

The Information Security Policy is reviewed at least once a year.


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2 - Organization of security

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2.1 - The place of Security in AFNIC’s processes:

AFNIC has set up a Quality Management System (QMS) following the European Framework for QUality Management (EFQM) excellence model. It describes AFNIC’s activities as a series of business processes. Security Process called “ENSURE SECURITY AND BUSINESS CONTINUITY” is one of the cross-business-processes supporting process. It is designed to be compliant with the ISO 27001 norm.
Ensuring security and business continuity mainly consists in defining and controlling how to :
* Supervise the governance of security,
* Apply security measures into the concerned operational fields,
* Manage the risks that could negatively impact the Registries operations.

The implementation of the AFNICʹs ISMS (Information Security Management System) is performed in the framework of the Security process with a view to obtaining ISO 27001 certification by 2014.

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2.2 - Security Coordination

The overall responsibility for security rests with the CEO. He is assisted in this role by the AFNIC Security Manager (ASM).

Strategic supervision is ensured in a concerted manner by the AFNIC Security Council (ASC) chaired by the AFNIC CEO. The purpose of the ASC is to assist and ensure that the conditions are conducive to attaining the security objectives that fall within the scope of the current strategy.

The ASC further supports the development of security practices at AFNIC through the supporting of operation business functions in implementing security policies, business continuity plans, and staff awareness activities. In carrying out its assignment, the ASC may refer at any time to the Executive Management for advice or a decision on the security of AFNIC and TLD.

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2.3 - Assignment of responsibilities

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2.3.1 - Organizational chain of responsibility

The application of security measures to the SRS, DNS, Whois, and other Information Systems is the responsibility of the CTO (head of the Information Systems Division).
The implementation of security measures for staff and premises is the responsibility of the CFO.
The implementation of security measures with respect to legal obligations and registry policies is the responsibility of the Registryʹs Legal Affairs and Policies Director.
The application of security measures relating to damage to the Registryʹs image is the responsibility of the Marketing and Innovation Director.
All the collaborators must be aware of their responsibility concerning the security of resources and information they are accessing, manipulating, publishing.

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2.3.2 - Relations with the authorities and groups of specialists

AFNIC has an agreement with the French National Agency for the Security of Information Systems (ANSSI). Against this background, the two structures cooperate on security issues that may affect AFNIC services related to its Internet business and risk management in this area.
They cooperate within the framework of two programs on the resilience of the Internet in France :
* Cooperation between the operators of vitals infrastructures in order to improve their capacity to respond to major crises affecting several operators at the same time: the Internet critical services (IP Routing and DNS) are now included in the nomenclature;
* Cooperation to assess the resilience of the French .fr TLD and more generally all the TLDs operated by AFNIC for use by the public.

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2.4 - Independent security review

Security audits must be conducted by independent organizations twice a year on global and ⁄ or specific issues related to security.

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2.5 - Relations with third parties

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2.5.1 - Risk Management

Risk studies are conducted using the EBIOS methodology (Expression of Business needs and Identification of Security Objectives, in French). This method was designed in 1995 by the French National Agency for Information Security. It is currently used to identify the worst-case scenarios that could affect registry activity. That leads Afnic to design and apply mitigation measures to enhance the protection against these worst-case scenarios.

The control of the effectiveness and efficiency of mitigation measures is performed by the AFNIC’s Security Council all along the year.

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2.5.2 - Security of sensitive areas

All sensitive areas are under control. That means that access must be controlled and could be restricted to authorized personnel only.
Co-contractors may be requested to sign a confidentiality agreement if required by the sensitivity of information and data they need to know and⁄or use. They only have access to critical technical facilities if accompanied, and never work on production systems.

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2.5.3 - Sensitive external sites

All security must be applied to protect AFNIC’s resources on external sites. That can be made by private zones and access control to them managed by AFNIC itself.

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2.5.4 - Security assurances for domain name registrants

The Registry guarantees the following for registrants :
* The continuous availability of operations on its portfolio of domain names, in accordance with the SLA on the SRS
* The continuous availability of information related to the domain, on condition that the registrant uses the services provided to carry out the operations in question,
* The confidentiality of the registrantsʹ personal data (except where other special conditions apply related to the policy of the registry)
* The confidentiality of non-public data relating to the domain and ⁄ or its portfolio of domain names,
* The confidentiality of the transactions with the Registryʹs system,
* The integrity of the information related to its domain name,and published in the WHOIS and the DNS.


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3 - Registry Asset Management

The security of the registryʹs assets is ensured by the staff assigned to the registryʹs production operations and management activities.
Considering the network connectivity provided by third party, AFNIC’s property begins at the service delivery point.

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3.1 - Responsibilities for Registry assets

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3.1.1 - Inventory of assets

Assets used in the run of critical services are identified, qualified, and managed under the guidance of the present policy. Assets considered are staff, infrastructure, software, connectivity, data and providers.

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3.1.2 - Qualification of support assets

The assets contributing to the Services are classified in 3 main categories :
* Computer Systems and Telecommunications : Hardware and Software; Communications Channels; Outsourced Services;
* Organizations : Staff; Corporate departments;
* Physical locations for business : Offices; Hosting Datacenters;

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3.1.3 - Ownership of assets

Registry data belong to the Registry owner. They are subject to the rules of the contract with ICANN, plus the applicable legal and ⁄ or legislative rules depending on the context in which the registry is implemented

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3.1.4 - Good and fair use of assets

All the registry operations and services must be used by third party in accordance with the contractual rules defined by the owner and the operator of the TLD.

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3.2 - Guidelines for the classification of information

The data used or produced in the context of the Registry are classified in the 3 following categories :

= Critical information = : it can⁄must be accessed⁄showed only by accredited persons. Disclosure or alteration may result in significant damage but repairable.

= Reserved information = : Information is limited to persons, entities or authorized partners. Disclosure or alteration may result in significant harm.

= Internal Information = : Information is available to staff of AFNIC and authorized partners. Disclosure or alteration may perturb the normal functioning of the company, without lasting consequence.


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4 - Security related to human resources

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4.1 - Roles and Responsibilities

There are 2 categories of staff :

* Technical staff : These personnel have access to resources according to defined rights.
* Administrators in charge of administering production resources. They can access all the production resources and data.
* Technicians in charge of the operation, maintenance and monitoring of the production system. They have limited rights of access to production resources. They can access certain resources on request and when accompanied by an administrator.
* Experts in charge of the design and development of production resources. They only have access to the production resources on request and when accompanied by a technician and ⁄ or an administrator.
* Non-technical staff :
* Administrative staff and managers (excluding production).

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4.2 - Background checks conducted on security personnel

French law applies to all staff. The contract they sign with their employer contains sufficient provisions in terms of professionalism and ethics for the activity involving the TLD. Same rules are applicable a Data Center level.


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5 - Physical and environmental security

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5.1 - Secure areas

AFNIC production sites are secured at the means of access to them. The DATA CENTER sites must meet the standards of industrial and environmental security compatible with the constraints implied by their activity. The layout of the premises must be such that access is restricted only to authorized personnel at entry points selected and controlled by AFNIC.

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5.2 - Hardware security

The Data centers that host AFNIC services ensure at least Tier 3 levels of resilience.


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6 - Operations Management and Telecommunications

AFNIC controls the operation of all the resources used to deliver essential services with the exception, of course, of outsourced services such as certain DNS servers.
AFNIC operates dark fiber connections between its sites. The terminals are owned by AFNIC. They are operated by AFNIC personnel.

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6.1 - Procedures and responsibilities related to operations

Operating procedures are documented and kept up to date on the intranet of the IT team.
Access to the applications, servers and databases must be defined and kept up to date for each staff member.
Access privileges are defined in order to respect the security rules associated with the classification of information.
Operations related to DNSSEC are subject to even more stringent security regulations and require respecting the DPS procedure.

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6.2 - Scheduling and acceptance testing of the system

The test, pre-production and production phases must be clearly specified. Any production launch must be announced to the registrars at least 2 month before it applies.

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6.3 - Protection against malicious and mobile code

All the entry points to the production servers are filtered by the firewall, which applies the filtering policy common to all the procedures, whether they involve a human operator or an automated process.

Each development must apply security rules and recommendations on the development of application.
The Web access must be protected against the most common (Script kiddies, SQL injection …)

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6.4 - Back-up

Registry data are stored and secured using the real-time replication mechanisms of the production Database Management System (production DBMS).
In addition, a physical backup of the entire database must be performed at the same time as the back-up of the other components of the SRS.
To be compliant with the ICANN requirements, a data escrow deposit must be performed every day between 0:00 am end 12:00pm

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6.5 - Security management of network services

A strict partitioning into zones must be implemented in order to avoid interconnections between the external production, administration and backup networks.

Any internal and external attempts to access production servers must pass through a Firewall. They are recorded in a log file for later analysis. The detection of malicious code based on a regularly updated list must be performed at this level.

An intrusion detections system must be installed and running between firewall and production servers.

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6.6 - Monitoring operation of the System

Automated monitoring must be implemented. It must cover the hardware, software systems and production applications.
Any failure must be subject to a specific alert sent to the staff:
* on duty during office hours;
* on standby outside office hours;


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7 - Access Control

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7.1 - Business requirements for access control

Access to the information system requires prior identification and authentication. The use of shared or anonymous accounts must be avoided. Mechanisms to limit the services, data, and privileges to which the users have access based on their role at AFNIC and the Registry must be implemented wherever possible.

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7.2 - Control of network access

The internal network must be partitioned to isolate the different services and applications and limit the impact of incidents. In particular it is highly desirable to isolate services visible from the outside in a semi-open zone (DMZ). Similarly, access to the wireless network must be controlled and the network must be subject to appropriate encryption.

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7.3 - Control of access to operating systems

The production servers must be confined in secure facilities. Access must be restricted to authorized personnel only. The personnel in question are the members of the operating teams and their managers, IT personnel and those of the Security Manager.


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8 - Acquisition, development and maintenance of information systems

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8.1 - Cryptographic measures

Cryptographic measures must be implemented to secure the exchanges :
* between the workstations of technical staff and the access proxies to production servers;
* between the Registrars and the EPP server;
* between the DNS master servers and the resolution servers;
* to upload the records of the Escrow Agent.

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8.2 - Management of technical vulnerabilities

The technical configuration of hardware and software used must be subject to up to date documentation.
The changes in technical configurations must be constantly monitored and documented.
Security alerts involving updates and ⁄ or patches to production systems must be constantly monitored.
Application procedures must be documented and updated based on the recommendations of the designers of a component.


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9 - Managing incidents related to information security

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9.1 - Managing improvement and incidents related to information security

The crisis management procedure serves to mobilize at a sufficiently high echelon, all the appropriate levels of responsibility for taking decisions on the actions required to resolve the crisis and return to normal.
Each security incident must be analyzed under the cover of the Security Council and the recommendations, if any, are applied, checked and evaluated as required by the QMS.


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10 - IT Disaster Recovery Plan

The risk analysis must produce some inputs for the elaboration of a disaster recovery plan. That plan has to be established and regularly tested in order to maintain or recover Registry activity and make critical services available at the required SLA after an interruption or a crash of critical services of the Registry.


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11 - Integrating audits of the information system

Security audits are performed annually. They are launched on the initiative of the CTO or upon request from the ASC. They are carried out by independent bodies and relate to one or more of the essentials services of the Registry.

The ASC and the ASM control the implementation and the efficiency of these measures in the framework of S3 process (see section 2.1).



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