Name	Position
David J. Jurenka	Vice President
Douglas P. Paoletti	Secretary
Hans L. Schroeder	President

Name	Position
NFL Enterprises LLC	Not Applicable

Founded in 1920 as the American Professional Football Association, the National Football League (ʺNFLʺ) is the most popular American sports league. The NFL consists of thirty-two Member Clubs (i.e., teams), evenly divided between the American Football Conference and the National Football Conference, and spread out across the United States as follows: Arizona Cardinals, Atlanta Falcons, Baltimore Ravens, Buffalo Bills, Carolina Panthers, Chicago Bears, Cincinnati Bengals, Cleveland Browns, Dallas Cowboys, Denver Broncos, Detroit Lions, Green Bay Packers, Houston Texans, Indianapolis Colts, Jacksonville Jaguars, Kansas City Chiefs, Miami Dolphins, Minnesota Vikings, New England Patriots, New Orleans Saints, New York Giants, New York Jets, Oakland Raiders, Philadelphia Eagles, Pittsburgh Steelers, San Diego Chargers, San Francisco 49ers, Seattle Seahawks, St. Louis Rams, Tampa Bay Buccaneers, Tennessee Titans, and Washington Redskins.

Every year fans descend on stadiums in tremendous numbers to watch NFL teams compete, culminating in the annually most-watched television program in the United States - the Super Bowl. With an average attendance of over 65,000 fans during each game of the 2011-2012 season, the NFL is the best-attended domestic sports league in the world. Indeed, NFL fansʹ devotion to the Super Bowl (even if their favorite team is not playing) has set American television viewing records in recent years. Super Bowl XLVI in 2012 was the most-watched TV program in U.S. history with an approximate audience of 111.3M. The 2012 Super Bowl was also telecast in more than 200 countries and territories worldwide.

The NFLʹs popularity does not end with the final play in any given game. NFL fans support the League year-round wearing team-branded apparel, decorating their homes and offices with branded merchandise, reading the latest news about their favorite players and teams, and ʺdraftingʺ their favorite players to their fantasy football teams. The market for NFL-related merchandise, ticket sales, advertising, and other products and services is now regularly valued in the billions of dollars.

Not surprisingly, the NFLʹs online presence is also tremendously popular. The NFLʹs principal website, which is associated with the 〈nfl.com〉 domain name, launched in or around 1996. During the 2011 NFL season, the NFL received an average of 70 million unique visitors per month to its website, syndicated and mobile properties. NFL fans want the complete fan experience and the NFL seeks to provide it, whether at the stadium, at home, at the store, or on the internet.

The marks of the NFL have always been well-protected. The NFL and its affiliates hold several hundred trademark registrations worldwide that contain or consist of NFL or NATIONAL FOOTBALL LEAGUE. Additionally, the NFL and its thirty-two Member Clubs hold approximately ten thousand other trademark registrations, including U.S. federal, U.S. state, and foreign trademarks, for other related marks.

Unfortunately, with such high demand and a correspondingly large market, there is an ever-present risk of unscrupulous third-parties who will try to unlawfully benefit from the NFL and NFL fans. The NFL works tirelessly to prevent the sale of fraudulent NFL game tickets, counterfeit NFL merchandise and other related illegal activities. The NFL devotes significant resources to policing for counterfeits and taking enforcement actions against counterfeiters, often joining forces with law enforcement. For example, the U.S. Department of Immigration and Customs Enforcement (ʺICEʺ) recently partnered with the NFL and seized roughly $4.8 million in counterfeit merchandise, while the Ontario and Los Angeles international airports intercepted almost 11,000 fake NFL jerseys between September 2011 and January 2012 alone. Because many counterfeit ticket, video, and merchandise operations are occurring online, secure and authentic web transactions are becoming increasingly important to the NFL. The NFLʹs Vice President of Legal Affairs recently explained that counterfeiting websites ʺmimic the look and feel of official NFL team websites in order to dupe consumers into believing they are buying legitimate goods from authorized retailers.ʺ Similarly, unauthorized distribution of NFL game content, whether live or previously recorded, threatens the value of professional football to the NFL, broadcasters, digital media companies, business partners, and fans. As an NFL representative testified to the US House of Representatives Judiciary Committee, ʺ[e]very year the NFL invests substantially more time and resources dedicated to combating online piracy.ʺ

NFL Reg Ops LLC (ʺNFL Reg Opsʺ), the applicant, is an Affiliate of the NFL. We anticipate that the .nfl gTLD may provide an opportunity to create a more secure and authentic online experience for NFL fans, to introduce more Internet users to the sport of American football, and to protect the NFLʹs intellectual property rights. Whether purchasing game tickets, checking the latest scores and news, playing NFL-sponsored fantasy football with friends, buying NFL merchandise, watching NFL footage, or anything else fans seek to do in support of the NFL, we hope that an .nfl gTLD will immediately, clearly, and effectively let fans know that they are on an authentic and trustworthy NFL domain.

This .nfl gTLD application is a logical progression in the NFLʹs history of online innovation. Seeing an opportunity to enhance its online presence and build relationships with fans, advertisers, and other businesses, the NFL took over operation of NFL.com from third-party producers in 2007. The Senior Vice President of NFL Digital Media and Media Strategy explained: ʺIn a rapidly changing digital landscape, bringing NFL.com in-house provides us greater control of our valuable content and enables us to strategically build the site as a media asset. Fans can look forward to an even more entertaining, interactive and informative site built upon the expertise of the NFL and its other in-house media outlets such as NFL Network and NFL Films.ʺ The .nfl gTLD has the potential to integrate marketing, fan interaction, ticket sales, news, merchandise, and other services into a simple .nfl domain that communicates an assurance of a secure and authentic NFL experience. Similarly, it is possible that, over time, consumers may come to recognize and rely on an .nfl gTLD as a signpost of security and authenticity. Further, we hope that our decision to allow only NFL Reg Ops, its Affiliates and the NFLʹs Member Clubs to register and use .nfl domains may hasten recognition of the .nfl gTLD as an indication of security and authenticity.

We also look forward to the possibility that the .nfl gTLD may create new opportunities for each of the NFLʹs thirty-two Member Clubs, expand the reach of the NFL outside the United States, and generate innovative ways for the NFL to expand its charitable activities. An .nfl gTLD that is open only to a limited number of Registrants-specifically, NFL Reg Ops, its Affiliates, and the thirty-two NFL Member Clubs-may embody a simple and unique way to integrate team websites with that of the NFL, while still maintaining the highest NFL standards for content and security. Similarly, .nfl may enable the NFL to eventually reach foreign audiences more easily with the most relevant news, statistics, merchandise, and advertising in their own languages, potentially with domain names in their own language scripts. Finally, we hope that it will provide a new opportunity for the NFL to continue charitable and social campaigns to foster community citizenship and philanthropy.

How do you expect that your proposed gTLD will benefit registrants, internet users, and others?

We expect that the proposed .nfl gTLD will benefit Internet users and others by providing a more secure and authentic experience for fans and others who use NFL-related websites. We plan that NFL Reg Ops, its Affiliates, and the thirty-two NFL Member Clubs will be the only registrants of .nfl domain names. As explained in the section above, we expect the .nfl gTLD to benefit a variety of NFL and fan interests.

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

The goal of the proposed .nfl gTLD tracks its area of specialty: To have an opportunity to create a more secure and authentic online experience for NFL fans, to introduce more Internet users to American football, and to protect the NFLʹs intellectual property rights. The opportunity to combine many, if not all, existing NFL websites under a single, branded gTLD may assist us in providing a more satisfying, secure, and authentic online experience to NFL fans and NFL partners. It is our goal that the service levels and reputation of the .nfl gTLD be of the highest level - commensurate with the goodwill and reputation of the world-famous NFL brand.

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

Worldwide, there are no sports teams or leagues currently utilizing team or league specific TLDs. The introduction of an .nfl gTLD clearly changes the status quo. An .nfl registry has the potential to give fans, Internet users, and business partners a new and unique portal dedicated to all of the different NFL online offerings, all in a more secure online environment to communicate to users that the online NFL experience is safe and authentic.

An .nfl gTLD also adds differentiation to the current space because we anticipate that the only registrants and users of the .nfl gTLD will be NFL Reg Ops, its Affiliates, and the NFLʹs thirty-two Member Clubs. Restricting registration and use of the .nfl gTLD may also provide a new platform for innovation. For instance, it may allow us to create a simple and user-friendly second-level domain name hierarchy for fans, Affiliates, and others to easily reach team, ticket, advertising, news, live content, charitable, merchandise, and interactive pages. And, of course, an .nfl gTLD will enable the NFL to continue its history of innovation and unique user experiences in ways not yet known.

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

We want NFL fans, our Affiliates, and business partners, as well as general Internet users, to expect that they can rely on and trust NFL websites. Accordingly, we hope that the .nfl gTLD will provide the opportunity to create a more secure and authentic online experience for NFL fans, to introduce more Internet users to American football, and to protect the NFLʹs intellectual property rights. These goals would apply regardless of whether an Internet user is trying to purchase tickets or merchandise, seeking NFL news, checking the standings of his⁄her fantasy football team, or watching videos of his⁄her favorite games.

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

NFL Reg Ops intends to adopt and carry out policies for the registration and use of .nfl domain names. We will revise and update these policies (a) in accordance with our interests and those of our Affiliates and the NFL Member Clubs; and (b) as needed to comply with requirements of ICANN Consensus Policies and Temporary Policies. These policies cover eligibility requirements for registration and use of .nfl domain names, what .nfl domains may be registered, and how .nfl domains may be used.

As stated previously, it is anticipated that only the Applicant, its Affiliates, and the thirty-two NFL Member Clubs (the ʺEligible .nfl Registrantsʺ) will be permitted to register and use .nfl domain names. Before any .nfl domain name is registered, we will confirm that the potential registrant is one of the Eligible .nfl Registrants.

All .nfl domain names will be registered in the name of the Eligible .nfl Registrant. No .nfl domain name will be transferred, assigned, or licensed to any third party that is not an Eligible .nfl Registrant.

Further, we will ensure that each .nfl domain name meets the following criteria:

1. It is not the label ʺEXAMPLEʺ - either at the second level or any other level in which we may allow registrations.
2. All domain names must be at least three characters long, unless we reach a specific agreement with a government and country-code manager to use a two-character domain or our proposal to allow registration and use of such names based on implementation of measures to avoid confusion with the corresponding country codes is approved.
3. No .nfl domain name may be longer than 63 characters.
4. All .nfl domain names shall consist only of the letters a-z, the digits 0-9, and a hyphen.
5. .nfl domain names shall not start or end with a hyphen, but must start and end with an alphanumeric character.
6. Hyphens will not be included in the third and fourth position unless they represent valid internationalized domain names in their ASCII encoding (tagging).
7. No protected country or territory name shall be used, as contained in the internationally recognized lists set forth in Specification 5 to the New gTLD Registry Agreement, unless the NFL reaches agreement with the applicable government(s) or pursuant to review and approval by ICANNʹs Governmental Advisory Committee and ICANN.
8. No domain name can match any ICANN-reserved strings.

The .nfl registry will support Internationalized Domain Names (ʺIDNʺ) at the second level.

All .nfl domain names shall be used solely for purposes that are, in our judgment and discretion, consistent with our business interests. No .nfl domain name shall be used in a way that knowingly infringes any third-party intellectual property rights.

All WHOIS data for all .nfl will be complete and accurate.

v. Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users? If so, please describe any such measures.

NFL Reg Ops, its Affiliates, and the thirty-two NFL Member Clubs, recognize that privacy is an important issue to users of existing NFL websites and potential future .nfl websites. NFL Reg Ops is a corporation organized in the United States, and will comply with all applicable data collection and privacy laws. Moreover, we intend to fully comply with the Personal Data obligations outlined in Section 2.17 of the new gTLD Registry Agreement.

Privacy protection measures may potentially include: (1) use of appropriate levels of encryption; (2) compliance with the EU Safe Harbor framework as set forth by the United States Department of Commerce regarding the collection, use, and retention of data from the European Union (see http:⁄⁄www.export.gov⁄safeharbor⁄); (3) regular testing procedures; (4) opt-in opportunities to receive third party offers; (5) restricted access to personal information to those who need it to do their jobs; and, among others, (6) the ability for website users to correct, update, or remove personal data.

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

We anticipate that we will conduct outreach and communications in a way and scale consistent with the objectives, standards and policies described in this gTLD application.

What operating rules will you adopt to eliminate or minimize social costs (e.g., Time or financial resource costs, as well as various types of consumer vulnerabilities)? What other steps will you take to minimize negative consequences imposed upon consumers?

We believe that our operation of a TLD registry that is limited to NFL Reg Ops, its Affiliates, and the thirty-two NFL Member Clubs is unlikely to have any social costs and negative consequences. We expect that our decision to limit the .nfl registry to a small and well-defined set of registrants will eliminate or minimize any social costs and negative consequences that may exist in a more open registry.

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

Because only NFL Reg Ops, its Affiliates, and the thirty-two NFL Member Clubs will be permitted to register and use .nfl domains, we do not expect that there will be multiple applications for specific domain names. As such, there will not be multiple applications for which any resolution will be necessary.

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

We anticipate that domains within the .nfl registry will not be sold or marketed to the general internet community. Because of this limited universe of registrants, we do not intend to implement any registration incentives.

iii. Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases.

Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.

We are committed to the registration terms contained in the Registry Agreement, including Section 2.10. Because we do not anticipate selling domains within the .nfl registry, we currently do not intend to make contractual commitments regarding length of registration or price escalations.

NFL Reg Ops LLC (ʺNFL Reg Opsʺ) shall follow the advice of ICANNʹs Governmental Advisory Committee and adhere to the requirements set forth in Specification 5 of the Registry Agreement by initially reserving from registration at no cost the country and territory names that appear on the following internationally recognized lists:

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

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

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

23.1 Introduction

NFL Reg Ops LLC (ʺNFL Reg Opsʺ) has elected to partner with Neustar, Inc. (ʺNeustarʺ) to provide back-end services for the .nfl registry. In making this decision, NFL Reg Ops recognized that Neustar already possesses a production-proven registry system that can be quickly deployed and smoothly operated over its robust, flexible, and scalable world-class infrastructure The existing registry services will be leveraged for the .nfl registry. The following section describes the registry services to be provided.

23.2 Standard Technical and Business Components

Neustar will provide the highest level of service while delivering a secure, stable and comprehensive registry platform. NFL Reg Ops will use Neustarʹs Registry Services platform to deploy the .nfl registry, by providing the following Registry Services (none of these services is offered in a manner that is unique to .nfl:

- Registry-Registrar Shared Registration Service (SRS)
- Extensible Provisioning Protocol (EPP)
- Domain Name System (DNS)
- WHOIS
- DNSSEC
- Data Escrow
- Dissemination of Zone Files using Dynamic Updates
- Access to Bulk Zone Files
- Dynamic WHOIS Updates
- IPv6 Support
- Rights Protection Mechanisms
- Internationalized Domain Names (IDN).

The following is a description of each of the services.

23.2.1 SRS

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

23.2.2 EPP

The .nfl registry will use the Extensible Provisioning Protocol (EPP) for the provisioning of domain names. The EPP implementation will be fully compliant with all RFCs. Registrars are provided with access via an EPP API and an EPP based Web GUI. With more than 10 gTLD, ccTLD, and private TLDs implementations, Neustar has extensive experience building EPP-based registries. Additional discussion on the EPP approach is presented in the response to Question 25.

23.2.3 DNS

NFL Reg Ops will leverage Neustarʹs world-class DNS network of geographically distributed nameserver sites to provide the highest level of DNS service. The service utilizes ʺAnycastʺ routing technology, and supports both IPv4 and IPv6. The DNS network is highly proven, and currently provides service to over 20 TLDs and thousands of enterprise companies. Additional information on the DNS solution is presented in the response to Questions 35.

23.2.4 WHOIS

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

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

23.3.5 DNSSEC

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

23.2.6 Data Escrow

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

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

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

23.2.7 Dissemination of Zone Files using Dynamic Updates

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

23.2.8 Access to Bulk Zone Files

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

23.2.9 Dynamic WHOIS Updates

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

23.2.10 IPv6 Support

The .nfl registry will provide IPv6 support in the following registry services: SRS, WHOIS, and DNS⁄DNSSEC. In addition, the registry supports the provisioning of IPv6 AAAA records. A detailed description of IPv6 is presented in the response to Question 36.

23.2.11 Required Rights Protection Mechanisms

NFL Reg Ops will provide all ICANN required Rights Mechanisms including:

- Trademark Claims Service
- Trademark Post-Delegation Dispute Resolution Procedure (PDDRP)
- Registration Restriction Dispute Resolution Procedure (RRDRP)
- UDRP
- URS
- Sunrise service.
More information is presented in the response to Question 29.

23.2.12 Internationalized Domain Names (IDN)

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

23.3 Unique Services

NFL Reg Ops will not be offering services that are unique to .nfl.

23.4 Security or Stability Concerns

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

24.1 Introduction

NFL Reg Ops LLC (ʺNFL Reg Opsʺ) has partnered with Neustar, Inc. (ʺNeustarʺ), an experienced TLD registry operator, for the operation of the .nfl Registry. NFL Reg Ops is confident that the plan in place for the operation of a robust and reliable Shared Registration System (SRS) as currently provided by Neustar will satisfy the criteria established by ICANN.
Neustar built its SRS from the ground up as an EPP-based platform and has been operating it reliably and at scale since 2001. The software currently provides registry services to five TLDs (.BIZ, .US, TEL, .CO, and .TRAVEL) and is used to provide gateway services to the .CN and .TW registries. Neustarʹs state-of-the-art registry has a proven track record of being secure, stable, and robust. It manages more than 6 million domains, and has over 300 registrars connected today.
The following describes a detailed plan for a robust and reliable SRS that meets all ICANN requirements including compliance with Specifications 6 and 10.

24.2 The Plan for Operation of a Robust and Reliable SRS

24.2.1 High-level SRS System Description

The SRS to be used for .nfl will leverage a production-proven, standards-based, highly reliable and high-performance domain name registration and management system that fully meets or exceeds the requirements as identified in the new gTLD Application Guidebook.

The SRS is the central component of any registry implementation and its quality, reliability and capabilities are essential to the overall stability of the TLD. Neustar has a documented history of deploying SRS implementations with proven and verifiable performance, reliability and availability. The SRS adheres to all industry standards and protocols. By leveraging an existing SRS platform, NFL Reg Ops is mitigating the significant risks and costs associated with the development of a new system. Highlights of the SRS include:

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

24.2.2 SRS Systems, Software, Hardware, and Interoperability

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

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

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

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

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

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

24.2.3 SRS Design

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

- Protocol Layer
- Business Policy Layer
- Database.

Each of the layers is described below.

24.2.4 Protocol Layer

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

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

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

24.2.5 Business Policy Layer

The Business Policy Layer is the ʺbrainʺ of the registry system. Within this layer, the policy engine servers perform rules-based processing as defined through configurable attributes. This process takes individual transactions, applies various validation and policy rules, persists data and dispatches notification through the central database in order to publish to various external systems. External systems fed by the Business Policy Layer include backend processes such as dynamic update of DNS, WHOIS and Billing.

Similar to the EPP protocol farm, the SRS consists of a farm of application servers within this layer. This design ensures that there is sufficient capacity to process every transaction in a manner that meets or exceeds all service level requirements. Some registries couple the business logic layer directly in the protocol layer or within the database. This architecture limits the ability to scale the registry. Using a decoupled architecture enables the load to be distributed among farms of inexpensive servers that can be scaled up or down as demand changes.

The SRS today processes over 30 million EPP transactions daily.

24.2.6 Database

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

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

24.2.7 Number of Servers

As depicted in the SRS architecture diagram above, Neustar operates a high availability architecture where at each level of the stack there are no single points of failures. Each of the network level devices runs with dual pairs as do the databases. For the .nfl registry, the SRS will operate with 8 protocol servers and 6 policy engine servers. These expand horizontally as volume increases due to additional TLDs, increased load, and through organic growth. In addition to the SRS servers described above, there are multiple backend servers for services such as DNS and WHOIS. These are discussed in detail within those respective response sections.

24.2.8 Description of Interconnectivity with Other Registry Systems

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

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

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

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

24.2.9 WHOIS External Notifier

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

24.2.10 DNS External Notifier

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

24.2.11 Billing External Notifier

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

24.2.12 Data Warehouse

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

24.2.13 Frequency of Synchronization between Servers

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

24.2.14 Synchronization Scheme (e.g., hot standby, cold standby)

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

24.2.15 Compliance with Specification 6 Section 1.2

The SRS implementation for .nfl is fully compliant with Specification 6, including section 1.2. EPP Standards are described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. Extensible Provisioning Protocol or EPP is defined by a core set of RFCs that standardize the interface that make up the registry-registrar model. The SRS interface supports EPP 1.0 as defined in the following RFCs shown in Table 24-1.

Additional information on the EPP implementation and compliance with RFCs can be found in the response to Question 25.

24.2.16 Compliance with Specification 10

Specification 10 of the New TLD Agreement defines the performance specifications of the TLD, including service level requirements related to DNS, RDDS (WHOIS), and EPP. The requirements include both availability and transaction response time measurements. As an experienced registry operator, Neustar has a long and verifiable track record of providing registry services that consistently exceed the performance specifications stipulated in ICANN agreements. This same high level of service will be provided for the .nfl Registry. The following section describes Neustarʹs experience and its capabilities to meet the requirements in the new agreement.

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

Neustarʹs ability to commit and meet such high performance standards is a direct result of its philosophy towards operational excellence. See response to Question 31 for a full description of their philosophy for building and managing for performance.

24.3 Resourcing Plans

The development, customization, and on-going support of the SRS are the responsibility of a combination of technical and operational teams, including:

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

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

The necessary resources will be pulled from the pool of operational resources described in detail in the response to Question 31. Neustarʹs SRS implementation is very mature, and has been in production for over 10 years. As such, very little new development related to the SRS will be required for the implementation of the .nfl registry. The following resources are available from those teams:

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

The resources are more than adequate to support the SRS needs of all the TLDs operated by Neustar, including the .nfl registry.

25.1 Introduction

NFL Reg Ops LLCʹs (ʺNFL Reg Opsʺ) back-end registry operator, Neustar, has over 10 years of experience operating EPP based registries. It deployed one of the first EPP registries in 2001 with the launch of .biz. In 2004, .biz was the first gTLD to implement EPP 1.0. Over the last ten years Neustar has implemented numerous extensions to meet various unique TLD requirements. Neustar will leverage its broad experience to ensure NFL Reg Ops is provided with an unparalleled EPP-based registry. The following discussion explains the EPP interface that will be used for the .nfl registry. This interface exists within the protocol farm layer as described in Question 24 and is depicted in Figure 25-1 attached.

25.2 EPP Interface

Registrars are provided with two different interfaces for interacting with the registry. Both are EPP based, and both contain all the functionality necessary to provision and manage domain names. The primary mechanism is an EPP interface to connect directly with the registry. This is the interface registrars will use for most of their interactions with the registry.

However, an alternative web GUI (Registry Administration Tool) that can also be used to perform EPP transactions will be provided. The primary use of the Registry Administration Tool is for performing administrative or customer support tasks.
The main features of the EPP implementation are:

-Standards Compliance: The EPP XML interface is compliant to the EPP RFCs. As future EPP RFCs are published or existing RFCs are updated, Neustar makes changes to the implementation keeping in mind any backward compatibility issues.

-Scalability: The system is deployed keeping in mind that it may be required to grow and shrink the footprint of the Registry system for a particular TLD.

-Fault-tolerance: The EPP servers are deployed in two geographically separate data centers to provide for quick failover capability in case of a major outage in a particular data center. The EPP servers adhere to strict availability requirements defined in the SLAs.

-Configurability: The EPP extensions are built in a way that they can be easily configured to turn on or off for a particular TLD.

-Extensibility: The software is built ground up using object oriented design. This allows for easy extensibility of the software without risking the possibility of the change rippling through the whole application.

-Auditable: The system stores detailed information about EPP transactions from provisioning to DNS and WHOIS publishing. In case of a dispute regarding a name registration, the .nfl Registry can provide comprehensive audit information on EPP transactions.

-Security: The system provides IP address based access control, client credential-based authorization test, digital certificate exchange, and connection limiting to the protocol layer.

25.3 Compliance with RFCs and Specifications

The registry-registrar model is described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. As shown in Table 25-1, EPP is defined by the core set of RFCs that standardize the interface that registrars use to provision domains with the SRS. As a core component of the SRS architecture, the implementation is fully compliant with all EPP RFCs.

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

Neustar has a long history of providing excellent service that exceeds all performance specifications. The SRS and EPP interface have been designed to exceed the EPP specifications defined in Specification 10 of the Registry Agreement and profiled in Table 25-2. Evidence of Neustarʹs ability to perform at these levels can be found in the .biz monthly progress reports found on the ICANN website.

25.3.1 EPP Toolkits

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

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

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

25.3 Proprietary EPP Extensions

The .nfl registry will not include proprietary EPP extensions. Neustar has implemented various EPP extensions for both internal and external use in other TLD registries. These extensions use the standard EPP extension framework described in RFC 5730. Table 25-3 provides a list of extensions developed for other TLDs. Should the .nfl registry require an EPP extension at some point in the future, the extension will be implemented in compliance with all RFC specifications including RFC 3735.

The full EPP schema to be used in the .nfl registry is attached in the document titled ʺEPP Schema.ʺ

25.4 Resourcing Plans

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

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

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

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

26.1 Introduction

NFL Reg Ops LLC (ʺNFL Reg Opsʺ) recognizes the importance of an accurate, reliable, and up-to-date WHOIS database to governments, law enforcement, intellectual property holders and the public as a whole and is firmly committed to complying with all of the applicable WHOIS specifications for data objects, bulk access, and lookups as defined in Specifications 4 and 10 to the Registry Agreement. .nflʹs back-end registry services provider, Neustar, has extensive experience providing ICANN and RFC-compliant WHOIS services for each of the TLDs that it operates both as a Registry Operator for gTLDs, ccTLDs and back-end registry services provider. As one of the first ʺthickʺ WHOIS registry operators in the gTLD space, Neustarʹs WHOIS service has been designed from the ground up to display as much information as required by a TLD and respond to a very stringent availability and performance requirement.

Some of the key features of .nflʹs solution include:

-Fully compliant with all relevant RFCs including 3912

-Production proven, highly flexible, and scalable with a track record of 100% availability over the past 10 years

-Exceeds current and proposed performance specifications

-Supports dynamic updates with the capability of doing bulk updates

-Geographically distributed sites to provide greater stability and performance

-In addition, .nflʹs thick-WHOIS solution also provides for additional search capabilities and mechanisms to mitigate potential forms of abuse as discussed below. (e.g., IDN, registrant data).

26.2 Software Components

The WHOIS architecture comprises the following components:

-An in-memory database local to each WHOIS node: To provide for the performance needs, the WHOIS data is served from an in-memory database indexed by searchable keys.

-Redundant servers: To provide for redundancy, the WHOIS updates are propagated to a cluster of WHOIS servers that maintain an independent copy of the database.

-Attack resistant: To ensure that the WHOIS system cannot be abused using malicious queries or DOS attacks, the WHOIS server is only allowed to query the local database and rate limits on queries based on IPs and IP ranges can be readily applied.

-Accuracy auditor: To ensure the accuracy of the information served by the WHOIS servers, a daily audit is done between the SRS information and the WHOIS responses for the domain names which are updated during the last 24-hour period. Any discrepancies are resolved proactively.

-Modular design: The WHOIS system allows for filtering and translation of data elements between the SRS and the WHOIS database to allow for customizations.

-Scalable architecture: The WHOIS system is scalable and has a very small footprint. Depending on the query volume, the deployment size can grow and shrink quickly.

-Flexible: It is flexible enough to accommodate thin, thick, or modified thick models and can accommodate any future ICANN policy, such as different information display levels based on user categorization.

-SRS master database: The SRS database is the main persistent store of the Registry information. The Update Agent computes what WHOIS updates need to be pushed out. A publish-subscribe mechanism then takes these incremental updates and pushes to all the WHOIS slaves that answer queries.

26.3 Compliance with RFC and Specifications 4 and 10

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

Table 26-1 attached describes Neustarʹs compliance with Specifications 4 and 10.

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

26.4 High-level WHOIS System Description

26.4.1 WHOIS Service (port 43)

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

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

26.4.2 Web Page for WHOIS queries

In addition to the WHOIS Service on port 43, Neustar provides a web based WHOIS application (www.whois.nfl). It is an intuitive and easy to use application for the general public to use. WHOIS web application provides all of the features available in the port 43 WHOIS. This includes full and partial search on:

-Domain names
-Name servers
-Registrant, Technical and Administrative Contacts
-Registrars

It also provides features not available on the port 43 service. These include:

1. Redemption Grace Period calculation: Based on the registryʹs policy, domains in pendingDelete can be restorable or scheduled for release depending on the date⁄time the domain went into pendingDelete. For these domains, the web-based WHOIS displays ʺRestorableʺ or ʺScheduled for Releaseʺ to clearly show this additional status to the user.

2. Extensive support for international domain names (IDN)

3. Ability to perform WHOIS lookups on the actual Unicode IDN

4. Display of the actual Unicode IDN in addition to the ACE-encoded name

5. A Unicode to Punycode and Punycode to Unicode translator

6. An extensive FAQ

7. A list of upcoming domain deletions

26.5 IT and Infrastructure Resources

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

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

The WHOIS service uses HP BL 460C servers, each with 2 X Quad Core CPU and a 64GB of RAM. The existing infrastructure has 6 servers, but is designed to be easily scaled with additional servers should it be needed.
Figure 26-1 attached depicts the different components of the WHOIS architecture.

26.6 Interconnectivity with Other Registry System

As described in Question 24 about the SRS and further in response to Question 31, ʺTechnical Overviewʺ, when an update is made by a registrar that impacts WHOIS data, a trigger is sent to the WHOIS system by the external notifier layer. The update agent processes these updates, transforms the data if necessary, and then uses messaging oriented middleware to publish all updates to each WHOIS slave. The local update agent accepts the update and applies it to the local in-memory database. A separate auditor compares the data in WHOIS and the SRS daily and monthly to ensure accuracy of the published data.

26.7 Frequency of Synchronization between Servers

Updates from the SRS, through the external notifiers, to the constellation of independent WHOIS slaves happens in real-time via an asynchronous publish⁄subscribe messaging architecture. The updates are guaranteed to be updated in each slave within the required SLA of 95%, less than or equal to 60 minutes. Please note that Neustarʹs current architecture is built towards the stricter SLAs (95%, less than or equal to 15 minutes) of .BIZ. The vast majority of updates tend to happen within 2-3 minutes.

26.8 Provision for Searchable WHOIS Capabilities

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

-Domain name

-Registrar ID

-Contacts and registrantʹs name

-Contact and registrantʹs postal address, including all the sub-fields described in EPP (e.g., street, city, state or province, etc.)

-Name server name and name server IP address

-The system will also allow search using non-Latin character sets which are compliant with IDNA specification.
The user will choose one or more search criteria, combine them by Boolean operators (AND, OR, NOT) and provide partial or exact match regular expressions for each of the criterion name-value pairs. The domain names matching the search criteria will be returned to the user.

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

Figure 26-2 attached shows an architectural depiction of the new service.

To mitigate the risk of this powerful search service being abused by unscrupulous data miners, a layer of security will be built around the query engine which will allow the registry to identify rogue activities and then take appropriate measures. Potential abuses include, but are not limited to:

-Data Mining
-Unauthorized Access
-Excessive Querying
-Denial of Service Attacks

To mitigate the abuses noted above, Neustar will implement any or all of these mechanisms as appropriate:

-Username-password based authentication
-Certificate based authentication
-Data encryption
-CAPTCHA mechanism to prevent robo invocation of Web query
-Fee-based advanced query capabilities for premium customers.

The searchable WHOIS application will adhere to applicable privacy laws and policies of the .nfl registry.

26.9 Resourcing Plans

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

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

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

27.1 Registration Life Cycle

27.1.1 Introduction

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

27.1.2 Domain Lifecycle - Description

The registry will use the EPP 1.0 standard for provisioning domain names, contacts and hosts. Each domain record is comprised of three registry object types: domain, contacts, and hosts

Domains, contacts and hosts may be assigned various EPP defined statuses indicating either a particular state or restriction placed on the object. Some statuses may be applied by the Registrar; other statuses may only be applied by the Registry. Statuses are an integral part of the domain lifecycle and serve the dual purpose of indicating the particular state of the domain and indicating any restrictions placed on the domain. The EPP standard defines 17 statuses, however only 14 of these statuses will be used in the .nfl registry per the defined .nfl business rules.

The following is a brief description of each of the statuses. Server statuses may only be applied by the Registry, and client statuses may be applied by the Registrar.

-OK - Default status applied by the Registry.
-Inactive - Default status applied by the Registry if the domain has less than 2 nameservers.
-PendingCreate - Status applied by the Registry upon processing a successful Create command, and indicates further action is pending. This status will not be used in the .nfl registry.
-PendingTransfer - Status applied by the Registry upon processing a successful Transfer request command, and indicates further action is pending.
-PendingDelete - Status applied by the Registry upon processing a successful Delete command that does not result in the immediate deletion of the domain, and indicates further action is pending.
-PendingRenew - Status applied by the Registry upon processing a successful Renew command that does not result in the immediate renewal of the domain, and indicates further action is pending. This status will not be used in the .nfl registry.
-PendingUpdate - Status applied by the Registry if an additional action is expected to complete the update, and indicates further action is pending. This status will not be used in the .nfl registry.
-Hold - Removes the domain from the DNS zone.
-UpdateProhibited - Prevents the object from being modified by an Update command.
-TransferProhibited - Prevents the object from being transferred to another Registrar by the Transfer command.
-RenewProhibited - Prevents a domain from being renewed by a Renew command.
-DeleteProhibited - Prevents the object from being deleted by a Delete command.

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

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

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

27.2 Registration States

27.2.1. Domain Lifecycle - Registration States

As described above the .nfl registry will implement a standard domain lifecycle found in most gTLD registries today. There are five possible domain states:

-Active
-Inactive
-Locked
-Pending Transfer
-Pending Delete.

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

27.2.2 Active State

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

27.2.3 Inactive State

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

27.2.4. Locked State

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

27.2.5 Pending Transfer State

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

27.2.6 Pending Delete State

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

27.3 Typical Registration Lifecycle Activities

27.3.1 Domain Creation Process

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

1. Contact objects are created in the SRS database. The same contact object may be used for each contact type, or they may all be different. If the contacts already exist in the database this step may be skipped.

2. Nameservers are created in the SRS database. Nameservers are not required to complete the registration process; however any domain with less than 2 name servers will not be resolvable.

3. The domain is created using the each of the objects created in the previous steps. In addition, the term and any client statuses may be assigned at the time of creation.

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

27.3.2 Update Process

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

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

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

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

27.3.4 Renew Process

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

27.3.5 Transfer Process

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

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

To transfer a domain from one Registrar to another the following process is followed:

1. The gaining (new) Registrar submits a Transfer command, which includes the AuthInfo code of the domain name.

2. If the AuthInfo code is valid and the domain is not in a status that does not allow transfers, the domain is placed into pendingTransfer status

3. A poll message notifying the losing Registrar of the pending transfer is sent to the Registrarʹs message queue

4. The domain remains in pendingTransfer status for up to 120 hours, or until the losing (current) Registrar Acks (approves) or Nack (rejects) the transfer request

5. If the losing Registrar has not Acked or Nacked the transfer request within the 120 hour timeframe, the Registry auto-approves the transfer

6. The requesting Registrar may cancel the original request up until the transfer has been completed.

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

27.3.6 Deletion Process

A domain may be deleted from the SRS using the EPP Delete operation. The Delete operation will result in either the domain being immediately removed from the database or the domain being placed in pendingDelete status. The outcome is dependent on when the domain is deleted. If the domain is deleted within the first five days (120 hours) of registration, the domain is immediately removed from the database. A deletion at any other time will result in the domain being placed in pendingDelete status and entering the Redemption Grace Period (RGP). Additionally, domains that are deleted within five days (120) hours of any billable (add, renew, transfer) transaction may be deleted for credit.

27.4 Applicable Time Elements

The following section explains the time elements that are involved.

27.4.1 Grace Periods

There are six grace periods:

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

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

27.4.2 Add-Delete Grace Period

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

27.4.3Renew-Delete Grace Period

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

27.4.4 Transfer-Delete Grace Period

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

27.4.5 Auto-Renew-Delete Grace Period

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

27.4.6 Auto-Renew Grace Period

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

27.4.7 Redemption Grace Period

The RGP is a special grace period that enables Registrars to restore domains that have been inadvertently deleted but are still in pendingDelete status within the Redemption Grace Period. All domains enter the RGP except those deleted during the AGP.

The RGP period is 30 days, during which time the domain may be restored using the EPP RenewDomain command as described below. Following the 30-day RGP period, the domain will remain in pendingDelete status for an additional five days, during which time the domain may NOT be restored. The domain is released from the SRS at the end of the 5 day non-restore period. A restore fee applies and is detailed in the Billing Section. A renewal fee will be automatically applied for any domain past expiration.

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

27.5 State Diagram

Figure 27-1 attached provides a description of the registration lifecycle.

The different states of the lifecycle are active, inactive, locked, pending transfer, and pending delete. Please refer to section 27.1.1 for detail description of each of these states. The lines between the states represent triggers that transition a domain from one state to another.

The details of each trigger are described below:

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

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

27.5.1 EPP RFC Consistency

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

27.6 Resources

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

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

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

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

28.1 Abuse Prevention and Mitigation

NFL Reg Ops and its registry service provider, Neustar, understand that preventing and mitigating abuse and malicious conduct in the .nfl TLD is a weighty and critical responsibility. NFL Reg Ops will leverage Neustarʹs extensive experience in establishing and implementing registration policies to prevent and mitigate abusive and malicious domain activity within the proposed .nfl space.

A responsible domain name registry works towards the eradication of abusive domain name registrations and malicious conduct, including, but not limited to, those resulting from:

-Illegal or fraudulent actions
-Spam
-Phishing
-Pharming
-Distribution of malware
-Fast flux hosting
-Botnets
-Distribution of child pornography
-Online sale or distribution of illegal pharmaceuticals.

By taking an active role in researching and monitoring botnets that use fast-flux DNS, NFL Reg Opsʹ partner, Neustar, has developed the ability to efficiently work with various law enforcement and security communities to begin a new phase of mitigation of these types of threats.

Policies and Procedures to Minimize Abusive Registrations

A registry must have the policies, resources, personnel, and expertise in place to combat such abusive DNS practices. Neustar, NFL Reg Opsʹ registry services provider, has taken a prominent role in preventing such abusive practices and is one of the few registry operators that has developed and implemented an active ʺdomain takedownʺ policy. NFL Reg Ops and believe that combating DNS abuse is important in protecting registrants.

Removing the domain name from the zone before it can cause harm is often the best preventative measure for thwarting certain malicious conduct such as botnets and malware distribution. Because removing a domain name from the zone will stop all activity associated with it, including websites and e-mail, a zone removal decision should follow a thorough and documented process, culminating in a determination that the domain name at issue threatens the security and stability of the registry or the Internet.

Abuse Point of Contact

As required by the Registry Agreement, NFL Reg Ops will establish and publish on its website a single abuse point of contact responsible for addressing inquiries from law enforcement and the public related to malicious and abusive conduct in the .nfl TLD. NFL Reg Ops will also provide this information to ICANN before delegating any domain names in the .nfl TLD. This information shall consist of, at a minimum, a valid e-mail address dedicated solely to the handling of malicious conduct complaints, and a telephone number and mailing address for the primary contact. NFL Reg Ops will ensure that this information is accurate and complete, and will provide updated information to ICANN as needed. In addition, Neustar shall have an additional point of contact, as it does today, for ICANN-accredited registrars that have entered into a Registry-Registrar Agreement with NFL Reg Ops.

28.2 Policies Regarding Abuse Complaints

NFL Reg Ops will adopt and implement an Acceptable Use Policy that (i) clearly delineates the types of activities that will not be permitted in the .nfl TLD ; (ii) reserves NFL Reg Opsʹ right to lock, cancel, transfer or otherwise suspend or take down domain names violating the Acceptable Use Policy; and (iii) identify the circumstances under which NFL Reg Ops may share information with law enforcement. NFL Reg Ops will incorporate its .nfl Acceptable User Policy into its Registry-Registrar Agreement.

Under the .nfl Acceptable Use Policy, which is set forth below, NFL Reg Ops may lock down the domain name to prevent any changes to the domain name contact and nameserver information, place the domain name ʺon holdʺ rendering the domain name non-resolvable, transfer the domain name to another registrar, and⁄or in cases in which the domain name is associated with an ongoing law enforcement investigation, substitute name servers to collect information about the DNS queries to assist the investigation.

It is important to note that NFL Reg Ops intends that registration and use of .nfl domains will be restricted to itself, its Affiliates, and the thirty-two NFL Member Clubs; that there will be no resellers of .nfl domains; and that there will be no market in .nfl domains. Accordingly , the potential for abusive registration, malicious conduct, and other activities that have a negative impact on Internet users is minimal. In the unlikely event that such abuse occurs, NFL Reg Ops and its registry service provider, Neustar, will implement the following policies and processes to manage such activities.

--.nfl Acceptable Use Policy--

This Acceptable Use Policy gives NFL Reg Ops the ability to quickly lock, cancel, transfer or take ownership of any .nfl domain name, either temporarily or permanently, if the domain name is being used in a manner that appears to threaten the stability, integrity or security of NFL Reg Ops, or any of its registrar partners - and⁄or that may put the safety and security of any registrant or user at risk. The process also allows NFL Reg Ops to take preventive measures to avoid any such criminal or security threats.

The Acceptable Use Policy may be triggered through a variety of channels, including, among other things, private complaint, public alert, government or enforcement agency outreach, and the on-going monitoring by NFL Reg Ops or its partners. In all cases, NFL Reg Ops or its designees will alert NFL Reg Opsʹ registrar partners about any identified threats, and will work closely with them to bring offending sites into compliance.

The following are some (but not all) activities that may be subject to rapid domain compliance:

-Phishing: the attempt to acquire personally identifiable information by masquerading as a website other than .nflʹs own.
-Pharming: the redirection of Internet users to websites other than those the user intends to visit, usually through unauthorized changes to the Hosts file on a victimʹs computer or DNS records in DNS servers.
-Dissemination of Malware: the intentional creation and distribution of ʺmaliciousʺ software designed to infiltrate a computer system without the ownerʹs consent, including, without limitation, computer viruses, worms, key loggers, and Trojans.
-Fast Flux Hosting: a technique used to shelter Phishing, Pharming and Malware sites and networks from detection and to frustrate methods employed to defend against such practices, whereby the IP address associated with fraudulent websites are changed rapidly so as to make the true location of the sites difficult to find.
-Botnetting: the development and use of a command, agent, motor, service, or software which is implemented: (1) to remotely control the computer or computer system of an Internet user without their knowledge or consent, (2) to generate direct denial of service (DDOS) attacks.
-Malicious Hacking: the attempt to gain unauthorized access (or exceed the level of authorized access) to a computer, information system, user account or profile, database, or security system.
-Child Pornography: the storage, publication, display and⁄or dissemination of pornographic materials depicting individuals under the age of majority in the relevant jurisdiction.

NFL Reg Ops reserves the right, in its sole discretion, to take any administrative and operational actions necessary, including the use of computer forensics and information security technological services, among other things, in order to implement the Acceptable Use Policy. In addition, NFL Reg Ops reserves the right to deny, cancel or transfer any registration or transaction, or place any domain name(s) on registry lock, hold or similar status, that it deems necessary, in its discretion; (1) to protect the integrity and stability of the registry; (2) to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of NFL Reg Ops as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement; or (5) to correct mistakes made by NFL Reg Ops or any its authorized registrars in connection with a domain name registration. NFL Reg Ops also reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a dispute.

Taking Action Against Abusive and⁄or Malicious Activity

NFL Reg Ops is committed to acting in a timely and decisive manner against .nfl domain names associated with abuse or malicious conduct in violation of the Acceptable Use Policy. After a complaint is received from a trusted source or third party, or is detected by NFL Reg Ops, NFL Reg Ops will use commercially reasonable efforts to verify the information in the complaint. If that information can be verified to the best of NFL Reg Opsʹ ability, the sponsoring registrar will be notified and will have 12 hours to investigate the activity and either (a) take down the domain name through a hold or deletion; or (b) provide NFL Reg Ops with a compelling argument as to why the domain name should be taken down. If the registrar has not acted within the 12-hour period (i.e., is unresponsive to the request or refuses to take action), NFL Reg Ops will place the domain on ʺServerHoldʺ. Placing the domain on ʺServerHoldʺ due to registrar inaction is unlikely because NFL Reg Ops will likely be using a single, gateway registrar with which it has a contract requiring the registrar to act within 12 hours. ServerHold removes the domain name from the .nfl zone, but the domain name record still appears in the .nfl WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved.

Coordination with Law Enforcement

With Neustarʹs assistance as its back-end registry services provider, NFL Reg Ops can meet its obligations under Section 2.8 of the Registry Agreement to take reasonable steps to investigate and respond to reports from law enforcement and governmental and quasi-governmental agencies of illegal conduct in connection with the use of its .nfl TLD. NFL Reg Ops will respond to legitimate law enforcement inquiries promptly upon receiving the request. Such response shall include, at a minimum, an acknowledgement of the requestʹs receipt, questions or comments about the request, and an outline of NFL Reg Opsʹ next steps to address the request rapidly.

If the request involves any activities that NFL Reg Ops can validate and that violate the .nfl Acceptable Use Policy, the registrar for the domain name at issue will have 12 hours to investigate the activity further and either (a) take down the domain name through a hold or deletion; or (b) provide NFL Reg Ops with a compelling argument as to why the domain name should be taken down. If the registrar has not acted within the 12-hour period (i.e., is unresponsive to the request or refuses to take action), NFL Reg Ops will place the domain on ʺServerHoldʺ.

28.3 Measures for Removal of Orphan Glue Records

As the Security and Stability Advisory Committee of ICANN (SSAC) rightly acknowledges, although orphaned glue records may be used for abusive or malicious purposes, the ʺdominant use of orphaned glue supports the correct and ordinary operation of the DNS.ʺ See http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf.

While orphan glue often support correct and ordinary operation of the DNS, such glue records can be used maliciously to point to name servers that host domains used in illegal phishing, bot-nets, malware, and other abusive behaviors. Problems occur when the parent domain of the glue record is deleted but its children glue records still remain in DNS. Therefore, when NFL Reg Ops has written evidence of actual abuse of orphaned glue, it will remove those records from the zone to mitigate such malicious conduct.

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

In addition, if either NFL Reg Ops or Neustar becomes aware of actual abuse on orphaned glue after receiving written notification by a third party through its Abuse Contact or through its customer support, such glue records will be removed from the zone.

28.4 Authentication of Registrant Information

As stated in its response to Question 18, it is anticipated that only NFL Reg Ops, its Affiliates, and the thirty-two NFL Member Clubs (the ʺEligible .nfl Registrantsʺ) will be permitted to register and use .nfl domain names. Before any .nfl domain name is registered, NFL Reg Ops will confirm through certain procedures that all registrants are Eligible .nfl Registrants and that only Eligible .nfl Registrants are permitted to register .nfl domain names.

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

Registrars may use a number of procedures for eligibility verification such as:

1. An automated authentication process to authenticate that the prospective registrant is an Eligible .nfl Registrant;
2. Registrar-conducted authentication of whether a prospective registrantʹs e-mail address is included in a pre-approved registrant list;
3. Contacting NFL Reg Ops if the registrar is unable to verify that a prospective registrant is an Eligible .nfl Registrant; and
4. Requiring each prospective registrant to represent and warrant that it is an Eligible .nfl Registrant, that it will comply will all .nfl policies, and that neither the registration of the domain name nor its use infringes or will infringe the legal rights of third parties.

28.5 Measures to Promote Whois Accuracy

NFL Reg Ops will implement several measures to promote Whois accuracy. NFL Reg Ops will retain essential contact details for each .nfl domain name in a system that facilitates access to the domain contact information. NFL Reg Ops intends to implement internal checks and procedures so that Whois data is accurate and complete.

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

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

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

28.6 Resourcing Plans

Responsibility for abuse mitigation rests with a variety of functional groups. The Abuse Monitoring team is primarily responsible for providing analysis and conducting investigations of reports of abuse. The customer service team also plays an important role in assisting with the investigations, responded to customers, and notifying registrars of abusive domains. Finally, the Policy⁄Legal team is responsible for developing the relevant policies and procedures.

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

-Customer Support - 12 employees
-Policy⁄Legal - 2 employees

The resources are more than adequate to support the abuse mitigation procedures of the .nfl registry.

29.1. Rights Protection Mechanisms

NFL Reg Ops LLC (ʺNFL Reg Opsʺ) is firmly committed to protecting intellectual property rights and to implementing the mandatory Rights Protection Mechanisms (ʺRPMsʺ) contained in the Applicant Guidebook and detailed in Specification 7 of the Registry Agreement. Indeed, as a ʺ.brandʺ registry, intellectual property rights protection is a core objective of the .nfl registry. Neustar, which NFL Reg Ops has selected as the .nfl registry services provider, has meaningful experience in successfully launching a number of TLDs with diverse RPMs, including many of those required for new gTLDs.

As an initial matter, it is important to understand the context in which NFL Reg Ops will implement its RPMs. NFL Reg Ops plans to limit registration and use of .nfl domains to itself, its Affiliates (including the National Football League), and the NFLʹs thirty-two Member Clubs. NFL Reg Ops believes that these significant restrictions will also serve as a de facto RPM.

NFL Reg Ops will implement the following RPMs in accordance with the Applicant Guidebook as further described below:

-Pre-Authorization and Authentication

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

-Sunrise and Trademark Claims processes for the TLD.

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

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

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

-Trademark Post Delegation Dispute Resolution Procedure

A. Pre-Authorization and Authentication

As stated in its response to Question 18, it is anticipated that only NFL Reg Ops, its Affiliates, and the thirty-two NFL Member Clubs (the ʺEligible .nfl Registrantsʺ) will be permitted to register and use .nfl domain names. Before any .nfl domain name is registered, NFL Reg Ops will confirm through certain procedures that all registrants are Eligible .nfl Registrants.

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

Registrars may use a number of procedures for eligibility verification such as:

1. An automated authentication process to authenticate that the prospective registrant is an Eligible .nfl Registrant;

2. Registrar-conducted authentication of whether a prospective registrantʹs e-mail address is included in a pre-approved registrant list;

3. Contacting NFL Reg Ops if the registrar is unable to verify that a prospective registrant is an Eligible .nfl Registrant; and

4. Requiring each prospective registrant to represent and warrant that it is an Eligible .nfl Registrant, that it will comply will all .nfl policies, and that neither the registration of the domain name nor its use infringes or will infringe the legal rights of third parties.

In addition, NFL Reg Ops will conduct checks necessary to verify that all .nfl domain names comply with its registration policy. More specifically, .nfl domain names shall be used solely for purposes that are, in its judgment and discretion, consistent with its business interests. No .nfl domain name shall be used in a way that knowingly infringes any third-party intellectual property rights. Finally, no .nfl domain name may be transferred, assigned, or licensed to any third party that is not an Eligible .nfl Registrant.

B. Trademark Clearinghouse Including Sunrise and Trademark Claims

NFL Reg Ops, in conjunction with its registry service provider, will interact with the Trademark Clearinghouse to support implementation of RPMs in .nfl. The Trademark Clearinghouse is intended to serve as a central repository for information to be authenticated, stored and disseminated pertaining to the rights of trademark holders. The data maintained in the Trademark Clearinghouse will support and facilitate other RPMs, including the mandatory Sunrise Period and Trademark Claims service.

NFL Reg Opsʹ outside counsel participated in and monitored the Implementation Assistance Group (ʺIAGʺ) , which ICANN convened to assist ICANN staff in implementing the specified processes to be supported by the Trademark Clearinghouse. Personnel from Neustar, the .nfl registry services provider, also participated in the IAG. Notwithstanding numerous active IAG participants, ICANN has disclosed virtually no details of how registry operators such as NFL Reg Ops and registry service providers such as Neustar will interact with the Trademark Clearinghouse. Accordingly, NFL Reg Ops is unable to provide the level of specificity in this response that it would have preferred to do.

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

NFL Reg Opsʹ registry service provider for .nfl, Neustar, has already implemented Sunrise and⁄or Trademark Claims programs for numerous TLDs including .biz, .us, .travel, .tel and .co and will implement both of these services for the .nfl registry. NFL Reg Ops expects to benefit from Neustarʹs prior experience.

NFL Reg Ops plans to limit registration and use of .nfl domains to itself, its Affiliates (including the National Football League), and the NFLʹs 32 Member Clubs. These eligibility restrictions carry over to the Sunrise and Trademark Claims processes. In other words, only NFL Reg Ops, its Affiliates and the NFL’s thirty-two Member Clubs will be permitted to participate in the Sunrise process for the .nfl registry and they will be the only Claimants under the .nfl Trademark Claims process that are entitled to register domain names in the .nfl registry. Nonetheless, NFL Reg Ops intends to operate its Sunrise and Trademark Claims processes in full compliance with ICANNʹs policies.

NFL Reg Opsʹ proposed Sunrise and Trademark Claims service is currently anticipated to be introduced according to the following timetable:

Day One: Announcement of registry launch and publication of registry website with details of the Sunrise and Trademark Claim Service

Day 30: Sunrise process opens for 30 days on a first-come, first served basis. Once registrations are approved, they will be entered into the SRS and published in the .nfl thick Whois database.

Day 60-75: .nfl registry opens, domains applied for during Sunrise are registered, and the Trademark Claims process starts and runs for at least 60 days

Day 120-135: Trademark Claims process ends and normal operations continue.

Neustarʹs Experience in Implementing Sunrise and Trademark Claims Processes

In early 2002, Neustar became the first registry operator to launch a successful authenticated Sunrise process. This process permitted qualified trademark owners to pre-register their trademarks as domain names in the .us TLD space before the .us space opened to the general public. Unlike any other ʺSunriseʺ plans implemented (or proposed before that time), Neustar validated the authenticity of Trademark applications and registrations with the United States Patent and Trademark Office (USPTO).

Subsequently, as the back-end registry operator for the .tel gTLD and the .co ccTLD, Neustar launched validated Sunrise processes. Those processes are very similar to the Sunrise process required in new gTLDs.

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

a) Sunrise and .co

The Sunrise process for .co was divided into two sub-phases:

-Local Sunrise that gave owners of eligible trademarks registered with the Colombian Trademark Office the opportunity to apply for the .CO domain names corresponding to their marks

-Global Sunrise program giving owners of eligible registered trademarks of national effect the opportunity to apply for the .CO domain names corresponding with their marks for a period of time before registration opened to the general public.

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

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

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

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

-If there was no approval number, trademark information and the domain name registration information was provided to the Clearinghouse through EPP (as is currently required under the Applicant Guidebook).

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

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

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

b) Trademark Claims Service Experience

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

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

Every Trademark Claimant provided information about their trademark rights, including the:

-Trademark or service mark on which the Trademark Claim was based;

-Trademark application filing date and trademark registration issue date, if applicable;

-Country in which trademark registration, if any, issued;

-Class or classes of goods and services for which the trademark or service mark was registered

-Name of a contact person with whom to discuss the claimed trademark rights.

After Neustar collected all Trademark Claims and domain name applications, Neustar compared its database of all Trademark Claims against its database of all .biz domain name applications. If a domain name application matched a Trademark Claim, the domain name applicant received an e-mail message that notified it of the existing Trademark Claim. The e-mail also stressed that, if the applicant continued the process and became the registrant, the applicant would be subject to Neustarʹs dispute proceedings if challenged by the Trademark Claimant for that particular domain name.

The domain name applicant could proceed with the application or cancel it. Proceeding meant that the applicant wanted to pursue the registration even though it had been notified of an existing Trademark Claim. By choosing to ʺcancel,ʺ the applicant made a decision in light of an existing Trademark Claim notification to not proceed.

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

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

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

1. UDRP

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

NFL Reg Ops is committed to protecting intellectual property rights in .nfl and values the UDRP. Indeed, at least one of its Affiliates has been a successful UDRP Complainant. Nevertheless, NFL Reg Ops believes it is unlikely that .nfl domains will be the subject of UDRP proceedings because Eligible .nfl Registrants are unlikely to engage in bad faith registration and use. In the unlikely event that a UDRP proceeding is brought against a .nfl domain name and the even more unlikely event that a trademark owner prevails in that proceeding, cancellation of the disputed .nfl domain name is the only remedy because only NFL Reg Ops, its Affiliates, and the thirty-two NFL Member Clubs can register and use .nfl domains.

2. URS

All new gTLD registries must take part in the Uniform Rapid Suspension System (ʺURSʺ). The URS is intended to provide a mechanism, more cost effective and timely than the UDRP, for brand owners to protect their trademarks and to promote consumer protection on the Internet. The URS is not meant to address questionable cases of alleged cybersquatting (e.g., use of terms in a generic sense) or for anti-competitive purposes or denial of free speech, but rather for those cases in which there is no genuine contestable issue as to the cybersquatting and abuse that is taking place.

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

Neustar, NFL Reg Opsʹ registry service provider, is committed to supporting the URS for the .nfl registry. NFL Reg Ops is fully aware of each of these requirements and will have the capability to implement these requirements for new gTLDs. NFL Reg Ops appreciates the importance of the URS process. However, NFL Reg Ops believes it is extremely unlikely that any .nfl domain will be the subject of a URS proceeding because only NFL Reg Ops, its Affiliates, and the 32 NFL Member Clubs can register and use .nfl domain names, and it is extremely unlikely that .nfl registrants would engage in the conduct targeted by the URS.

D. Implementation of Thick WHOIS

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

E. Trademark Post Delegation Dispute Resolution Procedure (ʺTrademark PDDRPʺ)

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

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

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

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

F. Policies Handling Complaints Regarding Abuse

In addition to the RPMs described above, NFL Reg Ops will implement a number of measures that are described in its response to Q28 to handle complaints regarding the abusive registration of .nfl domain names. NFL Reg Ops does not anticipate abusive registration or malicious conduct in the .nfl registry because NFL Reg Ops plans that only itself, its Affiliates, and the 32 NFL Member Clubs register and use .nfl domains.

Registry Acceptable Use Policy

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

Monitoring for Malicious Activity

NFL Reg Ops is committed to ensuring that those domain names associated with abuse or malicious conduct in violation of the Acceptable Use Policy are dealt with in a timely and decisive manner, which includes taking action against those domain names that are being used to threaten the stability and security of the .nfl registry, or is part of a real-time investigation by law enforcement.

Once a complaint is received from a trusted source, third-party, or detected by the .nfl registry, the registry will use best efforts to verify the information in the complaint. After that information is verified to the best of the .nfl registryʹs ability, the sponsoring registrar will have 12 hours to investigate the activity and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to NFL Reg Ops to keep the name in the zone. If the registrar has not acted within the 12-hour period (i.e., is unresponsive to the request or refuses to take action), NFL Reg Ops will place the domain on ʺServerHoldʺ. Although this action would remove the domain name from the .nfl zone, the domain name record will still appear in the .nfl Whois database so that the name and entities can be investigated by law enforcement if circumstances warrant.

29.2 Resourcing Plans

The RPMs described in the response above involve a wide range of tasks, procedures, and systems. The responsibility for each mechanism varies based on the specific requirements. The Engineering Team is primarily responsible for developing applications such as Sunrise and Trademark Claims, with guidance from the Product Management team. Customer Support and Legal play a critical role in enforcing certain policies such as the rapid suspension process. These teams have years of experience implementing these or similar processes.

The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:
-Development⁄Engineering - 19 employees
-Product Management- 4 employees
-Customer Support - 12 employees

The resources are more than adequate to support the RPMs of the .nfl registry.

30.(a).1 Summary of Security Policies

NFL Reg Ops LLC (ʺNFL Reg Opsʺ) and its back-end operator, Neustar, recognize the vital need to secure the systems and the integrity of the data in commercial solutions. The .nfl registry solution will leverage industry-best security practices including the consideration of physical, network, server, and application elements.
Neustarʹs approach to information security starts with comprehensive information security policies. These are based on the industry best practices for security including SANS (SysAdmin, Audit, Network, Security) Institute, NIST (National Institute of Standards and Technology), and Center for Internet Security (CIS). Policies are reviewed annually by Neustarʹs information security team.

The following is a summary of the security policies that will be used in the .nfl registry, including:

1. Summary of the security policies used in the registry operations
2. Description of independent security assessments
3. Description of security features that are appropriate for .nfl
4. List of commitments made to registrants regarding security levels

All of the security policies and levels described in this section are appropriate for the .nfl registry.

30.(a).2 Summary of Security Policies

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

The Program defines:

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

The following policies are included in the Program:

1. Acceptable Use Policy
The Acceptable Use Policy provides the ʺrules of behaviorʺ covering all Neustar Associates for using Neustar resources or accessing sensitive information.

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

3. Data Protection Policy
The Data Protection Policy provides the requirements for creating, storing, transmitting, disclosing, and disposing of sensitive information, including data classification and labeling requirements, the requirements for data retention. Encryption and related technologies such as digital certificates are also covered under this policy.

4. Third Party Policy
The Third Party Policy provides the requirements for handling service provider contracts, including specifically the vetting process, required contract reviews, and on-going monitoring of service providers for policy compliance.

5. Security Awareness and Training Policy
The Security Awareness and Training Policy provide the requirements for managing the on-going awareness and training program at Neustar. This includes awareness and training activities provided to all Neustar Associates.

6. Incident Response Policy
The Incident Response Policy provides the requirements for reacting to reports of potential security policy violations. This policy defines the necessary steps for identifying and reporting security incidents, remediation of problems, and conducting ʺlessons learnedʺ post-mortem reviews in order to provide feedback on the effectiveness of this Program. Additionally, this policy contains the requirement for reporting data security breaches to the appropriate authorities and to the public, as required by law, contractual requirements, or regulatory bodies.

7. Physical and Environmental Controls Policy
The Physical and Environment Controls Policy provides the requirements for securely storing sensitive information and the supporting information technology equipment and infrastructure. This policy includes details on the storage of paper records as well as access to computer systems and equipment locations by authorized personnel and visitors.

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

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

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

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

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

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

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

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

30. (a).3 Independent Assessment Reports

Neustar IT Operations is subject to yearly Sarbanes-Oxley (SOX), Statement on Auditing Standards #70 (SAS70) and ISO audits. Testing of controls implemented by Neustar management in the areas of access to programs and data, change management and IT Operations are subject to testing by both internal and external SOX and SAS70 audit groups. Audit Findings are communicated to process owners, Quality Management Group and Executive Management. Actions are taken to make process adjustments where required and remediation of issues is monitored by internal audit and QM groups.
External Penetration Test is conducted by a third party on a yearly basis. As authorized by Neustar, the third party performs an external Penetration Test to review potential security weaknesses of network devices and hosts and demonstrate the impact to the environment. The assessment is conducted remotely from the Internet with testing divided into four phases:

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

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

30.(a).4 Augmented Security Levels and Capabilities

There are no increased security levels specific for .nfl. However, Neustar will provide the same high level of security provided across all of the registries it manages.
A key to Neustarʹs operational success is Neustarʹs highly structured operations practices. The standards and governance of these processes:

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

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

30.(a).5 Commitments and Security Levels

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

Compliance with High Security Standards

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

Highly Developed and Document Security Policies

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

High Levels of Registry Security

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

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