New gTLD Application Submitted to ICANN by: NIKON CORPORATION

Application Downloaded On: 18 Mar 2015

String: nikon

Application ID: 1-1808-6217

Applicant Information

1. Full legal name
NIKON CORPORATION

2. Address of the principal place of business
4-6, Kanda-Surugadai, Chiyoda-ku, Tokyo 101-0062 Japan

3. Phone number
+81 3 3214 5311

4. Fax number
+81 3 3773 8409

5. If applicable, website or URL
http://www.nikon.com

Primary Contact

6(a). Name
Naoya Ogasawara

6(b). Title
General Manager

6(c). Address

6(d). Phone Number
+81 3 3773 1259

6(e). Fax Number
+81 3 3773 8409

6(f). Email Address
ogasawara.naoya@nikonoa.net

Secondary Contact

7(a). Name
Daisuke Aoki

7(b). Title
Manager

7(c). Address

7(d). Phone Number
+81 3 3773 8842

7(e). Fax Number
+81 3 3773 8409

7(f). Email Address
aoki.daisuke@nikonoa.net

Proof of Legal Establishment

8(a). Legal form of the Applicant
Corporation

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

8(c). Attach evidence of the applicant's establishment.
Attachments are not displayed on this form.

9(a). If applying company is publicly traded, provide the exchange and symbol.
Tokyo_Stock_Exchange / 7731

9(b). If the applying entity is a subsidiary, provide the parent company.

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

Applicant Background

11(a). Name(s) and position(s) of all directors
Name
Position
Hiroshi OhkiSenior Vice President and Director
Junichi ItohSenior Executive Vice President, CFO and Representative Director
Kazuo UshidaPresident and Representative Director
Kenji MatsuoDirector
Koukei HiguchiDirector
Makoto KimuraChairman of the Board and Representative Director
Michio KARIYARepresentative Director, Chairman of the Board
Norio HashizumeSenior Vice President and Director
Takaharu HondaSenior Vice President and Director
Tomohide HamadaSenior Vice President and Director
Toshiyuki MasaiDirector
Yasuyuki OkomotoSenior Vice President and Director

11(b). Name(s) and position(s) of all officers and partners
Name
Position
Atsumi NakamuraCorporate Vice President
Hiroshi OhkiSenior Vice President and Director
Hiroyuki HIRAIWACorporate Vice President
Jun NagatsukaCorporate Vice President
Junichi ItohSenior Executive Vice President, CFO and Representative Director
Kazuo USHIDAPresident and Representative Director
Kazuyuki KAZAMICorporate Vice President
Kenji YOSHIKAWACorporate Vice President
Kiyoyuki MuramatsuCorporate Vice President
Kunio KawabataCorporate Vice President
Masao NakajimaCorporate Vice President
Naoya SugimotoCorporate Vice President
Nobuyoshi GokyuSenior Vice President
Norio HashizumeSenior Vice President and Director
Osamu ShimodaCorporate Vice President
Tadashi NakayamaCorporate Vice President
Takaharu HondaSenior Vice President and Director
Takumi OdajimaCorporate Vice President
Tetsuya YamamotoCorporate Vice President
Tomohide HamadaSenior Vice President and Director
Toru IwaokaCorporate Vice President
Toshikazu UamtateSenior Vice President
Tsuneyoshi KonCorporate Vice President
Yasuyuki OkamotoSenior Vice President and Director
Yojiro TaniiCorporate Vice President

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

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

Applied-for gTLD string

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


14A. If applying for an IDN, provide the A-label (beginning with "xn--").



14B. If an IDN, provide the meaning, or restatement of the string in English, that is, a description of the literal meaning of the string in the opinion of the applicant.



14C1. If an IDN, provide the language of the label (in English).



14C2. If an IDN, provide the language of the label (as referenced by ISO-639-1).



14D1. If an IDN, provide the script of the label (in English).



14D2. If an IDN, provide the script of the label (as referenced by ISO 15924).



14E. If an IDN, list all code points contained in the U-label according to Unicode form.



15A. If an IDN, upload IDN tables for the proposed registry. An IDN table must include:
  1. the applied-for gTLD string relevant to the tables,
  2. the script or language designator (as defined in BCP 47),
  3. table version number,
  4. effective date (DD Month YYYY), and
  5. contact name, email address, and phone number.
    Submission of IDN tables in a standards-based format is encouraged.



15B. Describe the process used for development of the IDN tables submitted, including consultations and sources used.



15C. List any variants to the applied-for gTLD string according to the relevant IDN tables.



16. Describe the applicant's efforts to ensure that there are no known operational or rendering problems concerning the applied-for gTLD string. If such issues are known, describe steps that will be taken to mitigate these issues in software and other applications.

The .NIKON string and A-Label were developed in line with and checked against the eligibility, stability and policy criteria as stated in the ICANN Applicant Guidebook - version 2012-01-11. The results of those checks are as follows:

- The string has less than 63 characters;
- The string in ASCII is composed of three or more visually distinct characters;
- The ASCII label consists entirely of letters;
- The string is not a reserved name as shown in section 2.2.1.2.1
- Reserved Names of the ICANN Applicant Guidebook - version 2012-01-11; and
- .NIKON is not identical or similar to any of the top 10 invalid TLDʹs responsible for the majority of DNS pollution, as referenced in the Security and Stability Advisory Committee (SSAC)ʹs report on this topic at http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac045.pdf. It is likely that the .NIKON has not already been queried with meaningful frequency at the root. Therefore, it is unlikely that .NIKON will inherit significant invalid query traffic.

Due to the positive results of these checks, NIKON CORPORATION does not believe that the .NIKON gTLD will be subject to any operational or rendering problems.


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



18A. Describe the mission/purpose of your proposed gTLD.

The mission and purpose of the new restricted .nikon gTLD is to benefit internet users by ensuring increased trust, confidence and a sense of security through the elimination of user confusion and assurance of brand authenticity.

The .nikon gTLD will be a new generation gTLD serving the interests of end users by providing an authoritative Internet space where information, services and resources of NIKON CORPORATION (Nikon) and its brand will be closely controlled by Nikon. The majority of the anticipated domain name registrations in the .nikon gTLD will be used in the promotion and communication of the Nikon brand and its associated products. It is anticipated that the primary use of .nikon domain names will be used for communication and marketing purposes, with internet users assured of brand authenticity.

Since its establishment in 1917, Nikon has been creating a path as a pioneer of optical technology. Nikon currently develops a broad spectrum of products with advanced technologies from optical product for consumer goods such as camera-related products focused on digital cameras and binoculars to industrial precision instruments such as Semiconductor exposure equipment, liquid crystal exposure equipment, microscope and measuring instruments. Further, Nikon has sold over 22.8 million Nikon digital cameras and digital single-lens reflex cameras worldwide and has over 23% international market share for measuring instruments.

Nikon has over 24,000 employees with business operation in over 150 countries and consolidated net sales of 887,512 million Japanese Yen for March 2011 year end. The .nikon gTLD intends to support Nikonʹs core business products and services by consolidating its online presence and Nikon brand image at a global level enhancing the brand value, free from false impersonation of third parties, together with improved user experience and user-friendly .nikon domain space on the internet. Nikon was ranked as one of ʺJapanʹs Best Global Brands 2011ʺ in a survey conducted by Interbrand. Further ʺTrustworthiness & Creativityʺ is Nikonʹs corporate philosophy. In this regard, security, innovation and accessibility are paramount considerations in all of the business activities of Nikon.

Business activities are increasingly conducted over the internet, allowing for greater levels of interaction between businesses and customers. As a result, both businesses and end users benefit from ease of interaction and a wider range of choices with lower transaction costs. However, the development in this arena in the current domain name system has exposed both businesses and consumers to increased criminal activities over the internet, including data breach, hacking and phishing. These sophisticated criminal activities cause reputational damage to businesses as internet users lose consumer confidence and trust with the businesses targeted by such criminal activities. The .nikon gTLD will facilitate greater trust and assurance from internet users connecting with Nikon online, whilst still allowing convenient and efficient interaction.

Nikonʹs mission and purpose of the proposed new gTLD share ICANNʹs initiatives to promote public interest. Nikon is committed to contribute towards achieving such initiatives in line with ICANNʹs Affirmation of Commitments, which includes:

- consumer trust: the .nikon gTLD registry will be operated in a centralized manner with a restrictive registration policy. Registration of domain names will only be available to Nikon and its affiliate entities, which will provide added consumer trust that .nikon domain names are trustworthy. As .nikon domain names are subject to registration standards, policies and procedures under Nikonʹs control, this eliminates the possibility of malicious conduct within the .nikon domain space;

- competition: the proposed new gTLD is not intended to instigate competition and consumer choice among prospective registrants. Instead it is anticipated to contribute to ICANNʹs initiatives to promote public interest through its operation focused on promoting consumer trust. Increased trust in .nikon gTLD will drive existing and new top level domain (TLD) registry operators to make improvements in mechanisms to improve consumer trust of their TLDs; and

- consumer choice: the proposed new gTLD will enable user-driven improvements and innovations assisting Nikonʹs marketing efforts through its ability to create new second and third level domain names on demand. These names will provide the consumers with more choices for interacting with Nikon. As Nikon has effective control over the registration and use of domain names under .nikon domain space, this will also contribute towards general service innovations on the internet.

Given the restricted nature of the .nikon gTLD, the projected number of registration is likely to be limited. It is anticipated that a more limited number of domain names (10-20) will be registered in the first year. However, over the next few years, the number of registrations is likely to increase up to about 1000 domain names as new services and marketing campaigns are developed and implemented by Nikon.
As the .nikon gTLD expands and evolves, Nikon may consider offering the use of second level domain names to its official agents and other eligible business partners at a later date. In this endeavor, Nikon will continue to comply with all operational, technical and policy requirements, as well as maintaining consumer trust and the stability of the internet. Nikon will keep ICANN reasonably informed of any material developments relating to .nikon gTLD including compliance with the continued operations instrument obligations as set out in Specification 8 of the Registry Agreement.

Nikon intends to create relevant domain names for use including product, services or geographic names in the second or third level domain names. In accordance with registration policies and the proposed measures for protection of geographic names as outlined in response to Question 22, Nikon will use geographic names to localize its websites in the countries in which it operates. The use of geographic names is intended to:
- connect internet users with relevant information as applicable to the territory; and
- comply with required rules and regulations in the national territory.

Nikon does not intend to utilize Internationalized Domain Names (IDNs) at the second level initially. However, as the use of the .nikon gTLD evolves, it is anticipated that Nikon may utilize IDNs within the .nikon domain space to allow internet users to engage with .nikon in their native language, creating a more positive user experience and encouraging diversity.

Nikon is a well-recognized global brand with a total of 1,853 trademarks registered in 138 countries and territories worldwide. The ʺNikonʺ trademarks are registered under various categories including but not limited to class 9, which covers Nikonʹs core business of video equipment and optical precision measuring equipment. Further, Nikon is currently applying for additional 1,112 trademarks in over 195 countries for better protection and promotion of its ʺNikonʺ brand.

Nikon has an extensive portfolio of registered domain names in both generic Top Level Domains (gTLDs) and country-code Top Level Domains (ccTLDs) including nikon.com, nikon.sa, nikon.qa, nikon.com.de, nikon.com.co, nikon.co, nikon.com.tn, nikon.tn, nikon.do, nikon.com.au, mynikonlife.com.au.

Recently, Nikon was successful in securing sunrise application for the following domain spaces based on existing trademark registration: nikon.xxx, nikion.sa, nikon.qa, nikon.com.de, nikon.com.co, nikon.co, nikon.com.tn, nikon.tn, nikon.do, nikon.tel.


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

18(b)i.
The key goals of the proposed new .nikon gTLD are in line with ICANNʹs Affirmation of Commitments: to promote consumer trust, competition and consumer choice. Nikon also seeks to foster its online reputation and provide an authoritative internet space through which Nikon is able to communicate with its customers directly and effectively. The ability to create domain names on demand related to specific marketing, specialty service and product development supports these goals. Strengthened security measures, service levels and more effective functionality will provide a trusted and positive user experience.


18(b)ii.
It is anticipated that the proposed .nikon gTLD will make positive contributions to the wider internet community by providing:

Differentiation (Increased trust):
The .nikon gTLD will simplify how internet users interact with Nikon by providing a distinctive domain space. Internet users will be able to directly navigate to .nikon gTLD site, saving time and resources searching for an official site. The current domain name system has shown that it is vulnerable to malicious abuses due to registration of domain names which seek to exploit consumer confusion. Nikon can address some of these vulnerabilities by maintaining complete control over the domain names registered under the .nikon domain space. Nikon will implement and utilize the integrated infrastructure of the .nikon gTLD to enhance its online reputation to achieve increased consumer trust. Together with consumer trust, internet users will be able to rely on the authoritativeness of the domain names under .nikon domain space, which will differentiate interaction between internet users and Nikon.

Competition:
The differentiation of .nikon gTLD as a trusted site for Nikon will drive existing and new TLD registry operators to make improvements in mechanisms to improve consumer trust of their TLDs. Internet users will be encouraged to interact with domain names under .nikon domain space. As a result, .nikon will have a flow on effect to enable increased competition. Therefore, the benefits of the proposed .nikon will be distributed not only to its direct customers, but to the internet community at large forcing improved services and competitive pricing in the market place.

Innovation:
With the expansion of the internet community to all corners of the world, the existing TLD structure presents limitations, not only in the availability of domain names for registrants, but also to businesses and organizations establishing a coherent global online brand presence to meet their evolving business needs. It is often difficult to register a domain name in existing domain space due to unavailability of the desired name. Even when the desired domain name is available, it may come with a high price tag associated with a purchase of such desired name from a third party. Nikon will utilize the ability to create second or third level domain names, including the use of geographic names, on demand in .nikon domain space to foster its corporate philosophy of ʺTrustworthiness & Creativity.ʺ .nikon domain names will provide an opportunity for Nikon to provide relevant information to its specific customer base, services and products. Nikon will be able to combine its use of the domain space with innovative user focused marketing and services to address the currently unmet needs in the existing domain name system providing greater consumer choice.


18(b)iii.
The proposed .nikon gTLD will provide positive user experience, which meets the changing and growing needs of the global internet community. Nikon will maintain control in the registration and use of domain names and will ensure that the new gTLD will only be used for purposes authorized by Nikon. Therefore, .nikon gTLD will:
- provide an easy and intuitive reference and access point for internet users;
- represent authenticity thus promoting user confidence;
- direct internet users to relevant information in a timely manner by creating domain names on demand;
- use geographic names to localize its websites to connect with internet users in the relevant regions and to comply with local laws;
- enhance security and minimize security risks by implementing necessary technical and policy measures;
- strengthen brand reputation and user confidence by eliminating user confusion; and
- prevent potential abuses in the registration process reducing overall costs to businesses and users.

The .nikon gTLD should address the concerns that the current domain name system is open to potential malicious abuse and user confusion in the registration processes. Although the current system allows an eligible party to lodge a claim through existing Uniform Domain Name Dispute Resolution Policy (UDRP) or other dispute resolution processes, the .nikon will reduce potential abuses in the registration processes and overall costs to internet users. User confidence in the domain name system will be strengthened, which will ultimately contribute towards promoting ICANNʹs core values in benefiting the public interest.


18(b)iv.
The proposed registration policy is attached in response to Question 28.

Only affiliate entities of Nikon will be eligible to register domain names in .nikon gTLD at this stage. The domain name registration processes will address the requirements mandated by ICANN, including rights abuse prevention measures.


18(b)v.
Nikon is committed to protection of privacy and confidential information in accordance with its objective of increasing consumer trust and providing a safe and legitimate internet space for internet users. Privacy and confidential information will be protected in accordance with all applicable laws and regulations relating to internet security, privacy and userʹs confidential information including Private Information Protection Law (Japan).

Nikon has also implemented its own privacy policy (the Nikon Group Privacy Protection Policy) to demonstrate its commitment to the protection of user privacy and confidential information. Nikon is committed to abide by all laws and regulations related to privacy protection and will only acquire personal information, as necessary, in a fair and lawful manner. Personal information obtained by Nikon will only be used:
- to provide products or services requested by the customers;
- to enable response to customer requests, as a reference to determine customer requirements for products, planning, development, advertisement, sales and service activities of Nikon;
- to offer product information, company information, service information or other related information of Nikon;
- to notify a prize winner or send a prize;
- to verify participants in exhibitions and seminars;
- to develop and maintain smooth relations with business partners, as a reference in the recruitment process of individuals;
- to send necessary information to shareholders; and
- as defined by Personal Data Protection Law.
Personal information will not be disclosed to third parties except with prior consent or where authorized by Personal Data Protection Law or other relevant laws and regulations.

As the .nikon gTLD will only be available to affiliate entities of Nikon, the amount of data that will be collected for the purposes of operating the gTLD and made publicly available in the WHOIS database will be very limited. Nikon will provide a publicly available and searchable WHOIS look up facility, where information about the domain name status, registrant information including administrative and technical contact details can be found in accordance with Specification 4 of the Registry Agreement. In order to prevent misuse of the WHOIS look up facility, Nikon will utilize measures including a requirement where any person submitting a WHOIS database query is required to read and agree to the terms and conditions in accordance with the registration policies. This will include the terms of use that the WHOIS database is provided for information purposes only and that the user agrees not to use the information for any other purposes such as allowing or enabling the transmission of unsolicited commercial advertising or other communication.

Nikon will deploy Domain Name System Security Extensions (DNSSEC) which is intended to benefit both Nikon and its users interacting with Nikon online. DNSSEC provides additional security by validating information in the transmission, therefore it is intended to benefit those who publish information in the domain name system (DNS) and the users who retrieve information from the new gTLD. Nikon already implements measures to protect privacy or confidential information of its users against misuse, loss, alteration and unauthorized access. Such measures include but are not limited to the use of Security Socket Layers (SSL) encrypted communication.

Nikon will continue to apply all security measures currently implemented and will comply with all other policies and practices required by ICANN in the Registry Agreement and any relevant Consensus Policy for protecting the privacy and confidential information of registrants and users in the new .nikon domain space.


18(b)vi
The proposed new gTLD will be publicized by a media plan to promote recognition of the new gTLD within the internet community to be a trusted site and as a sign of authenticity.

During the initial stage of the operation of the proposed new gTLD, it is anticipated that the use of the new gTLD will remain relatively limited.. However, over time, it is foreseen that communication to the internet community of the existence of the proposed new gTLD and encouragement to utilize the trusted site will contribute towards minimizing malicious abuses and protecting internet users.


18C. 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/costs imposed upon consumers?

As a restricted gTLD, registration will only be open to internal users (affiliate entities) at this stage and no third parties will be able to register domain names under .nikon domain space. Therefore, it is not anticipated that third party trademark owners will incur costs in relation to the .nikon gTLD. The affiliate entities wishing to register domain names must ensure that all the policy requirements for registration are satisfied. Nikon will utilise the services of the proposed Trademark Clearinghouse to ensure that domain names registered and the use of those domain names, do not infringe any registered third party intellectual property rights.

No unaffiliated third party will be permitted to register domain names at this stage. It is estimated that time and money spent by consumers internet will reduce over time as a result of the new, trusted .nikon gTLD.

18(c)i.
The initial use of the proposed new gTLD will be restricted to internal business use and Nikon and affiliate entities are intended to be the registrants under the .nikon gTLD. Therefore conflicts between multiple applications are not anticipated to occur.


18(c)ii.
This gTLD will be used for internal purposes only, at this stage, so pricing incentives are not applicable or relevant.

18(c)iii.
This gTLD will be used for internal purposes only, at this stage, so pricing incentives or pricing increases are not applicable or relevant as no additional fees are to be charged.


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

No


20A. Provide the name and full description of the community that the applicant is committing to serve. In the event that this application is included in a community priority evaluation, it will be scored based on the community identified in response to this question. The name of the community does not have to be formally adopted for the application to be designated as community-based.



20B. Explain the applicant’s relationship to the community identified in 20(a).



20C. Provide a description of the community-based purpose of the applied-for gTLD.



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



20E. Provide a complete description of the applicant’s intended registration policies in support of the community-based purpose of the applied-for gTLD. Policies and enforcement mechanisms are expected to constitute a coherent set.



20F. Attach any written endorsements for the application from established institutions representative of the community identified in 20(a). An applicant may submit written endorsements by multiple institutions, if relevant to the community.



21A. Is the application for a geographic name?

No


22. Describe proposed measures for protection of geographic names at the second and other levels in the applied-for gTLD. This should include any applicable rules and procedures for reservation and/or release of such names.

NIKON CORPORATION generally respects and abides by the GACʹs Principles regarding New gTLDs, dated March 28, 2007. In particular, NIKON CORPORATION adheres to and⁄or intends to adhere to the recommendations directed towards new registry operators in Sections 2.1, 2.4, 2.7(b) On the other hand, NIKON CORPORATION assumes that several of the recommendations directed towards new registry operators, in general, are less applicable in the case of Single-Registrant operational models such as .nikon than in an completely open Registry model. These include without limitation Sections 2.2, 2.3, 2.7(a) and 2.9.

In order to comply with the requirements of the Registry Agreement, Specification 5, and as with all other domains in the .nikon gTLD, all Two-character labels (Section 2) and Country and Territory Names (Section 5) will be initially reserved. However, NIKON CORPORATION believes that the use of geographic terms can provide great benefit and simplicity to internet users because these terms are intuitive ways to resolve to NIKON CORPORATIONʹs content that is specifically relevant and targeted to users in the particular geographic region and in line with local customs, laws and regulations. The use of the geographic terms will be valuable to internet users because they can be reassured that the content that they are viewing is relevant to their local situation thus mitigating the risk of unnecessary user confusion.

NIKON CORPORATION intends to use any Two-character label and⁄or Country or Territory Name domains in NIKON CORPORATIONʹs discretion, and to participate in or implement a process by which any Government may reasonably object to that use. NIKON CORPORATION envisions a number of possible scenarios for ensuring Government agreement to the use of Country and Territory names. These will be explored in detail with ICANN and the Governmental Advisory Committee to ensure a mutually agreeable solution. Scenarios range from at a minimum; NIKON CORPORATION informing the Chair of the Governmental Advisory Committee (GAC) to ICANN in writing of its proposed use of geographic terms and provide Governments who wish to do so with an opportunity to block the use of their relevant name in the .nikon gTLD. Other plausible scenarios would include;

SCENARIO 1 (Letter to GAC):
In advance of any use of geographical names NIKON CORPORATION will send a letter to the chair of the Governmental Advisory Committee (GAC) informing the GAC of its intention to use geographical names in the .nikon gTLD. The letter will outline the reasons for using geographical names and provide Governments with the opportunity to contact NIKON CORPORATION within 90 days to reserve their respective geographical name from use in the .nikon gTLD. Should a Government inform NIKON CORPORATION that it wishes to reserve the use of their respective geographical name, the name will remain reserved for the duration of NIKON CORPORATIONʹs registry agreement with ICANN. The opportunity to reserve a name will be offered to Governments free of charge.

SCENARIO 2 (Letter informing individual Governments):
In advance of any use of geographical names NIKON CORPORATION will send a letter to the Government concerned and inform it of NIKON CORPORATIONʹs intention to use geographical names in the .nikon gTLD. The letter will outline the reasons for using geographical names and provide the Government with the opportunity to contact NIKON CORPORATION within 90 days to reserve its respective geographical name from use in the .nikon gTLD. Should the Government inform NIKON CORPORATION that it wishes to reserve the use of its respective geographical name, the name will remain reserved for the duration of NIKON CORPORATIONʹs registry agreement with ICANN. The opportunity to reserve a name will be offered to the Government free of charge.

SCENARIO 3 (Letter requesting permission from individual Government):
In advance of any use of geographical names NIKON CORPORATION will send a letter to the Government concerned and inform it of NIKON CORPORATIONʹs intention to use geographical names in the .nikon gTLD. The letter will outline the reasons for using geographical names and request the Governmentʹs approval or non-objection to the proposed use of the geographical name. Should the Government not respond to the NIKON CORPORATION within 90 days, NIKON CORPORATION will understand this to mean that the Government does not object to NIKON CORPORATIONʹs proposed use of the geographical name. However should the Government at a later stage
contact NIKON CORPORATION and request that the geographical name no longer be used, NIKON CORPORATION will work in good faith with the Government to try to find a mutually agreeable solution.

Alternatively: However should the Government at a later stage contact NIKON CORPORATION and request that the geographical name no longer be used, NIKON CORPORATION will work in good faith with the Government to try to find a mutually agreeable solution. If such a solution cannot be found NIKON CORPORATION will respect the Governmentʹs wishes and reserve the name from use without cost to the Government concerned.

Generally, it is extremely unlikely that NIKON CORPORATIONʹs tightly controlled use of any cc.nikon or countryname.nikon domain name could be confusing or detrimental to users, or otherwise offensive to any country. Nor is it likely to be detrimental to the operator of a country code top level domain. To the extent that use of any .nikon domain was ever deemed confusing or offensive, NIKON CORPORATION has a strong desire to resolve the situation quickly and respectfully to any affected Governmentʹs sovereign interests. NIKON CORPORATION will ensure that its designated abuse contact is aware of the additional sensitivities that may potentially arise with respect to use of cc. nikon or countryname.nikon domains, such that any complaints of this nature are prioritized accordingly. NIKON CORPORATION will not use geographic names until ICANN has approved such use.


23. Provide name and full description of all the Registry Services to be provided. Descriptions should include both technical and business components of each proposed service, and address any potential security or stability concerns.
The following registry services are customary services offered by a registry operator:
  1. Receipt of data from registrars concerning registration of domain names and name servers.
  2. Dissemination of TLD zone files.
  3. Dissemination of contact or other information concerning domain name registrations (e.g., port-43 WHOIS, Web- based Whois, RESTful Whois service).
  4. Internationalized Domain Names, where offered.
  5. DNS Security Extensions (DNSSEC). The applicant must describe whether any of
    these registry services are intended to be offered in a manner unique to the TLD.
Additional proposed registry services that are unique to the registry must also be described.

1 CUSTOMARY REGISTRY SERVICES

As NIKON CORPORATION(Nikon)ʹs selected provider of backend registry services, Verisign provides a comprehensive system and physical security solution that is designed to ensure a TLD is protected from unauthorized disclosure, alteration, insertion, or destruction of registry data. Verisignʹs system addresses all areas of security including information and policies, security procedures, the systems development lifecycle, physical security, system hacks, break-ins, data tampering, and other disruptions to operations. Verisignʹs operational environments not only meet the security criteria specified in its customer contractual agreements, thereby preventing unauthorized access to or disclosure of information or resources on the Internet by systems operating in accordance with applicable standards, but also are subject to multiple independent assessments as detailed in the response to Question 30, Security Policy. Verisignʹs physical and system security methodology follows a mature, ongoing lifecycle that was developed and implemented many years before the development of the industry standards with which Verisign currently complies. Please see the response to Question 30, Security Policy, for details of the security features of Verisignʹs registry services. Verisignʹs registry services fully comply with relevant standards and best current practice RFCs published by the Internet Engineering Task Force (IETF), including all successor standards, modifications, or additions relating to the DNS and name server operations including without limitation RFCs 1034, 1035, 1982, 2181, 2182, 2671, 3226, 3596, 3597, 3901, 4343, and 4472. Moreover, Verisignʹs Shared Registration System (SRS) supports the following IETF Extensible Provisioning Protocol (EPP) specifications, where the Extensible Markup Language (XML) templates and XML schemas are defined in RFC 3915, 5730, 5731, 5732, 5733, and 5734. By strictly adhering to these RFCs, Verisign helps to ensure its registry services do not create a condition that adversely affects the throughput, response time, consistency, or coherence of responses to Internet servers or end systems. Besides its leadership in authoring RFCs for EPP, Domain Name System Security Extensions (DNSSEC), and other DNS services, Verisign has created and contributed to several now well-established IETF standards and is a regular and long-standing participant in key Internet standards forums. Figure 23-1 summarizes the technical and business components of those registry services, customarily offered by a registry operator (i.e., Verisign), that support this application. These services are currently operational and support both large and small Verisign-managed registries. Customary registry services are provided in the same manner as Verisign provides these services for its existing gTLDs. Through these established registry services, Verisign has proven its ability to operate a reliable and low-risk registry that supports millions of transactions per day. Verisign is unaware of any potential security or stability concern related to any of these services. Registry services defined by this application are not intended to be offered in a manner unique to the new generic top-level domain (gTLD) nor are any proposed services unique to this applicationʹs registry.

As further evidence of Verisignʹs compliance with ICANN mandated security and stability requirements, Verisign allocates the applicable RFCs to each of the five customary registry services (items A-E above). For each registry service, Verisign also provides evidence in Figure 23-2 of Verisignʹs RFC compliance and includes relevant ICANN prior-service approval actions.

1.1 Critical Operations of the Registry

i. Receipt of Data from Registrars Concerning Registration of Domain Names and Name Servers
See Item A in Figure 23-1 and Figure 23-2.

ii. Provision to Registrars Status Information Relating to the Zone Servers
Verisign is Nikonʹs selected provider of backend registry services. Verisign registry services provisions to registrars status information relating to zone servers for the TLD. The services also allow a domain name to be updated with clientHold, serverHold status, which removes the domain name server details from zone files. This ensures that DNS queries of the domain name are not resolved temporarily. When these hold statuses are removed, the name server details are written back to zone files and DNS queries are again resolved. Figure 23-3 describes the domain name status information and zone insertion indicator provided to registrars. The zone insertion indicator determines whether the name server details of the domain name exist in the zone file for a given domain name status.

Verisign also has the capability to withdraw domain names from the zone file in near-real time by changing the domain name statuses upon request by customers, courts, or legal authorities as required.

iii. Dissemination of TLD Zone Files
See Item B in Figure 23-1 and Figure 23-2.

iv. Operation of the Registry Zone Servers
Verisign is Nikonʹs selected provider of backend registry services. Verisign, as a company, operates zone servers and serves DNS resolution from 76 geographically distributed resolution sites located in North America, South America, Africa, Europe, Asia, and Australia. Currently, 17 DNS locations are designated primary sites, offering greater capacity than smaller sites comprising the remainder of the Verisign constellation. Verisign also uses Anycast techniques and regional Internet resolution sites to expand coverage, accommodate emergency or surge capacity, and support system availability during maintenance procedures. Verisign operates Nikonʹs gTLD from a minimum of eight of its primary sites (two on the East Coast of the United States, two on the West Coast of the United States, two in Europe, and two in Asia) and expands resolution sites based on traffic volume and patterns. Further details of the geographic diversity of Verisignʹs zone servers are provided in the response to Question 34, Geographic Diversity. Moreover, additional details of Verisignʹs zone servers are provided in the response to Question 32, Architecture and the response to Question 35, DNS Service.

v. Dissemination of Contact and Other Information Concerning Domain Name Server Registrations
See Item C in Figure 23-1 and Figure 23-2.


2 OTHER PRODUCTS OR SERVICES THE REGISTRY OPERATOR IS REQUIRED TO PROVIDE BECAUSE OF THE ESTABLISHMENT OF A CONSENSUS POLICY

Verisign, Nikonʹs selected provider of backend registry services, is a proven supporter of ICANNʹs consensus-driven, bottom-up policy development process whereby community members identify a problem, initiate policy discussions, and generate a solution that produces effective and sustained results. Verisign currently provides all of the products or services (collectively referred to as services) that the registry operator is required to provide because of the establishment of a Consensus Policy. For the .nikon gTLD, Verisign implements these services using the same proven processes and procedures currently in-place for all registries under Verisignʹs management. Furthermore, Verisign executes these services on computing platforms comparable to those of other registries under Verisignʹs management. Verisignʹs extensive experience with consensus policy required services and its proven processes to implement these services greatly minimize any potential risk to Internet security or stability. Details of these services are provided in the following subsections. It shall be noted that consensus policy services required of registrars (e.g., Whois Reminder, Expired Domain) are not included in this response. This exclusion is in accordance with the direction provided in the questionʹs Notes column to address registry operator services.

2.1 Inter-Registrar Transfer Policy (IRTP)
Technical Component: In compliance with the IRTP consensus policy, Verisign, Nikonʹs selected provider of backend registry services, has designed its registration systems to systematically restrict the transfer of domain names within 60 days of the initial create date. In addition, Verisign has implemented EPP and ʺAuthInfoʺ code functionality, which is used to further authenticate transfer requests. The registration system has been designed to enable compliance with the five-day Transfer grace period and includes the following functionality:

- Allows the losing registrar to proactively ʹACKʹ or acknowledge a transfer prior to the expiration of the five-day Transfer grace period
- Allows the losing registrar to proactively ʹNACKʹ or not acknowledge a transfer prior to the expiration of the five-day Transfer grace period
- Allows the system to automatically ACK the transfer request once the five-day Transfer grace period has passed if the losing registrar has not proactively ACKʹd or NACKʹd the transfer request.

Business Component: All requests to transfer a domain name to a new registrar are handled according to the procedures detailed in the IRTP. Dispute proceedings arising from a registrarʹs alleged failure to abide by this policy may be initiated by any ICANN-accredited registrar under the Transfer Dispute Resolution Policy. Nikonʹs compliance office serves as the first-level dispute resolution provider pursuant to the associated Transfer Dispute Resolution Policy. As needed Verisign is available to offer policy guidance as issues arise. Security and Stability Concerns: Verisign is unaware of any impact, caused by the service, on throughput, response time, consistency, or coherence of the responses to Internet servers or end-user systems. By implementing the IRTP in accordance with ICANN policy, security is enhanced as all transfer commands are authenticated using the AuthInfo code prior to processing.

ICANN Prior Approval: Verisign has been in compliance with the IRTP since November 2004 and is available to support Nikon in a consulting capacity as needed.

Unique to the TLD: This service is not provided in a manner unique to the .nikon TLD.


2.2 Add Grace Period (AGP) Limits Policy
Technical Component: Verisignʹs registry system monitors registrarʹs Add grace period deletion activity and provides reporting that permits Nikon to assess registration fees upon registrars that have exceeded the AGP thresholds stipulated in the AGP Limits Policy. Further, Nikon accepts and evaluates all exemption requests received from registrars and determines whether the exemption request meets the exemption criteria. Nikon maintains all AGP Limits Policy exemption request activity so that this material may be included within Nikonʹs Monthly Registry Operator Report to ICANN. Registrars that exceed the limits established by the policy may submit exemption requests to Nikon for consideration. Nikonʹs compliance office reviews these exemption requests in accordance with the AGP Limits Policy and renders a decision. Upon request, Nikon submits associated reporting on exemption request activity to support reporting in accordance with established ICANN requirements.

Business Component: The Add grace period (AGP) is restricted for any gTLD operator that has implemented an AGP. Specifically, for each operator:
- During any given month, an operator may not offer any refund to an ICANN-accredited registrar for any domain names deleted during the AGP that exceed (i) 10% of that registrarʹs net new registrations (calculated as the total number of net adds of one-year through ten-year registrations as defined in the monthly reporting requirement of Operator Agreements) in that month, or (ii) fifty (50) domain names, whichever is greater, unless an exemption has been granted by an operator.
- Upon the documented demonstration of extraordinary circumstances, a registrar may seek from an operator an exemption from such restrictions in a specific month. The registrar must confirm in writing to the operator how, at the time the names were deleted, these extraordinary circumstances were not known, reasonably could not have been known, and were outside the registrarʹs control. Acceptance of any exemption will be at the sole and reasonable discretion of the operator; however ʺextraordinary circumstancesʺ that reoccur regularly for the same registrar will not be deemed extraordinary.

In addition to all other reporting requirements to ICANN, Nikon identifies each registrar that has sought an exemption, along with a brief description of the type of extraordinary circumstance and the action, approval, or denial that the operator took.

Security and Stability Cncerns: Verisign is unaware of any impact, caused by the policy, on throughput, response time, consistency, or coherence of the responses to Internet servers or end-user systems.

ICANN Prior Approval: Verisign, Nikonʹs backend registry services provider, has had experience with this policy since its implementation in April 2009 and is available to support Nikon in a consulting capacity as needed.

Unique to the TLD: This service is not provided in a manner unique to the .nikon TLD.


2.3 Registry Services Evaluation Policy (RSEP)
Technical Component: Verisign, Nikonʹs selected provider of backend registry services, adheres to all RSEP submission requirements. Verisign has followed the process many times and is fully aware of the submission procedures, the type of documentation required, and the evaluation process that ICANN adheres to.

Business Component: In accordance with ICANN procedures detailed on the ICANN RSEP website (http:⁄⁄www.icann.org⁄en⁄registries⁄rsep⁄), all gTLD registry operators are required to follow this policy when submitting a request for new registry services.

Security and Stability Concerns: As part of the RSEP submission process, Verisign, Nikonʹs backend registry services provider, identifies any potential security and stability concerns in accordance with RSEP stability and security requirements.Verisign never launches services without satisfactory completion of the RSEP process and resulting approval.

ICANN Prior Approval: Not applicable.

Unique to the TLD: gTLD RSEP procedures are not implemented in a manner unique to the .nikon TLD.


3 PRODUCTS OR SERVICES ONLY A REGISTRY OPERATOR IS CAPABLE OF PROVIDING BY REASON OF ITS DESIGNATION AS THE REGISTRY OPERATOR

Verisign, Nikonʹs selected backend registry services provider, has developed a Registry-Registrar Two-Factor Authentication Service that complements traditional registration and resolution registry services. In accordance with direction provided in Question 23, Verisign details below the technical and business components of the service, identifies any potential threat to registry security or stability, and lists previous interactions with ICANN to approve the operation of the service. The Two-Factor Authentication Service is currently operational, supporting multiple registries under ICANNʹs purview. Nikon is unaware of any competition issue that may require the registry service(s) listed in this response to be referred to the appropriate governmental competition authority or authorities with applicable jurisdiction. ICANN previously approved the service(s), at which time it was determined that either the service(s) raised no competitive concerns or any applicable concerns related to competition were satisfactorily addressed.

3.1 Two-Factor Authentication Service
Technical Component: The Registry-Registrar Two-Factor Authentication Service is designed to improve domain name security and assist registrars in protecting the accounts they manage. As part of the service, dynamic one-time passwords augment the user names and passwords currently used to process update, transfer, and⁄or deletion requests. These one-time passwords enable transaction processing to be based on requests that are validated both by ʺwhat users knowʺ (i.e., their user name and password) and ʺwhat users haveʺ (i.e., a two-factor authentication credential with a one-time-password). Registrars can use the one-time-password when communicating directly with Verisignʹs Customer Service department as well as when using the registrar portal to make manual updates, transfers, and⁄or deletion transactions. The Two-Factor Authentication Service is an optional service offered to registrars that execute the Registry-Registrar Two-Factor Authentication Service Agreement.

Business Component: There is no charge for the Registry-Registrar Two-Factor Authentication Service. It is enabled only for registrars that wish to take advantage of the added security provided by the service.

Security and Stability Concerns: Verisign is unaware of any impact, caused by the service, on throughput, response time, consistency, or coherence of the responses to Internet servers or end-user systems. The service is intended to enhance domain name security, resulting in increased confidence and trust by registrants.

ICANN Prior Approval: ICANN approved the same Two-Factor Authentication Service for Verisignʹs use on .com and .net on 10 July 2009 (RSEP Proposal 2009004) and for .name on 16 February 2011 (RSEP Proposal 2011001).

Unique to the TLD: This service is not provided in a manner unique to the .nikon TLD.


4 COMMITMENT OF THE REGISTRY FUNCTIONS

Nikon and Verisign have executed agreements for the purpose of providing the necessary back-end services for fulfilling the registry services requirement under Nikonʹs Registry Agreement with ICANN.


5 ATTACHMENT

Following figures are provided in the attachment file, see the Q23_Figures_nikon.pdf attached.
- Figure 23-1, Figure 23-2, Figure 23-3


24. Shared Registration System (SRS) Performance:
describe

1 ROBUST PLAN FOR OPERATING A RELIABLE SRS

1.1 High-Level Shared Registration System (SRS) System Description
Verisign, NIKON CORPORATION(Nikon)ʹs selected provider of backend registry services, provides and operates a robust and reliable SRS that enables multiple registrars to provide domain name registration services in the top-level domain (TLD). Verisignʹs proven reliable SRS serves approximately 915 registrars, and Verisign, as a company, has averaged more than 140 million registration transactions per day. The SRS provides a scalable, fault-tolerant platform for the delivery of gTLDs through the use of a central customer database, a web interface, a standard provisioning protocol (i.e., Extensible Provisioning Protocol, EPP), and a transport protocol (i.e., Secure Sockets Layer, SSL).

The SRS components include:
- Web Interface: Allows customers to access the authoritative database for accounts, contacts, users, authorization groups, product catalog, product subscriptions, and customer notification messages.
- EPP Interface: Provides an interface to the SRS that enables registrars to use EPP to register and manage domains, hosts, and contacts.
- Authentication Provider: A Verisign developed application, specific to the SRS, that authenticates a user based on a login name, password, and the SSL certificate common name and client IP address.

The SRS is designed to be scalable and fault tolerant by incorporating clustering in multiple tiers of the platform. New nodes can be added to a cluster within a single tier to scale a specific tier, and if one node fails within a single tier, the services will still be available. The SRS allows registrars to manage the .nikon gTLD domain names in a single architecture.

To flexibly accommodate the scale of its transaction volumes, as well as new technologies, Verisign employs the following design practices:
- Scale for Growth: Scale to handle current volumes and projected growth.
- Scale for Peaks: Scale to twice base capacity to withstand ʺregistration add attacksʺ from a compromised registrar system.
- Limit Database CPU Utilization: Limit utilization to no more than 50 percent during peak loads.
- Limit Database Memory Utilization: Each userʹs login process that connects to the database allocates a small segment of memory to perform connection overhead, sorting, and data caching. Verisignʹs standards mandate that no more than 40 percent of the total available physical memory on the database server will be allocated for these functions.

Verisignʹs SRS is built upon a three-tier architecture as illustrated in Figure 24-1 and detailed here:
- Gateway Layer: The first tier, the gateway servers, uses EPP to communicate with registrars. These gateway servers then interact with application servers, which comprise the second tier.
- Application Layer: The application servers contain business logic for managing and maintaining the registry business. The business logic is particular to each TLDʹs business rules and requirements. The flexible internal design of the application servers allows Verisign to easily leverage existing business rules to apply to the .nikon gTLD. The application servers store Nikonʹs data in the registry database, which comprises the third and final tier. This simple, industry-standard design has been highly effective with other customers for whom Verisign provides backend registry services.
- Database Layer: The database is the heart of this architecture. It stores all the essential information provisioned from registrars through the gateway servers. Separate servers query the database, extract updated zone and Whois information, validate that information, and distribute it around the clock to Verisignʹs worldwide domain name resolution sites.

Scalability and Performance. Verisign, Nikonʹs selected backend registry services provider, implements its scalable SRS on a supportable infrastructure that achieves the availability requirements in Specification 10. Verisign employs the design patterns of simplicity and parallelism in both its software and systems, based on its experience that these factors contribute most significantly to scalability and reliable performance. Going counter to feature-rich development patterns, Verisign intentionally minimizes the number of lines of code between the end user and the data delivered. The result is a network of restorable components that provide rapid, accurate updates. Figure 24-2 depicts EPP traffic flows and local redundancy in Verisignʹs SRS provisioning architecture. As detailed in the figure, local redundancy is maintained for each layer as well as each piece of equipment. This built-in redundancy enhances operational performance while enabling the future system scaling necessary to meet additional demand created by this or future registry applications.

Besides improving scalability and reliability, local SRS redundancy enables Verisign to take down individual system components for maintenance and upgrades, with little to no performance impact. With Verisignʹs redundant design, Verisign can perform routine maintenance while the remainder of the system remains online and unaffected. For the .nikon gTLD registry, this flexibility minimizes unplanned downtime and provides a more consistent end-user experience.

1.2 Representative Network Diagrams
Figure 24-3provides a summary network diagram of Nikonʹs selected backend registry services providerʹs (Verisignʹs) SRS. This configuration at both the primary and alternate-primary Verisign data centers provides a highly reliable backup capability. Data is continuously replicated between both sites to ensure failover to the alternate-primary site can be implemented expeditiously to support both planned and unplanned outages.

1.3 Number of Servers
As Nikonʹs selected provider of backend registry services, Verisign continually reviews its server deployments for all aspects of its registry service. Verisign evaluates usage based on peak performance objectives as well as current transaction volumes, which drive the quantity of servers in its implementations. Verisignʹs scaling is based on the following factors:
- Server configuration is based on CPU, memory, disk IO, total disk, and network throughput projections.
- Server quantity is determined through statistical modeling to fulfill overall performance objectives as defined by both the service availability and the server configuration.
- To ensure continuity of operations for the .nikon gTLD, Verisign uses a minimum of 100 dedicated servers per SRS site. These servers are virtualized to meet demand.

1.4 Description of Interconnectivity with Other Registry Systems
Figure 24-4 provides a technical overview of the Nikonʹs selected backend registry services providerʹs (Verisignʹs) SRS, showing how the SRS component fits into this larger system and interconnects with other system components.

1.5 Frequency of Synchronization Between Servers
As Nikonʹs selected provider of backend registry services, Verisign uses synchronous replication to keep the Verisign SRS continuously in sync between the two data centers. This synchronization is performed in near-real time, thereby supporting rapid failover should a failure occur or a planned maintenance outage be required.

1.6 Synchronization Scheme
Verisign uses synchronous replication to keep the Verisign SRS continuously in sync between the two data centers. Because the alternate-primary site is continuously up, and built using an identical design to the primary data center, it is classified as a ʺhot standby.ʺ


2 SCALABILITY AND PERFORMANCE ARE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY

Verisign is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisignʹs infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies.

Verisignʹs scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the .nikon gTLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisignʹs pricing for the backend registry services it provides to Nikon fully accounts for cost related to this infrastructure, which is provided as the ʺBackend registry servicesʺ in Section I.K.i and I.K.ii of ʺOutsourcing Operating Costsʺ Template-1 within the Question 46 financial projections response.


3 TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION

Verisign, the Nikonʹs selected provider of backend registry services, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1-Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLDʹs initial implementation and ongoing maintenance. Verisignʹs pricing for the backend registry services provided to Nikon fully accounts for this personnel-related cost, which is provided as the ʺBackend registry servicesʺ in Section I.K.i and I.K.ii of ʺOutsourcing Operating Costsʺ Template-1 within the Question 46 financial projections response.


Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force. (Current statistics are publicly available in Verisignʹs quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100 percent of the time for more than 13 years for .com, proving Verisignʹs ability to align personnel resource growth to the scale increases of Verisignʹs TLD service offerings.

Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support SRS performance:
- Application Engineers: 19
- Database Administrators: 8
- Database Engineers: 3
- Network Administrators: 11
- Network Architects: 4
- Project Managers: 25
- Quality Assurance Engineers: 11
- SRS System Administrators: 13
- Storage Administrators: 4
- Systems Architects: 9

To implement and manage the .nikon gTLD as described in this application, Verisign, Nikonʹs selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area.

When usage projections indicate a need for additional staff, Verisignʹs internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed gTLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internetʹs largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.


4 EVIDENCE OF COMPLIANCE WITH SPECIFICATION 6 AND 10 TO THE REGISTRY AGREEMENT

Section 1.2 (EPP) of Specification 6, Registry Interoperability and Continuity Specifications. Verisign,Nikonʹs selected backend registry services provider, provides these services using its SRS, which complies fully with Specification 6, Section 1.2 of the Registry Agreement. In using its SRS to provide backend registry services, Verisign implements and complies with relevant existing RFCs (i.e., 5730, 5731, 5732, 5733, 5734, and 5910) and intends to comply with RFCs that may be published in the future by the Internet Engineering Task Force (IETF), including successor standards, modifications, or additions thereto relating to the provisioning and management of domain names that use EPP. In addition, Verisignʹs SRS includes a Registry Grace Period (RGP) and thus complies with RFC 3915 and its successors. Details of the Verisign SRSʹ compliance with RFC SRS⁄EPP are provided in the response to Question 25, Extensible Provisioning Protocol. Verisign does not use functionality outside the base EPP RFCs, although proprietary EPP extensions are documented in Internet-Draft format following the guidelines described in RFC 3735 within the response to Question 25. Moreover, prior to deployment, Nikon will provide to ICANN updated documentation of all the EPP objects and extensions supported in accordance with Specification 6, Section 1.2. Specification 10, EPP Registry Performance Specifications. Verisignʹs SRS meets all EPP Registry Performance Specifications detailed in Specification 10, Section 2. Evidence of this performance can be verified by a review of the .com and .net Registry Operatorʹs Monthly Reports, which Verisign files with ICANN. These reports detail Verisignʹs operational status of the .com and .net registries, which use an SRS design and approach comparable to the one proposed for the .nikon gTLD. These reports provide evidence of Verisignʹs ability to meet registry operation service level agreements (SLAs) comparable to those detailed in Specification 10. The reports are accessible at the following URL: http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄.

In accordance with EPP Registry Performance Specifications detailed in Specification 10, Verisignʹs SRS meets the following performance attributes:
- EPP service availability: Fewer than or equal to 864 minutes of downtime (approximately 98%)
- EPP session-command round trip time (RTT): Fewer than or equal to 4000 milliseconds (ms), for at least 90 percent of the commands
- EPP query-command RTT: Fewer than or equal to 2000 ms, for at least 90 percent of the commands
- EPP transform-command RTT: Fewer than or equal to 4000 ms, for at least 90 percent of the commands


5 ATTACHMENT

Following figures are provided in the attachment file, see the Q24_Figures_nikon.pdf attached.
- Figure 24-1, Figure 24-2, Figure 24-3, Figure 24-4

Nikon and Verisign have executed agreements for the purpose of providing the necessary back-end services for fulfilling the registry services requirement under Nikonʹs Registry Agreement with ICANN. Please see the attachment of question 47a Q47a_LOI_for_RegistryServices_nikon.pdf for evidence.


25. Extensible Provisioning Protocol (EPP): provide a detailed description of the interface with registrars, including how the applicant will comply with EPP in RFCs 3735 (if applicable), and 5730-5734.
If intending to provide proprietary EPP extensions, provide documentation consistent with RFC 3735, including the EPP templates and schemas that will be used.
Describe resourcing plans (number and description of personnel roles allocated to this area).
A complete answer is expected to be no more than 5 pages. If there are proprietary EPP extensions, a complete answer is also expected to be no more than 5 pages per EPP extension.

1 COMPLETE KNOWLEDGE AND UNDERSTANDING OF THIS ASPECT OF REGISTRY TECHNICAL REQUIREMENTS

Verisign, NIKON CORPORATION(Nikon)ʹs selected backend registry services provider, has used Extensible Provisioning Protocol (EPP) since its inception and possesses complete knowledge and understanding of EPP registry systems. Its first EPP implementation, for a thick registry for the .name generic top-level domain (gTLD), was in 2002. Since then Verisign has continued its RFC-compliant use of EPP in multiple TLDs, as detailed in Figure 25-1.

Verisignʹs understanding of EPP and its ability to implement code that complies with the applicable RFCs is unparalleled. Mr. Scott Hollenbeck, Verisignʹs director of software development, authored the Extensible Provisioning Protocol and continues to be fully engaged in its refinement and enhancement (U.S. Patent Number 7299299 - Shared registration system for registering domain names). Verisign has also developed numerous new object mappings and object extensions following the guidelines in RFC 3735 (Guidelines for Extending the Extensible Provisioning Protocol). Mr. James Gould, a principal engineer at Verisign, led and co-authored the most recent EPP Domain Name System Security Extensions (DNSSEC) RFC effort (RFC 5910).

All registry systems for which Verisign is the registry operator or provides backend registry services use EPP. Upon approval of this application, Verisign will use EPP to provide the backend registry services for this gTLD. The .com, .net, and .name registries for which Verisign is the registry operator use an SRS design and approach comparable to the one proposed for this gTLD. Approximately 915 registrars use the Verisign EPP service, and the registry system performs more than 140 million EPP transactions daily without performance issues or restrictive maintenance windows. The processing time service level agreement (SLA) requirements for the Verisign-operated .net gTLD are the strictest of the current Verisign managed gTLDs. All processing times for Verisign-operated gTLDs can be found in ICANNʹs Registry Operatorʹs Monthly Reports at http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄.

Verisign has also been active on the Internet Engineering Task Force (IETF) Provisioning Registry Protocol (provreg) working group and mailing list since work started on the EPP protocol in 2000. This working group provided a forum for members of the Internet community to comment on Mr. Scott Hollenbeckʹs initial EPP drafts, which Mr. Hollenbeck refined based on input and discussions with representatives from registries, registrars, and other interested parties. The working group has since concluded, but the mailing list is still active to enable discussion of different aspects of EPP.

1.1 EPP Interface with Registrars
Verisign, Nikonʹs selected backend registry services provider, fully supports the features defined in the EPP specifications and provides a set of software development kits (SDK) and tools to help registrars build secure and stable interfaces. Verisignʹs SDKs give registrars the option of either fully writing their own EPP client software to integrate with the Shared Registration System (SRS), or using the Verisign-provided SDKs to aid them in the integration effort. Registrars can download the Verisign EPP SDKs and tools from the registrar website at http:⁄⁄www.Verisign.com⁄domain-name-services⁄current-registrars⁄epp-sdk⁄index.html.

The EPP SDKs provide a host of features including connection pooling, Secure Sockets Layer (SSL), and a test server (stub server) to run EPP tests against. One tool, the EPP tool, provides a web interface for creating EPP Extensible Markup Language (XML) commands and sending them to a configurable set of target servers. This helps registrars in creating the template XML and testing a variety of test cases against the EPP servers. An Operational Test and Evaluation (OT&E) environment, which runs the same software as the production system so approved registrars can integrate and test their software before moving into a live production environment, is also available.


2 TECHNICAL PLAN SCOPE⁄SCALE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY

Verisign, Nikonʹs selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisignʹs infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies.

Verisignʹs scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the .nikon gTLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 - Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisignʹs pricing for the backend registry services it provides to Nikon fully accounts for cost related to this infrastructure, which is provided as the ʺBackend registry servicesʺ in Section I.K.i and I.K.ii of ʺOutsourcing Operating Costsʺ Template-1 within the Question 46 financial projections response.


3 TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION

Verisign, Nikonʹs selected backend registry services provider, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 - Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLDʹs initial implementation and ongoing maintenance. Verisignʹs pricing for the backend registry services it provides to Nikon fully accounts for cost related to this infrastructure, which is provided as the ʺBackend registry servicesʺ in Section I.K.i and I.K.ii of ʺOutsourcing Operating Costsʺ Template-1 within the Question 46 financial projections response.


Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force. (Current statistics are publicly available in Verisignʹs quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100 percent of the time for more than 13 years for .com, proving Verisignʹs ability to align personnel resource growth to the scale increases of Verisignʹs TLD service offerings.

Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support the provisioning of EPP services:
- Application Engineers: 19
- Database Engineers: 3
- Quality Assurance Engineers: 11

To implement and manage the .nikon gTLD as described in this application, Verisign, Nikonʹs selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area.

When usage projections indicate a need for additional staff, Verisignʹs internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed TLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internetʹs largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.


4 ABILITY TO COMPLY WITH RELEVANT RFCS

Verisign, Nikonʹs selected backend registry services provider, incorporates design reviews, code reviews, and peer reviews into its software development lifecycle (SDLC) to ensure compliance with the relevant RFCs. Verisignʹs dedicated QA team creates extensive test plans and issues internal certifications when it has confirmed the accuracy of the code in relation to the RFC requirements. Verisignʹs QA organization is independent from the development team within engineering. This separation helps Verisign ensure adopted processes and procedures are followed, further ensuring that all software releases fully consider the security and stability of the TLD.

For the .nikon gTLD, the Shared Registration System (SRS) complies with the following IETF EPP specifications, where the XML templates and XML schemas are defined in the following specifications:

- EPP RGP 3915 (http:⁄⁄www.apps.ietf.org⁄rfc⁄rfc3915.html): EPP Redemption Grace Period (RGP) Mapping specification for support of RGP statuses and support of Restore Request and Restore Report (authored by Verisignʹs Scott Hollenbeck)
- EPP 5730 (http:⁄⁄tools.ietf.org⁄html⁄rfc5730): Base EPP specification (authored by Verisignʹs Scott Hollenbeck)
- EPP Domain 5731 (http:⁄⁄tools.ietf.org⁄html⁄rfc5731): EPP Domain Name Mapping specification (authored by Verisignʹs Scott Hollenbeck)
- EPP Host 5732 (http:⁄⁄tools.ietf.org⁄html⁄rfc5732): EPP Host Mapping specification (authored by Verisignʹs Scott Hollenbeck)
- EPP Contact 5733 (http:⁄⁄tools.ietf.org⁄html⁄rfc5733): EPP Contact Mapping specification (authored by Verisignʹs Scott Hollenbeck)
- EPP TCP 5734 (http:⁄⁄tools.ietf.org⁄html⁄rfc5734): EPP Transport over Transmission Control Protocol (TCP) specification (authored by Verisignʹs Scott Hollenbeck)
- EPP DNSSEC 5910 (http:⁄⁄tools.ietf.org⁄html⁄rfc5910): EPP Domain Name System Security Extensions (DNSSEC) Mapping specification (authored by Verisignʹs James Gould and Scott Hollenbeck)


5 PROPRIETARY EPP EXTENSIONS

Verisign, Nikonʹs selected backend registry services provider, uses its SRS to provide registry services. The SRS supports the following EPP specifications, which Verisign developed following the guidelines in RFC 3735, where the XML templates and XML schemas are defined in the specifications:
- IDN Language Tag (http:⁄⁄www.verisigninc.com⁄assets⁄idn-language-tag.pdf): EPP internationalized domain names (IDN) language tag extension used for IDN domain name registrations
- RGP Poll Mapping (http:⁄⁄www.verisigninc.com⁄assets⁄whois-info-extension.pdf): EPP mapping for an EPP poll message in support of Restore Request and Restore Report
- Whois Info Extension (http:⁄⁄www.verisigninc.com⁄assets⁄whois-info-extension.pdf): EPP extension for returning additional information needed for transfers
- EPP ConsoliDate Mapping (http:⁄⁄www.verisigninc.com⁄assets⁄consolidate-mapping.txt): EPP mapping to support a Domain Sync operation for synchronizing domain name expiration dates
- NameStore Extension (http:⁄⁄www.verisigninc.com⁄assets⁄namestore-extension.pdf): EPP extension for routing with an EPP intelligent gateway to a pluggable set of backend products and services
- Low Balance Mapping (http:⁄⁄www.verisigninc.com⁄assets⁄low-balance-mapping.pdf): EPP mapping to support low balance poll messages that proactively notify registrars of a low balance (available credit) condition

As part of the 2006 implementation report to bring the EPP RFC documents from Proposed Standard status to Draft Standard status, an implementation test matrix was completed. Two independently developed EPP client implementations based on the RFCs were tested against the Verisign EPP server for the domain, host, and contact transactions. No compliance-related issues were identified during this test, providing evidence that these extensions comply with RFC 3735 guidelines and further demonstrating Verisignʹs ability to design, test, and deploy an RFC-compliant EPP implementation.

5.1 EPP Templates and Schemas
The EPP XML schemas are formal descriptions of the EPP XML templates. They are used to express the set of rules to which the EPP templates must conform in order to be considered valid by the schema. The EPP schemas define the building blocks of the EPP templates, describing the format of the data and the different EPP commandsʹ request and response formats. The current EPP implementations managed by Verisign, Nikonʹs selected backend registry services provider, use these EPP templates and schemas, as will the proposed TLD. For each proprietary XML template⁄schema Verisign provides a reference to the applicable template and includes the schema. The EPP Templates and Schemas are provided in the attachment file, see the Q25_EPP_Schemas_nikon.pdf attached.

6 PROPRIETARY EPP EXTENSION CONSISTENCY WITH REGISTRATION LIFECYCLE

Nikonʹs selected backend registry services providerʹs (Verisignʹs) proprietary EPP extensions, defined in Section 5 above, are consistent with the registration lifecycle documented in the response to Question 27, Registration Lifecycle. Details of the registration lifecycle are presented in that response. As new registry features are required, Verisign develops proprietary EPP extensions to address new operational requirements. Consistent with ICANN procedures Verisign adheres to all applicable Registry Services Evaluation Process (RSEP) procedures.


7 ATTACHMENT

Following figure is provided in the attachment file, see the Q25_Figures_nikon.pdf attached.
- Figure 25-1

Nikon and Verisign have executed agreements for the purpose of providing the necessary back-end services for fulfilling the registry services requirement under Nikonʹs Registry Agreement with ICANN. Please see the attachment of question 47a Q47a_LOI_for_RegistryServices_nikon.pdf for evidence.


26. Whois: describeA complete answer should include, but is not limited to:Frequency of synchronization between servers.
To be eligible for a score of 2, answers must also include:A complete answer is expected to be no more than 5 pages.

1 COMPLETE KNOWLEDGE AND UNDERSTANDING OF THIS ASPECT OF REGISTRY TECHNICAL REQUIREMENTS

Verisign, NIKON CORPORATION(Nikon)ʹs selected backend registry services provider, has operated the Whois lookup service for the gTLDs and ccTLDs it manages since 1991, and will provide these proven services for the .nikon gTLD registry. In addition, it continues to work with the Internet community to improve the utility of Whois data, while thwarting its application for abusive uses.

1.1 High-Level Whois System Description
Like all other components of Nikonʹs selected backend registry services providerʹs(Verisignʹs) registry service, Verisignʹs Whois system is designed and built for both reliability and performance in full compliance with applicable RFCs. Verisignʹs current Whois implementation has answered more than five billion Whois queries per month for the TLDs it manages, and has experienced more than 250,000 queries per minute in peak conditions. The proposed gTLD uses a Whois system design and approach that is comparable to the current implementation. Independent quality control testing ensures Verisignʹs Whois service is RFC-compliant through all phases of its lifecycle.

Verisignʹs redundant Whois databases further contribute to overall system availability and reliability. The hardware and software for its Whois service is architected to scale both horizontally(by adding more servers) and vertically(by adding more CPUs and memory to existing servers) to meet future need.

Verisign can fine-tune access to its Whois database on an individual Internet Protocol(IP) address basis, and it works with registrars to help ensure their services are not limited by any restriction placed on Whois. Verisign provides near real-time updates for Whois services for the TLDs under its management. As information is updated in the registration database, it is propagated to the Whois servers for quick publication. These updates align with the near real-time publication of Domain Name System(DNS) information as it is updated in the registration database. This capability is important for the .nikon gTLD registry as it is Verisignʹs experience that when DNS data is updated in near real time, so should Whois data be updated to reflect the registration specifics of those domain names.

Verisignʹs Whois response time has been less than 500ms for 95% of all Whois queries in .com, .net, .tv, and .cc. The response time in these TLDs, combined with Verisignʹs capacity, enables the Whois system to respond to up to 30,000 searches(or queries) per second for a total capacity of 2.6 billion queries per day.

The Whois software written by Verisign complies with RFC 3912. Verisign uses an advanced in-memory database technology to provide exceptional overall system performance and security. In accordance with RFC 3912, Verisign provides a website at whois.nic.nikon that provides free public query-based access to the registration data.

Verisign currently operates both thin and thick Whois systems.

Verisign commits to implementing a RESTful Whois service upon finalization of agreements with the IETF.

Provided Functionalities for User Interface
To use the Whois service via port 43, the user enters the applicable parameter on the command line as illustrated here:
- For domain name: whois EXAMPLE.nikon
- For registrar: whois ʺregistrar NIKON CORPORATIONʺ
- For name server: whois ʺNS1.EXAMPLE.nikonʺ or whois ʺname server(IP address)ʺ

To use the Whois service via the web-based directory service search interface:
- Go to http:⁄⁄whois.nic.nikon
- Click on the appropriate button(Domain, Registrar, or Name Server)
- Enter the applicable parameter:
o Domain name, including the TLD
o Full name of the registrar, including punctuation
o Full host name or the IP address
- Click on the Submit button.

Provisions to Ensure That Access Is Limited to Legitimate Authorized Users and Is in Compliance with Applicable Privacy Laws or Policies
To further promote reliable and secure Whois operations, Verisign, Nikonʹs selected backend registry services provider, has implemented rate-limiting characteristics within the Whois service software. For example, to prevent data mining or other abusive behavior, the service can throttle a specific requestor if the query rate exceeds a configurable threshold. In addition, QoS technology enables rate limiting of queries before they reach the servers, which helps protect against denial of service(DoS) and distributed denial of service(DDoS) attacks.

Verisignʹs software also permits restrictions on search capabilities. For example, wild card searches can be disabled. If needed, it is possible to temporarily restrict and⁄or block requests coming from specific IP addresses for a configurable amount of time. Additional features that are configurable in the Whois software include help files, headers and footers for Whois query responses, statistics, and methods to memory map the database. Furthermore, Verisign is European Union(EU) Safe Harbor certified and has worked with European data protection authorities to address applicable privacy laws by developing a tiered Whois access structure that requires users who require access to more extensive data to(i) identify themselves,(ii) confirm that their use is for a specified purpose and(iii) enter into an agreement governing their use of the more extensive Whois data.

1.2 Relevant Network Diagrams
Figure 26-1 provides a summary network diagram of the Whois service provided by Verisign, Nikonʹs selected backend registry services provider. The figure details the configuration with one resolution⁄Whois site. For the .nikon gTLD Verisign provides Whois service from 6 of its 17 primary sites based on the proposed gTLDʹs traffic volume and patterns. A functionally equivalent resolution architecture configuration exists at each Whois site.

1.3 IT and Infrastructure Resources
Figure 26-2 summarizes the IT and infrastructure resources that Verisign, Nikonʹs selected backend registry services provider, uses to provision Whois services from Verisign primary resolution sites. As needed, virtual machines are created based on actual and projected demand.

1.4 Description of Interconnectivity with Other Registry Systems
Figure 26-3 provides a technical overview of the registry system provided by Verisign, Nikonʹs selected backend registry services provider, and shows how the Whois service component fits into this larger system and interconnects with other system components.

1.5 Frequency of Synchronization Between Servers
Synchronization between the SRS and the geographically distributed Whois resolution sites occurs approximately every three minutes. Verisign, Nikonʹs selected backend registry services provider, uses a two-part Whois update process to ensure Whois data is accurate and available. Every 12 hours an initial file is distributed to each resolution site. This file is a complete copy of all Whois data fields associated with each domain name under management. As interactions with the SRS cause the Whois data to be changed, these incremental changes are distributed to the resolution sites as an incremental file update. This incremental update occurs approximately every three minutes. When the new 12-hour full update is distributed, this file includes all past incremental updates. Verisignʹs approach to frequency of synchronization between servers meets the Performance Specifications defined in Specification 10 of the Registry Agreement for new gTLDs.


2 TECHNICAL PLAN SCOPE⁄SCALE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY

Verisign, Nikonʹs selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisignʹs infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies.

Verisignʹs scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the .nikon gTLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely scenario(defined in Question 46, Template 1 - Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisignʹs pricing for the backend registry services it provides to Nikon fully accounts for cost related to this infrastructure, which is provided as the ʺBackend registry servicesʺ in Section I.K.i and I.K.ii of ʺOutsourcing Operating Costsʺ Template-1 within the Question 46 financial projections response.


3 TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION

Verisign, Nikonʹs selected backend registry services provider, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario(defined in Question 46, Template 1 - Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLDʹs initial implementation and ongoing maintenance. Verisignʹs pricing for the backend registry services it provides to Nikon fully accounts for cost related to this infrastructure, which is provided as the ʺBackend registry servicesʺ in Section I.K.i and I.K.ii of ʺOutsourcing Operating Costsʺ Template-1 within the Question 46 financial projections response.

Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force.(Current statistics are publicly available in Verisignʹs quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100% of the time for more than 13 years for .com, proving Verisignʹs ability to align personnel resource growth to the scale increases of Verisignʹs TLD service offerings.

Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support Whois services:
- Application Engineers:19
- Database Engineers:3
- Quality Assurance Engineers:11

To implement and manage the .nikon gTLD as described in this application, Verisign, Nikonʹs selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area.

When usage projections indicate a need for additional staff, Verisignʹs internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed gTLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internetʹs largest TLDs(i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.


4 COMPLIANCE WITH RELEVANT RFC

Nikonʹs selected backend registry services providerʹs(Verisignʹs) Whois service complies with the data formats defined in Specification 4 of the Registry Agreement. Verisign will provision Whois services for registered domain names and associated data in the top-level domain(TLD). Verisignʹs Whois services are accessible over Internet Protocol version 4(IPv4) and Internet Protocol version 6(IPv6), via both Transmission Control Protocol(TCP) port 43 and a web-based directory service at whois.nic.nikon, which in accordance with RFC 3912, provides free public query-based access to domain name, registrar, and name server lookups. Verisignʹs proposed Whois system meets all requirements as defined by ICANN for each registry under Verisign management. Evidence of this successful implementation, and thus compliance with the applicable RFCs, can be verified by a review of the .com and .net Registry Operatorʹs Monthly Reports that Verisign files with ICANN. These reports provide evidence of Verisignʹs ability to meet registry operation service level agreements(SLAs) comparable to those detailed in Specification 10. The reports are accessible at the following URL: http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄.


5 COMPLIANCE WITH SPECIFICATIONS 4 AND 10 OF REGISTRY AGREEMENT

In accordance with Specification 4, Verisign, Nikonʹs selected backend registry services provider, provides a Whois service that is available via both port 43 in accordance with RFC 3912, and a web-based directory service at whois.nic.nikon also in accordance with RFC 3912, thereby providing free public query-based access. Verisign acknowledges that ICANN reserves the right to specify alternative formats and protocols, and upon such specification, Verisign will implement such alternative specification as soon as reasonably practicable.

The format of the following data fields conforms to the mappings specified in Extensible Provisioning Protocol(EPP) RFCs 5730-5734 so the display of this information(or values returned in Whois responses) can be uniformly processed and understood: domain name status, individual and organizational names, address, street, city, state⁄province, postal code, country, telephone and fax numbers, email addresses, date, and times.

Specifications for data objects, bulk access, and lookups comply with Specification 4 and are detailed in the following subsections, provided in both bulk access and lookup modes.

Bulk Access Mode. This data is provided on a daily schedule to a party designated from time to time in writing by ICANN. The specification of the content and format of this data, and the procedures for providing access, shall be as stated below, until revised in the ICANN Registry Agreement.

The data is provided in three files:
- Domain Name File: For each domain name, the file provides the domain name, server name for each name server, registrar ID, and updated date.
- Name Server File: For each registered name server, the file provides the server name, each IP address, registrar ID, and updated date.
- Registrar File: For each registrar, the following data elements are provided: registrar ID, registrar address, registrar telephone number, registrar email address, Whois server, referral URL, updated date, and the name, telephone number, and email address of all the registrarʹs administrative, billing, and technical contacts.

Lookup Mode. Figure 26-4 through Figure 26-6 provide the query and response format for domain name, registrar, and name server data objects.

5.1 Specification 10, RDDS Registry Performance Specifications
The Whois service meets all registration data directory services(RDDS) registry performance specifications detailed in Specification 10, Section 2. Evidence of this performance can be verified by a review of the .com and .net Registry Operatorʹs Monthly Reports that Verisign files monthly with ICANN. These reports are accessible from the ICANN website at the following URL: http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄.

In accordance with RDDS registry performance specifications detailed in Specification 10, Verisignʹs Whois service meets the following proven performance attributes:
- RDDS availability: Fewer than or equal to 864 min of downtime(approximately 98%)
- RDDS query RTT: Fewer than or equal to 2000 ms, for at least 95% of the queries
- RDDS update time: Fewer than or equal to 60 min, for at least 95% of the probes


6 SEARCHABLE WHOIS

Verisign, Nikonʹs selected backend registry services provider, provides a searchable Whois service for the .nikon gTLD. Verisign has experience in providing tiered access to Whois for the .name registry, and uses these methods and control structures to help reduce potential malicious use of the function. The searchable Whois system currently uses Apacheʹs Lucene full text search engine to index relevant Whois content with near-real time incremental updates from the provisioning system.

Features of the Verisign searchable Whois function include:
- Provision of a web-based searchable directory service
- Ability to perform partial match, at least, for the following data fields: domain name, contacts and registrantʹs name, and contact and registrantʹs postal address, including all the sub-fields described in EPP(e.g.,city, state, or province)
- Ability to perform exact match, at least, on the following fields: registrar ID, name server name, and name serverʹs IP address(only applies to IP addresses stored by the registry, i.e.,glue records)
- Ability to perform Boolean search supporting, at least, the following logical operators to join a set of search criteria: AND, OR, NOT
- Search results that include domain names that match the selected search criteria

Verisignʹs implementation of searchable Whois is EU Safe Harbor certified and includes appropriate access control measures that help ensure that only legitimate authorized users can use the service. Furthermore, Verisignʹs compliance office monitors current ICANN policy and applicable privacy laws or policies to help ensure the solution is maintained within compliance of applicable regulations. Features of these access control measures include:

- All unauthenticated searches are returned as thin results.
- Registry system authentication is used to grant access to appropriate users for thick Whois data search results.
- Account access is granted by the Nikon defined .nikon gTLD admin user.

Potential Forms of Abuse and Related Risk Mitigation. Leveraging its experience providing tiered access to Whois for the .name registry and interacting with ICANN, data protection authorities, and applicable industry groups, Verisign, Nikonʹs selected backend registry services provider, is knowledgeable of the likely data mining forms of abuse associated with a searchable Whois service. Figure 26-7 summarizes these potential forms of abuse and Verisignʹs approach to mitigate the identified risk.


7 ATTACHMENT

All Figures are attached into the Q26_Figures_nikon.pdf.
- Figure 26-1, 26-2, 26-3, 26-4, 26-5, 26-6, 26-7

Nikon and Verisign have executed agreements for the purpose of providing the necessary back-end services for fulfilling the registry services requirement under Nikonʹs Registry Agreement with ICANN. Please see the attachment of question 47a Q47a_LOI_for_RegistryServices_nikon.pdf for evidence.


27. Registration Life Cycle: provide a detailed description of the proposed registration lifecycle for domain names in the proposed gTLD. The description must:The description of the registration lifecycle should be supplemented by the inclusion of a state diagram, which captures definitions, explanations of trigger points, and transitions from state to state.
If applicable, provide definitions for aspects of the registration lifecycle that are not covered by standard EPP RFCs.
A complete answer is expected to be no more than 5 pages.

1 COMPLETE KNOWLEDGE AND UNDERSTANDING OF REGISTRATION LIFECYCLES AND STATES

Starting with domain name registration and continuing through domain name delete operations, NIKON CORPORATION(Nikon)ʹs selected backend registry services providerʹs (Verisignʹs) registry implements the full registration lifecycle for domain names supporting the operations in the Extensible Provisioning Protocol (EPP) specification. The registration lifecycle of the domain name starts with registration and traverses various states as specified in the following sections. The registry system provides options to update domain names with different server and client status codes that block operations based on the EPP specification. The system also provides different grace periods for different billable operations, where the price of the billable operation is credited back to the registrar if the billable operation is removed within the grace period. Together Figure 27-1 and Figure 27-2 define the registration states comprising the registration lifecycle and explain the trigger points that cause state-to-state transitions. States are represented as green rectangles within Figure 27-1.


1.1 Registration Lifecycle of Create⁄Update⁄Delete
The following section details the create⁄update⁄delete processes and the related renewal process that Verisign, Nikonʹs selected backend registry services provider, follows. For each process, this response defines the process function and its characterization, and as appropriate provides a process flow chart.

〈Create Process〉
The domain name lifecycle begins with a registration or what is referred to as a Domain Name Create operation in EPP. The system fully supports the EPP Domain Name Mapping as defined by RFC 5731, where the associated objects (e.g., hosts and contacts) are created independent of the domain name.

Process Characterization.
The Domain Name Create command is received, validated, run through a set of business rules, persisted to the database, and committed in the database if all business rules pass. The domain name is included with the data flow to the DNS and Whois resolution services. If no name servers are supplied, the domain name is not included with the data flow to the DNS. A successfully created domain name has the created date and expiration date set in the database. Creates are subject to grace periods as described in Section 1.3 of this response, Add Grace Period, Redemption Grace Period, and Notice Periods for Renewals or Transfers. The Domain Name Create operation is detailed in Figure 27-3 and requires the following attributes:
- A domain name that meets the string restrictions.
- A domain name that does not already exist.
- The registrar is authorized to create a domain name in .nikon.
- The registrar has available credit.
- A valid Authorization Information (Auth-Info) value.
- Required contacts (e.g., registrant, administrative contact, technical contact, and billing contact) are specified and exist.
- The specified name servers (hosts) exist, and there is a maximum of 13 name servers.
- A period in units of years with a maximum value of 10 (default period is one year).

〈Renewal Process〉
The domain name can be renewed unless it has any form of Pending Delete, Pending Transfer, or Renew Prohibited.
A request for renewal that sets the expiry date to more than ten years in the future is denied. The registrar must pass the current expiration date (without the timestamp) to support the idempotent features of EPP, where sending the same command a second time does not cause unexpected side effects.
Automatic renewal occurs when a domain name expires. On the expiration date, the registry extends the registration period one year and debits the registrar account balance. In the case of an auto-renewal of the domain name, a separate Auto-Renew grace period applies. Renewals are subject to grace periods as described in Section 1.3 of this response, Add Grace Period, Redemption Grace Period, and Notice Periods for Renewals or Transfers.

Process Characterization.
The Domain Name Renew command is received, validated, authorized, and run through a set of business rules. The data is updated and committed in the database if it passes all business rules. The updated domain nameʹs expiration date is included in the flow to the Whois resolution service.

The Domain Name Renew operation is detailed in Figure 27-4 and requires the following attributes:
- A domain name that exists and is sponsored by the requesting registrar.
- The registrar is authorized to renew a domain name in .nikon.
- The registrar has available credit.
- The passed current expiration date matches the domain nameʹs expiration date.
- A period in units of years with a maximum value of 10 (default period is one year). A domain name expiry past ten years is not allowed.

〈Registrar Transfer Procedures〉
A registrant may transfer his⁄her domain name from his⁄her current registrar to another registrar. The database system allows a transfer as long as the transfer is not within the initial 60 days, per industry standard, of the original registration date.
The registrar transfer process goes through many process states, which are described in detail below, unless it has any form of Pending Delete, Pending Transfer, or Transfer Prohibited.

A transfer can only be initiated when the appropriate Auth-Info is supplied. The Auth-Info for transfer is only available to the current registrar. Any other registrar requesting to initiate a transfer on behalf of a registrant must obtain the Auth-Info from the registrant.
The Auth-Info is made available to the registrant upon request. The registrant is the only party other than the current registrar that has access to the Auth-Info. Registrar transfer entails a specified extension of the expiry date for the object. The registrar transfer is a billable operation and is charged identically to a renewal for the same extension of the period. This period can be from one to ten years, in one-year increments.
Because registrar transfer involves an extension of the registration period, the rules and policies applying to how the resulting expiry date is set after transfer are based on the renewal policies on extension.

Per industry standard, a domain name cannot be transferred to another registrar within the first 60 days after registration. This restriction continues to apply if the domain name is renewed during the first 60 days. Transfer of the domain name changes the sponsoring registrar of the domain name, and also changes the child hosts (ns1.sample.xyz) of the domain name (sample.xyz).
The domain name transfer consists of five separate operations:
- Transfer Request (Figure 27-5): Executed by a non-sponsoring registrar with the valid Auth-Info provided by the registrant. The Transfer Request holds funds of the requesting registrar but does not bill the registrar until the transfer is completed. The sponsoring registrar receives a Transfer Request poll message.
- Transfer Cancel (Figure 27-6): Executed by the requesting registrar to cancel the pending transfer. The held funds of the requesting registrar are reversed. The sponsoring registrar receives a Transfer Cancel poll message.
- Transfer Approve (Figure 27-7): Executed by the sponsoring registrar to approve the Transfer Request. The requesting registrar is billed for the Transfer Request and the sponsoring registrar is credited for an applicable Auto-Renew grace period. The requesting registrar receives a Transfer Approve poll message.
- Transfer Reject (Figure 27-8): Executed by the sponsoring registrar to reject the pending transfer. The held funds of the requesting registrar are reversed. The requesting registrar receives a Transfer Reject poll message.
- Transfer Query (Figure 27-9): Executed by either the requesting registrar or the sponsoring registrar of the last transfer.

The registry auto-approves a transfer if the sponsoring registrar takes no action. The requesting registrar is billed for the Transfer Request and the sponsoring registrar is credited for an applicable Auto-Renew grace period. The requesting registrar and the sponsoring registrar receive a Transfer Auto-Approve poll message.

〈Delete Process〉
A registrar may choose to delete the domain name at any time.

Process Characterization.
The domain name can be deleted, unless it has any form of Pending Delete, Pending Transfer, or Delete Prohibited.
A domain name is also prohibited from deletion if it has any in-zone child hosts that are name servers for domain names. For example, the domain name ʺsample.xyzʺ cannot be deleted if an in-zone host ʺns.sample.xyzʺ exists and is a name server for ʺsample2.xyz.ʺ
If the Domain Name Delete occurs within the Add grace period, the domain name is immediately deleted and the sponsoring registrar is credited for the Domain Name Create. If the Domain Name Delete occurs outside the Add grace period, it follows the Redemption grace period (RGP) lifecycle.

〈Update Process〉
The sponsoring registrar can update the following attributes of a domain name:
- Auth-Info
- Name servers
- Contacts (i.e., registrant, administrative contact, technical contact, and billing contact)
- Statuses (e.g., Client Delete Prohibited, Client Hold, Client Renew Prohibited, Client Transfer Prohibited, Client Update Prohibited)

Process Characterization.
Updates are allowed provided that the update includes the removal of any Update Prohibited status. The Domain Name Update operation is detailed in Figure 27-10.
A domain name can be updated unless it has any form of Pending Delete, Pending Transfer, or Update Prohibited.


1.2 Pending, Locked, Expired, and Transferred
Verisign, Nikonʹs selected backend registry services provider, handles pending, locked, expired, and transferred domain names as described here. When the domain name is deleted after the five-day Add grace period, it enters into the Pending Delete state. The registrant can return its domain name to active any time within the five-day Pending Delete grace period. After the five-day Pending Delete grace period expires, the domain name enters the Redemption Pending state and then is deleted by the system. The registrant can restore the domain name at any time during the Redemption Pending state.

When a non-sponsoring registrar initiates the domain name transfer request, the domain name enters Pending Transfer state and a notification is mailed to the sponsoring registrar for approvals. If the sponsoring registrar doesnʹt respond within five days, the Pending Transfer expires and the transfer request is automatically approved.

EPP specifies both client (registrar) and server (registry) status codes that can be used to prevent registry changes that are not intended by the registrant. Currently, many registrars use the client status codes to protect against inadvertent modifications that would affect their customersʹ high-profile or valuable domain names.

Verisignʹs registry service supports the following client (registrar) and server (registry) status codes:
- clientHold
- clientRenewProhibited
- clientTransferProhibited
- clientUpdateProhibited
- clientDeleteProhibited
- serverHold
- serverRenewProhibited
- serverTransferProhibited
- serverUpdateProhibited
- serverDeleteProhibited


1.3 Add Grace Period, Redemption Grace Period, and Notice Periods for Renewals or Transfers
Verisign, Nikonʹs selected backend registry services provider, handles Add grace periods, Redemption grace periods, and notice periods for renewals or transfers as described here.
- Add Grace Period: The Add grace period is a specified number of days following the initial registration of the domain name. The current value of the Add grace period for all registrars is five days.
- Redemption Grace Period: If the domain name is deleted after the five-day grace period expires, it enters the Redemption grace period and then is deleted by the system. The registrant has an option to use the Restore Request command to restore the domain name within the Redemption grace period. In this scenario, the domain name goes to Pending Restore state if there is a Restore Request command within 30 days of the Redemption grace period. From the Pending Restore state, it goes either to the OK state, if there is a Restore Report Submission command within seven days of the Restore Request grace period, or a Redemption Period state if there is no Restore Report Submission command within seven days of the Restore Request grace period.
- Renew Grace Period: The Renew⁄Extend grace period is a specified number of days following the renewal⁄extension of the domain nameʹs registration period. The current value of the Renew⁄Extend grace period is five days.
- Auto-Renew Grace Period: All auto-renewed domain names have a grace period of 45 days.
- Transfer Grace Period: Domain names have a five-day Transfer grace period.


1.4 Aspects of the Registration Lifecycle Not Covered by Standard EPP RFCs
Nikonʹs selected backend registry services providerʹs (Verisignʹs) registration lifecycle processes and code implementations adhere to the standard EPP RFCs related to the registration lifecycle. By adhering to the RFCs, Verisignʹs registration lifecycle is complete and addresses each registration-related task comprising the lifecycle. No aspect of Verisignʹs registration lifecycle is not covered by one of the standard EPP RFCs and thus no additional definitions are provided in this response.



2 CONSISTENCY WITH ANY SPECIFIC COMMITMENTS MADE TO REGISTRANTS AS ADAPTED TO THE OVERALL BUSINESS APPROACH FOR THE PROPOSED gTLD

The registration lifecycle described above applies to the .nikon gTLD as well as other TLDs managed by Verisign, Nikonʹs selected backend registry services provider; thus Verisign remains consistent with commitments made to its registrants. No unique or specific registration lifecycle modifications or adaptations are required to support the overall business approach for the .nikon gTLD.

To accommodate a range of registries, Verisignʹs registry implementation is capable of offering both a thin and thick Whois implementation, which is also built upon Verisignʹs award-winning ATLAS infrastructure.



3 COMPLIANCE WITH RELEVANT RFCs

Nikonʹs selected backend registry services providerʹs (Verisignʹs) registration lifecycle complies with applicable RFCs, specifically RFCs 5730 - 5734 and 3915. The system fully supports the EPP Domain Name Mapping as defined by RFC 5731, where the associated objects (e.g., hosts and contacts) are created independent of the domain name.

In addition, in accordance with RFCs 5732 and 5733, the Verisign registration system enforces the following domain name registration constraints:
- Uniqueness⁄Multiplicity: A second-level domain name is unique in the .nikon database. Two identical second-level domain names cannot simultaneously exist in .nikon. Further, a second-level domain name cannot be created if it conflicts with a reserved domain name.
- Point of Contact Associations: The domain name is associated with the following points of contact. Contacts are created and managed independently according to RFC 5733.
- Registrant
- Administrative contact
- Technical contact
- Billing contact
- Domain Name Associations: Each domain name is associated with:
- A maximum of 13 hosts, which are created and managed independently according to RFC 5732
- An Auth-Info, which is used to authorize certain operations on the object
- Status(es), which are used to describe the domain nameʹs status in the registry
- A created date, updated date, and expiry date



4 DEMONSTRATES THAT TECHNICAL RESOURCES REQUIRED TO CARRY THROUGH THE PLANS FOR THIS ELEMENT ARE ALREADY ON HAND OR READILY AVAILABLE

Verisign, Nikonʹs selected backend registry services provider, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 - Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLDʹs initial implementation and ongoing maintenance. Verisignʹs pricing for the backend registry services it provides to Nikon fully accounts for cost related to this infrastructure, which is provided as the ʺBackend registry servicesʺ in Section I.K.i and I.K.ii of ʺOutsourcing Operating Costsʺ Template-1 within the Question 46 financial projections response.

Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force. (Current statistics are publicly available in Verisignʹs quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100 percent of the time for more than 13 years for .com, proving Verisignʹs ability to align personnel resource growth to the scale increases of Verisignʹs TLD service offerings.

Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support the registration lifecycle:
- Application Engineers: 19
- Customer Support Personnel: 36
- Database Administrators: 8
- Database Engineers: 3
- Quality Assurance Engineers: 11
- SRS System Administrators: 13

To implement and manage the .nikon gTLD as described in this application, Verisign, Nikonʹs selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area.

When usage projections indicate a need for additional staff, Verisignʹs internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed gTLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internetʹs largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.


5 ATTACHMENT

Following figures are provided in the attachment file, see the Q27_Figures_nikon.pdf attached.
- Figure 27-1, Figure 27-2, Figure 27-3, Figure 27-4, Figure 27-5, Figure 27-6, Figure 27-7, Figure 27-8, Figure 27-9, Figure 27-10

Nikon and Verisign have executed agreements for the purpose of providing the necessary back-end services for fulfilling the registry services requirement under Nikonʹs Registry Agreement with ICANN. Please see the attachment of question 47a Q47a_LOI_for_RegistryServices_nikon.pdf for evidence.


28. Abuse Prevention and Mitigation: Applicants should describe the proposed policies and procedures to minimize abusive registrations and other activities that have a negative impact on Internet users. A complete answer should include, but is not limited to:To be eligible for a score of 2, answers must include measures to promote Whois accuracy as well as measures from one other area as described below.A complete answer is expected to be no more than 20 pages.

A. ABUSE PREVENTION AND MITIGATION TO BE IMPLEMENTED BY NIKON CORPORATION

NIKON CORPORATIONʹs proposed use for .nikon should, by its very nature, preclude abusive registrations from occurring, as all domains names may only be registered in the name of NIKON CORPORATION and its affiliates (for the purposes of this response, ʺaffiliatesʺ means in relation to a party any corporation or other business entity
controlling, controlled by, or under common control of that party and for the purposes of this definition, a corporation or other business entity shall be deemed to control another corporation or business entity if it owns directly or indirectly (i) fifty percent (50%) or more of the voting securities or voting interest in any such corporation or other entity; or (ii) fifty percent (50%) or more of the interest in the profit or income in the case of a business entity other than a corporation; or (iii) in the case of a partnership, any other compatible interest equal to at least a fifty percent (50%) share in the general partner).

NIKON CORPORATION is intending to operate .nikon for the benefit of Internet users that would like to interact with NIKON CORPORATION. There is no incentive for NIKON CORPORATION to confuse Internet users, nor otherwise use domain names in bad faith, since NIKON CORPORATIONʹs branded keyword gTLD is inherently intertwined with all uses of .nikon domain names.

Notwithstanding the above, NIKON CORPORATION understands and agrees that it must comply with the different rights protection mechanisms such as the Uniform Domain Name Dispute Resolution Policy (UDRP) and the Uniform Rapid Suspension System (URS) as described in the gTLD Applicant Guidebook (as may be later amended via Consensus Policy) and the Registry Agreement. The aforementioned policies provide a strong incentive to ensure that relevant and effective checks are in place to ensure that all .nikon domain names are only registered and used in an appropriate manner so as to benefit Internet users who would like to interact with NIKON CORPORATION, rather than in any manner that may be deemed inappropriate or in bad faith.

NIKON CORPORATION will implement a clear written policy which requires the relevant corporate authorization and approvals to be procured and evidenced in order for any .nikon domain name to be registered for NIKON CORPORATIONʹs use. In the event that NIKON CORPORATION resolves to permit third parties (other than affiliates) that have a relationship with either NIKON CORPORATION or its business, to register (or license) and use domain names within the top level domain (TLD), then additional corporate authorizations and approvals may be required to ensure internal responsibility for permitting and enforcing the terms of use of the .nikon domain. In addition to these safeguards, all registered domain names in the TLD will be regularly monitored for abusive use.

As stated in response to Question 18, NIKON CORPORATIONʹs Registration Policy will address the minimum requirements mandated by ICANN including rights abuse prevention measures. NIKON CORPORATION will implement the following as means of abuse prevention and mitigation:

- NIKON CORPORATIONʹs Registration Policy - draft, see the Q28_Registration_Policy_Draft_nikon.pdf attached.
- NIKON CORPORATIONʹs Procedure for Management of Trademark Infringement Claims - draft, see the Q28_Procedure_for_Management_of_TIC_nikon.pdf attached.


B. .nikon ANTI-ABUSE POLICIES

Although domain names will only be registered to NIKON CORPORATION and its affiliates, all domain names will be subject to specific internal registration policy for .nikon domain. The NIKON CORPORATIONʹs Registration Policy will set out in writing a methodology for corporate authorization, approval and evidence in order for any domain name to be registered for NIKON CORPORATIONʹs use. This will prohibit any abusive use of a domain name. These policies include not only the required URS, but also the supplemental Anti-Phishing Takedown Process, NIKON CORPORATIONʹs Acceptable Use Policy, and NIKON CORPORATIONʹs strict controls on registration.


C. DEFINITION OF ABUSE

NIKON CORPORATION defines abuse as an action that causes actual and substantial harm, or is a material predicate of such harm, and is illegal, illegitimate, or otherwise contrary to NIKON CORPORATIONʹs Registration Policy. Abuse includes, without limitation, the following:

- Content or actions that attempt to defraud members of the public in any way (for example, ʺphishingʺ sites);
- Content that is hateful, defamatory, derogatory or bigoted based on racial, ethnic, political grounds or which otherwise may cause or incite injury, damage or harm of any kind to any person or entity;
- Content that is threatening or invades another personʹs privacy or property rights or is otherwise in breach of any duty owed to a third party;
- Content or actions that infringe the trademark, copyright, patent rights, trade secret or other intellectual property rights, or any other legal rights of NIKON CORPORATION or any third party;
- Content or actions that violate any applicable local, state, national or international law or regulation;
- Content or actions that promote, are involved in or assist in, the conduct of illegal activity of any kind or promote business opportunities or investments that are not permitted under applicable law;
- Content that advertises or offers for sale any goods or services that are unlawful or in breach of any national or international law or regulation; or
- Content or actions associated with the sale or distribution of prescription medication without a valid prescription;
- Content that depicts minors engaged in any activity of a sexual nature or which may otherwise harm minors;
- Activities that mislead or deceive minors into viewing sexually explicit material;
- Spam: The use of electronic messaging systems to send unsolicited bulk messages. The term applies to e-mail spam and similar abuses such as instant messaging spam, mobile messaging spam, and the spamming of Web sites and Internet forums. An example, for purposes of illustration, would be the use of email in denial-of-service attacks;
- Phishing: The use of counterfeit Web pages that are designed to trick recipients into divulging sensitive data such as usernames, passwords, or financial data;
- Pharming: The redirecting of unknowing users to fraudulent sites or services, typically through Domain Name System (DNS) hijacking or poisoning;
- Willful distribution of malware: The dissemination of software designed to infiltrate or damage a computer system without the ownerʹs informed consent. Examples include, without limitation, computer viruses, worms, keyloggers and trojan horses;
- Botnet command and control: Services run on a domain name that are used to control a collection of illegally compromised computers or ʺzombies,ʺ or to direct denial-of-service attacks (DDoS attacks); and
- Illegal Access to Other Computers or Networks: Illegally accessing computers, accounts, or networks belonging to another party, or attempting to penetrate security measures of another individualʹs system (often known as ʺhackingʺ). Also, any activity that might be used as a precursor to an attempted system penetration (e.g., port scan, stealth scan, or other information gathering activity).

Any employee found to have violated any of NIKON CORPORATIONʹs policies may be subject to disciplinary action, up to and including termination of employment.

Every NIKON CORPORATION employee should be aware that the data they create on the corporate systems, including on any domain name hosted in .nikon, remains the property of NIKON CORPORATION. For security and network maintenance purposes, authorized individuals within NIKON CORPORATION may monitor equipment, systems and network traffic at any time. NIKON CORPORATION reserves the right to audit networks and systems on a periodic basis to ensure compliance with this policy.

NIKON CORPORATION recognizes that, notwithstanding all of NIKON CORPORATIONʹs internal policies having been meticulously followed by all employees and affiliates, the Internet remains an open and
ubiquitous system that provides access and anonymity to participants around the world. This is one of the Internetʹs strengths and also a source of difficulty as malicious or criminal perpetrators exploit these characteristics for their own benefit. The frequency of activities such as phishing, pharming, spam and DDoS attacks have increased dramatically on the Internet and there is strong evidence to suggest this will continue.

NIKON CORPORATION has resolved to ensure that abusive use of the .nikon domain names will not be permitted nor tolerated. The nature of such abuses creates security and stability issues for NIKON
CORPORATION, as well as for users of the Internet in general, and particularly those who wish to interact with NIKON CORPORATION in a secure and reliable manner. The nature of such abuses also inherently creates negative publicity and loss of brand integrity and goodwill and, therefore, any such abuse must be swiftly and effectively addressed, and systems must continue to evolve in accordance with evolving threats.

Scanning to identify malicious or abusive behavior.
All domain names within the .nikon domain shall be continually executing approved virus-scanning software with a current virus database, unless overridden by departmental or group policy for
legitimate business reason.

NIKON CORPORATION will conduct automated and regular scanning for malware of all domain names in the Registry through its selected back end Registry services provider, Verisign. Registrants are often unknowing victims of malware exploits. Verisign has developed proprietary code to help identify malware in the zones it manages, which in turn helps registrars by identifying malicious code hidden in their domain names. Verisignʹs malware scanning service helps prevent websites from infecting other websites by scanning web pages for embedded malicious content that will infect visitorsʹ websites. Verisignʹs malware scanning technology uses a combination of in-depth malware behavioral analysis, anti-virus results, detailed malware patterns, and network analysis to discover known exploits for the particular scanned zone. If malware is detected, the service sends the registrar a report that contains the number of malicious domains found and details about malicious content within its TLD zones. Reports with remediation instructions are provided to help registrars and registrants eliminate the identified malware from the registrantʹs website.


D. ADDITIONAL PROCESSES TO ADDRESS ABUSIVE USE OF REGISTERED DOMAIN NAMES

Suspension processes conducted by backend registry services provider.
In the case of domain name abuse, NIKON CORPORATION or NIKON CORPORATIONʹs approved registrar(s) will determine whether to take down the subject domain name. Verisign, NIKON CORPORATIONʹs selected backend registry services provider, will follow the auditable processes to comply with the suspension request as set out Diagram 1 of the Attachment.

Verisign Suspension Notification.
NIKON CORPORATION or NIKON CORPORATIONʹs approved registrar(s) submits the suspension request to Verisign for processing, documented by:

- Threat domain name
- Registry incident number
- Incident narrative, threat analytics, screen shots to depict abuse, and⁄or other evidence
- Threat classification
- Threat urgency description
- Recommended timeframe for suspension⁄takedown
- Technical details (e.g., Whois records, IP addresses, hash values, anti-virus detection results⁄nomenclature, name servers, domain name status that are relevant to the suspension)
- Incident response, including surge capacity

Verisign Notification Verification.
When Verisign receives a suspension request from NIKON CORPORATION or NIKON CORPORATIONʹs approved registrar(s), it performs the following verification procedures:

- Validate that all the required data appears in the notification
- Validate that the request for suspension is for a registered domain name
- Return a case number for tracking purposes

Suspension Rejection.
If required data is missing from the suspension request, or the domain name is not registered, the request will be rejected and returned to NIKON CORPORATION or NIKON CORPORATIONʹs approved registrar(s) with the following information:

- Threat domain name
- Registry incident number
- Verisign case number
- Error reason

NIKON CORPORATION will notify the registrar of record in relation to a complaint.


E. ABUSE POINT OF CONTACT AND PROCESS FOR ADDRESSING COMPLAINTS

NIKON CORPORATION will act as the primary abuse point of contact for the gTLD. NIKON CORPORATION may use its third party registrar(s) or its selected back end registry services provider, Verisign, to perform some or all of the functions associated with handling inquiries relating to malicious conduct in the gTLD. Contact details (including at least a valid email and mailing address) for the abuse primary contact will be displayed prominently on NIKON CORPORATIONʹs main website. The primary contact will investigate and respond to all complaints and incidents within a reasonable time and be empowered to take effective action within well-defined written criteria to guide those actions. Action will be taken in line with what is set out in this answer and the registration policy for the .nikon domain. Changes to contact details will be clearly and effectively communicated to ICANN and prominently displayed on NIKON CORPORATIONʹs website.

The above mentioned email address will be set up to receive complaints for any potential malicious conduct in the TLD. Furthermore, the email address will be routinely monitored over a 24 hour period, 365 days a year. Complainants will be provided with a written email response communication containing an auditable tracking or case number. NIKON CORPORATION will investigate all reasonable complaints and take any reasonably necessary and appropriate action. Verified law enforcement requests will be addressed in no more than twenty-four hours from verified receipt. All other requests will be addressed in no more than seventy-two hours from receipt.

Abuse complaint metrics will be tracked, and adequate resources will be expended to ensure appropriate trending of those metrics by providing the abuse point of contact with sufficient resources. The complaint metrics will be gathered by the registrar(s) and regularly forwarded to NIKON CORPORATION for the purposes of identifying gaps in the Registryʹs current policies and areas of improvement. Given NIKON CORPORATIONʹs belief that infrastructure protection, rights protection and user security are paramount goals of operating the TLD, NIKON CORPORATION intends to engage a third party registrar(s), who will be required to ensure that sufficient resources are provided to satisfy this critical requirement, and to do whatever is reasonably necessary to ensure a secure and trusted zone.

NIKON CORPORATION will have strict controls over the registration and use of the .nikon domain names. NIKON CORPORATION will devise and document strict criteria and authority levels which will need to be satisfied before a domain name can be registered for use. To ensure independence of this function, a third party registrar will be responsible for ensuring strict compliance with the criteria and authority levels designated. Only authorized personnel within NIKON CORPORATION organization will be permitted to request and⁄or authorize DNS changes to be made either by the third party registrar or the registry services provider. NIKON CORPORATIONʹs documented criteria and authority levels for registering a domain name ensure multiple, unique points of contact are needed to request and⁄ or approve, update, transfer and⁄ or deal with deletion requests, and will require notification of multiple unique points of contact when a domain name has been updated, transferred, or deleted.


F. ORPHAN GLUE RECORDS

NIKON CORPORATION will ensure proper attention is paid to orphan glue records. While orphan glue often supports correct and ordinary operation of the DNS, NIKON CORPORATION understands that it will be required, via Specification 6 of the Registry Agreement, to take action to remove orphan glue records when provided with evidence in written form that such records are present in connection with malicious conduct. NIKON CORPORATIONʹs robust controls on registration and use, and ongoing monitoring of the .nikon zone, should ensure that this is not an area of concern. Furthermore, NIKON CORPORATIONʹs selected backend registry services providerʹs (Verisignʹs), registration system is specifically designed to not allow orphan glue records. Registrars are required to delete⁄move all dependent DNS records before they are allowed to delete the parent domain. To prevent orphan glue records, Verisign performs the following checks before removing a domain or name server:

Checks during domain delete:
- Parent domain delete is not allowed if any other domain in the zone refers to the child name server
- If the parent domain is the only domain using the child name server, then both the domain and the glue record are removed from the zone

Check during explicit name server delete:
- Verisign confirms that the current name server is not referenced by any domain name (in-zone) before deleting the name server

Zone-file impact:
- If the parent domain references the child name server AND if other domains in the zone also reference it AND if the parent domain name is assigned a server Hold status, then the parent domain goes out of the zone but the name server glue record does not
- If no domains reference a name server, then the zone file removes the glue record

Controls on new registrations of domain names.
NIKON CORPORATION will adopt and impose strict controls over the registration and use of .nikon domain names. NIKON CORPORATION will devise and document strict criteria and authority levels which will need to be satisfied before a domain name can be registered for NIKON CORPORATIONʹs use. To ensure appropriate verification of this function, third party registrar(s) will be appointed to perform the administrative aspects of the registration of domain names in strict compliance with the defined criteria and designated authority levels. The registry services provider will be provided with the defined criteria and will be required to ensure that only domains which comply with the criteria are registered. Only authorized personnel within NIKON CORPORATION organization will be able to request and⁄or authorize DNS changes to be made either by the third party registrar(s) or the registry services provider. NIKON CORPORATIONʹs documented criteria and authority levels for domain name registration will ensure multiple, unique points of contact are needed to request and⁄ or approve, update, transfer and⁄ or deal with deletion requests, and will require notification of multiple unique points of contact when a domain name has been updated, transferred, or deleted.

NIKON CORPORATION confirms that it will meet the standards set out in the Registry Agreement, with respect to the Sunrise and Trademark claims process for any domain names registered.


G. ENSURING WHOIS ACCURACY

A complete and accurate Whois database promotes the prevention of identity theft, fraud and other on-line crime, promotes the publicʹs ability to police its rights against unlawful copyright and trademark infringement, and minimizes technical errors. NIKON CORPORATION has a compelling interest in accounting to itself and the public for the use of Applicant assets, and in ensuring those assets are only used by persons or entities authorized by NIKON CORPORATION. That interest is especially strong with respect to the .nikon and all domain names registered or used therein, since it is a core component of NIKON CORPORATIONʹs online branding and technological platform.

NIKON CORPORATION will enforce the Whois data accuracy provisions in ICANNʹs Registry Agreement, Registrar Accreditation Agreement and all relevant Consensus Policies. Those agreements generally require all registrants to provide accurate and reliable contact details and promptly update any changes made during the registration term. NIKON CORPORATIONʹs registrars must present to the registrant the current Whois information, and remind the registrant that provision of false Whois information can be grounds for cancellation of the domain name registration. .nikon and⁄or its affiliates (as defined in this response) will be listed as the sole registrant of all domains within the .nikon. NIKON CORPORATIONʹs clear written policy which requires the relevant corporate authorization and approvals to be procured and evidenced for any .nikon domain name to be registered for NIKON CORPORATIONʹs use, and the subsequent verification through a registrar will ensure thorough pre-verification of all Whois data. Therefore, all Whois information will be complete and accurate at the time of registration. In the event of any change in the Whois contact information for a domain name, that change will be promptly updated in the Whois database.

Verisign, NIKON CORPORATIONʹs selected backend registry services provider, has established policies and procedures to encourage registrar compliance with ICANNʹs Whois accuracy requirements. Verisign provides the following services to NIKON CORPORATION for incorporation into its full-service registry operations.

Registrar self certification.
The self-certification program consists, in part, of evaluations applied equally to all operational ICANN accredited registrars and conducted from time to time throughout the year. Process steps are as follows:

- Verisign sends an email notification to the ICANN primary registrar contact, requesting that the contact go to a designated URL, log in with his⁄her Web ID and password, and complete and submit the online form. The contact must submit the form within 15 business days of receipt of the notification;
- When the form is submitted, Verisign sends the registrar an automated email confirming that the form was successfully submitted;
- Verisign reviews the submitted form to ensure the certifications are compliant;
- Verisign sends the registrar an email notification if the registrar is found to be compliant in all areas;
- If a review of the response indicates that the registrar is out of compliance or if Verisign has follow-up questions, the registrar has 10 days to respond to the inquiry;
- If the registrar does not respond within 15 business days of receiving the original notification, or if it does not respond to the request for additional information, Verisign sends the registrar a Breach Notice and gives the registrar 30 days to cure the breach;
- If the registrar does not cure the breach, Verisign terminates the Registry-Registrar Agreement (RRA).

Whois data reminder process.
Verisign regularly reminds registrars of their obligation to comply with ICANNʹs Whois Data Reminder Policy, which was adopted by ICANN as a consensus policy on 27 March 2003. Verisign sends a notice to all registrars once a year reminding them of their obligation to be diligent in validating the Whois information provided during the registration process, to investigate claims of fraudulent Whois information, and to cancel domain name registrations for which Whois information is determined to be invalid.


H. RESOURCE PLANNING

NIKON CORPORATION has effectively mitigated the risk of abuse in the gTLD and foresees assigning a member of staff to act as the primary points of contact for handling inquiries relating to malicious or abusive conduct in the TLD. NIKON CORPORATION is committed to ensuring that sufficient resources are made available at all times. However, given the restricted nature of the gTLD, NIKON CORPORATION does not currently expect that this role will require a full-time resource. NIKON CORPORATION may engage its third party registrar(s) and its selected back end registry services provider, Verisign, to perform some or all of the tasks associated with abuse issues. This will ensure that highly skilled, specialized and scalable resources are on hand to address any possible abuse issues both during the startup phase of the TLD and continually during operations of the TLD.

Verisign, NIKON CORPORATIONʹs selected backend registry services provider, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 - Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLDʹs initial implementation and ongoing maintenance. Verisignʹs pricing for the backend registry services is included in VSJʹs pricing and it provides to NIKON CORPORATION fully accounts for cost related to this infrastructure, which is included in the registry services provider costs in Section I.K ʺOutsourcing Operating Costsʺ within the Question 46 financial projections response.

Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force. (Current statistics are publicly available in Verisignʹs quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100 percent of the time for more than 13 years for .com, proving Verisignʹs ability to align personnel resource growth to the scale increases of Verisignʹs TLD service offerings.

Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support abuse prevention and mitigation:

- Application Engineers: 19
- Business Continuity Personnel: 3
- Customer Affairs Organization: 9
- Customer Support Personnel: 36
- Information Security Engineers: 11
- Network Administrators: 11
- Network Architects: 4
- Network Operations Center (NOC) Engineers: 33
- Project Managers: 25
- Quality Assurance Engineers: 11
- Systems Architects: 9

To implement and manage the .nikon TLD as described in this application, Verisign, NIKON CORPORATIONʹs selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area.

When usage projections indicate a need for additional staff, Verisign ʹs internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed gTLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internetʹs largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.

To the extent NIKON CORPORATION licenses use of any .nikon domain names, at minimum it will ensure proper controls such that its abuse point of contact will have necessary information to investigate all abuse complaints and formulate any appropriate responsive actions in a timely fashion. NIKON CORPORATION may also require the licenseeʹs information in the WHOIS record as the Administrative, Technical and⁄or a supplemental contact point. In addition, licensees will be bound in a written contract to relevant provisions of the Registry Agreement, the registration policy for the NIKON CORPORATION TLD and NIKON CORPORATIONʹs Acceptable Use Policy.


I. Conclusion

The approach outlined in this answer clearly shows that the risk of abuse in the .nikon TLD has been extensively mitigated and as a direct result is very low. NIKON CORPORATION is committed to ensuring that abuse will not be tolerated. The proposed policies and methods for addressing any abuse exceed the standard outline in the gTLD Applicant Guidebook and is more than commensurate with the risks identified, NIKON CORPORATION is, therefore, entitled to a score of two points for its response to Question 28.


The NIKON CORPORATIONʹs Procedure for Management of Trademark Infringement Claims see the Q28_Procedure_for_Management_of_TIC_nikon.pdf attached.

The NIKON CORPORATIONʹs Registration Policy, see the Q28_Registration_Policy_Draft_nikon.pdf attached.

The Diagram 1 is provided in the attachment file, see the Q28_Suspension_processes_diagram_nikon.pdf attached.

The Question 46 ʺmost likelyʺ financial projections template, see the Q46_Mostlikely_Financial_Projection_nikon.xlsx attached.


29. Rights Protection Mechanisms: Applicants must describe how their registry will comply with policies and practices that minimize abusive registrations and other activities that affect the legal rights of others, such as the Uniform Domain Name Dispute Resolution Policy (UDRP), Uniform Rapid Suspension (URS) system, and Trademark Claims and Sunrise services at startup.
A complete answer should include:>To be eligible for a score of 2, answers must also include additional measures specific to rights protection, such as abusive use policies, takedown procedures, registrant pre-verification, or authentication procedures, or other covenants.
A complete answer is expected to be no more than 10 pages.

A. RIGHTS PROTECTION MECHANISMS TO BE IMPLEMENTED BY NIKON CORPORATION

NIKON CORPORATIONʹs core purpose in operating the .NIKON domain is to ensure better rights protection for NIKON CORPORATION, as well as for all Internet users. In particular, NIKON CORPORATION seeks to establish a trusted and reliable, branded platform for those who wish to interact or communicate with NIKON CORPORATION. Therefore, NIKON CORPORATION has extremely strong interest in ensuring that all of its aforementioned policies are implemented and continually enforced. NIKON CORPORATIONʹs proposed use of the .NIKON gTLD should, of itself, preclude any abusive registrations from occurring, since all domain names may only be registered in the name of NIKON CORPORATION and its affiliates in the manner outlined in the response to Question 28. Notwithstanding the above, NIKON CORPORATION understands the importance of ensuring safeguards are implemented which protect against unqualified registrations. Therefore, NIKON CORPORATION has resolved to implement the following:

Firstly, NIKON CORPORATION will have absolute control over the registration and use of .NIKON domain names. Only authorized personnel will be able to register a second level domain name for corporate use and only authorized personnel will be permitted to make Domain Name System (DNS) changes. NIKON CORPORATION will require multiple, unique points of contact to request and⁄ or approve, update, transfer and⁄ or deal with deletion requests, and will require notification of multiple unique points of contact when a domain name has been updated, transferred, or deleted. In other words, NIKON CORPORATION will have an identifiable and delineated process in place from pre-verification to eventual deletion of a domain name. This process will apply to NIKON CORPORATION and also to any subsidiaries or affiliates (as defined in the response to Question 28 above). Compliance with the policy will be ensured by the appointed Registrar(s). This, in conjunction with NIKON CORPORATIONʹs resolution to ensure that abusive use of .NIKON domain names will not be permitted nor tolerated, means that the scope for abusive use will be very limited.

Secondly, where NIKON CORPORATION intends to permit certain entities who are affiliated with NIKON CORPORATIONʹs business to register second level domain names within the .NIKON domain, NIKON CORPORATION will ensure that the registration is limited to legitimate uses of the allocated domain name (such use being consistent with the mission and purpose of the .NIKON, and subject always to the registrantʹs continuing compliance with all policies in place during that time and those mandated thereafter to ensure compliance with on-going ICANN requirements wherever reasonable. Any registrants must warrant they will not assign, license or otherwise permit any other third party to use or link to the subdomain.

Third, NIKON CORPORATION will regularly monitor the .NIKON zone, for viruses⁄ malware, illegitimate use and for inappropriate content. Abuses and complaints will be quickly addressed in the manner set forth in response to Question 28.

Fourthly, NIKON CORPORATION will participate in, and comply with, the required Rights Protection Mechanisms set forth in the gTLD Applicant Guidebook and Registry Agreement, including the Uniform Domain Name Dispute Resolution Policy (UDRP), the Uniform Rapid Suspension (URS) and the Trademark Claims and Sunrise processes. In the unlikely event that third parties perceive that their rights have been infringed, they will have a speedy right of recourse open to them. Given that NIKON CORPORATION has resolved to ensure that abusive use of .NIKON domain names will not be permitted nor tolerated and the risk that such abuses inherently create negative publicity, loss of brand integrity and goodwill, NIKON CORPORATION is committed to ensuring that any abuse will be swiftly and effectively addressed, and that systems are in place to mitigate rights protection issues.

Fifth, NIKON CORPORATION will go beyond the required rights protection mechanisms defined in Specification 7 of the Registry Agreement by also participating in solutions to monitor potentially malicious conduct over the Internet as outlined below and in the answer to Question 28. This may occur via private contracts with a qualified anti-phishing solutions vendor who will both monitor the .NIKON zone for abuse and take action to remedy the abuse, and⁄ or this may occur via participation in a broader program such as the Abusive Domain Name Resolution Suspension Process (ADNRS) in development by the Anti-Phishing Working Group. These measures will be available at time of registration and include:

- Rapid Takedown or Suspension Based on Court Orders: NIKON CORPORATION or NIKON CORPORATIONʹs approved registrar(s) complies promptly with any order from a court of competent jurisdiction that directs it to take any action on a domain name that is within its technical capabilities as a gTLD registry. These orders may be issued when abusive content, such as child pornography, counterfeit goods, or illegal pharmaceuticals, is associated with the domain name;
- Anti-Abuse Process: NIKON CORPORATION or NIKON CORPORATIONʹs approved registrar(s) implements an anti-abuse process that is executed based on the type of domain name takedown requested. The anti-abuse process is for malicious exploitation of the DNS infrastructure, such as phishing, botnets, and malware;
- Authentication Procedures: Verisign, NIKON CORPORATIONʹs selected backend registry services provider, uses two-factor authentication to augment security protocols for telephone, email, and chat communications;
- Malware Code Identification: This safeguard reduces opportunities for abusive behaviors that use registered domain names in the gTLD. Registrants are often unknowing victims of malware exploits. As NIKON CORPORATIONʹs backend registry services provider, Verisign has developed proprietary code to help identify malware in the zones it manages, which in turn helps registrars by identifying malicious code hidden in the computer systems accessible through domain names;
- DNSSEC Signing Service: Domain Name System Security Extensions (DNSSEC) helps mitigate pharming attacks that use cache poisoning to redirect unsuspecting users to fraudulent websites or addresses. It uses public key cryptography to digitally sign DNS data when it comes into the system and then validate it at its destination. The .NIKON gTLD is DNSSEC-enabled as part of Verisignʹs core backend registry services.

Lastly, NIKON CORPORATION will also ensure in all cases that its approved Registrar(s) will adopt appropriate anti-abuse mechanisms, respond to abuse processes and third party rights protection mechanisms and processes, in dealing with any domain name registrations, renewals and use, on behalf of NIKON CORPORATION. This will ensure that highly skilled, specialized and scalable resources are on hand to address any possible rights protection issues both during the startup phase of the TLD and continually during operations of the TLD.
An example of the type of processes that Registrar(s) will be required to have in place for managing e.g. a UDRP claim is described at the end of the response to Question 29*** (see end of document).
NIKON CORPORATION will ensure that Registrar(s) are contractually bound to provide high quality and responsive management of rights protection queries.


B. REGISTRY OPERATOR PROVIDED RIGHTS PROTECTION MECHANISMS

NIKON CORPORATION has engaged Verisign to provide certain registry operation services, amongst which, are the technical functions required to implement the mechanisms outlined below in respect of sunrise periods, trademark claims periods and the interaction with the Trademark Clearinghouse. The manner in which these elements will be addressed by the various parties is set out in this section. It should be noted that because ICANN, as of the time of this application submission, has not issued final guidance with respect to the Trademark Clearinghouse, NIKON CORPORATION cannot fully detail the specific implementation of the Trademark Clearinghouse within this application. NIKON CORPORATION will adhere to all processes and procedures to comply with ICANN guidance once this guidance is finalized.

Sunrise Services
NIKON CORPORATION acknowledges that, although the .NIKON domain is intended to be limited exclusively to registrations by NIKON CORPORATION and its affiliates as defined in the response to Question 28, the gTLD Applicant Guidebook provides that all new gTLDs must provide a sunrise period before general registration of domain names.

NIKON CORPORATION confirms that it will implement a sunrise service pre-registration procedure for domain names for 30 days prior to the launch of the general registration of domain names. Prior to the Sunrise Period commencing, NIKON CORPORATION will establish and then notify its registry service provider of the sunrise eligibility requirements for the gTLD. NIKON CORPORATION may register domain names which meet the sunrise eligibility requirements. The registrant of any registrations of domain names during this period must agree to be subject to the Sunrise Dispute Resolution Policy (SDRP) consistent with Section 6 of the Trademark Clearinghouse Rules as set forth by ICANN. During this period, NIKON CORPORATION, and its approved registrars, will verify whether or not a particular domain name is eligible to be registered on an individual case by case basis before adding the necessary command to the Shared Registry Service (SRS) to register the applicable domain name.

Trademark Claims Service
In respect of the .NIKON domain, NIKON CORPORATION will provide a trademark claims service for a minimum of sixty (60) days after it has permitted general registration of domain names in the .NIKON domain. During this period, NIKON CORPORATION (or its approved registrars on its behalf) shall validate each request for registration of a domain name against trademarks registered in the Trademark Clearinghouse and shall (where applicable) provide notice to each prospective Registrant of a domain name that it is an identical match (as defined in the gTLD Applicant Guidebook) to the mark holder validated in the Trademark Clearinghouse, in the form required by ICANN. The Approved Registrar(s) will then require each registrant to provide the warranties set out in the gTLD Applicant Guidebook before registration of the particular domain name. Those warranties will include receipt and understanding of the Trademark Claims Notice and confirmation that registration and use of said domain name will not infringe on the trademark rights of the mark holders listed. Without receipt of said warranties, NIKON CORPORATION or NIKON CORPORATIONʹs approved Registrar will not process the domain name registration.

NIKON CORPORATION and⁄or its approved Registrar(s) (as applicable) will be responsible for determining whether a domain name is eligible to be registered and will do so for each domain name before submitting an add command to the gTLD Shared Registry Service to register the applicable domain name.

Following the registration of a domain name, the holders of trademarks that have been previously validated by the Trademark Clearinghouse as an identical match, will receive a notice of the domain name registration by NIKON CORPORATION or NIKON CORPORATIONʹs approved Registrar (as applicable), in the form required by ICANN.

General registration period
Following the expiry of the trademark claims service, NIKON CORPORATION (through its appointed registrar(s) may nevertheless continue to require potential domain names in the .NIKON domain to be validated against trademarks registered in the Trademark Clearinghouse as part of its internal approval process prior to the registration being approved. This will be subject to the final rules for the Trademark Clearinghouse, and reasonable commercial terms for the on-going use of the Trademark Clearinghouse for this purpose.

NIKON CORPORATION will implement processes to enable Internet users or third parties to lodge complaints about any domain names in the .NIKON which the complainant claims is infringing a third partyʹs intellectual property rights in some way. These processes will include mechanisms for rapid suspension of an infringing domain name (including but not limited to via ICANNʹs URS system). The abuse point of contact resources described in the response to Question 28 above will also be tasked with responding to complaints in relation to rights protection.


C. Dispute Resolution

NIKON CORPORATION will comply with the dispute resolution mechanisms required by ICANN including the Trademark Post-Delegation Dispute Resolution Procedure (PDDRP), the Registration Restriction Dispute Resolution Procedure (RRDRP), the URS, and the UDRP. All registrations of domain names will be subject to compliance with the above procedures and policies, should any relevant disputes occur. NIKON CORPORATION will act as the primary contact for handling inquiries relating to malicious conduct in the gTLD. The primary contact will investigate and respond to all complaints and incidents within a reasonable time and be empowered to take effective action within well-defined written criteria to guide those actions. Action will be taken in line with what is set out in the answers to Question 28 and 29 and the registration policy for the .NIKON.


D. Resource planning

Resource planning specific to backend Registry activities Verisign, NIKON CORPORATIONʹs selected backend registry
services provider, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 - Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLDʹs initial implementation and ongoing maintenance. Verisignʹs pricing for the backend registry services it provides to NIKON CORPORATION fully accounts for cost related to this infrastructure, which is included in the registry services provider costs in Section I.K ʺOutsourcing Operating Costsʺ, within the Question 46 financial projections response.

Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force. (Current statistics are publicly available in Verisignʹs quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100 percent of the time for more than 13 years for .com, proving Verisignʹs ability to align personnel resource growth to the scale increases of Verisignʹs TLD service offerings.

Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support the implementation of RPMs:

- Customer Affairs Organization: 9
- Customer Support Personnel: 36
- Information Security Engineers: 11

To implement and manage the .NIKON gTLD as described in this application, Verisign, NIKON CORPORATIONʹs selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area.

When usage projections indicate a need for additional staff, Verisignʹs internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed gTLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internetʹs largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.

Resource planning specific to engaging third party registrars NIKON CORPORATION has effectively mitigated the risk of abuse in the gTLD and foresees assigning a member of staff to act as the primary points of contact for handling inquiries relating to malicious or abusive conduct in the TLD. NIKON CORPORATION is committed to ensuring that sufficient resources are made available at all times. However, given the restricted nature of the gTLD, NIKON CORPORATION does not currently expect that this role will require a full-time resource. NIKON CORPORATION may engage its third party registrar(s) and its selected back end registry services provider, Verisign to perform some or all of the tasks associated with abuse issues. This will ensure that highly skilled, specialized and scalable resources are on hand to address any possible abuse issues both during the startup phase of the TLD and continually during operations of the TLD.


E. Conclusion

The approach outlined in this answer clearly shows that the risk of abuse in the .NIKON TLD has been extensively mitigated and as a direct result is very low. NIKON CORPORATION is committed to ensuring that abuse will not be tolerated. The proposed policies and methods for addressing any abuse exceed the standard outlined in the gTLD Applicant Guidebook and is more than commensurate with the risks identified, NIKON CORPORATION is, therefore, entitled to a score of two points for its response to Question 29.


***
Example of a draft process for a Registrarʹs handling of UDRP claims

Request for Registrar Verification
ʹRequest for Registrar Verificationʹ emails are received from the provider of UDRP, and are the official ʺbeginningʺ of the UDRP case. These emails normally ask the Registrar to verify the domain name and the corresponding registrant details. The Registrar can ONLY ever lock a domain name following receipt of one of these emails. The receipt of a copy of a complaint does not indicate the beginning of a dispute.

The two most commonly used providers are the National Arbitration Forum (NAF) and the World Intellectual Property Organization (WIPO). NAF requests will generally have the subject ʺDomain Name Dispute Verification Requestʺ. WIPO requests will generally have the subject ʺRequest for Registrar Verificationʺ

When such a request is received, the following steps need to be taken:
1. Update the UDRP Spreadsheet with the complaint details
2. Create a response to UDRP Provider
3. Send a confirmation to the complainant of receipt of complaint and inform of registrar lock and the circumstances under which the lock will expire
4. Change domain name Registry Key
5. Assign domain name to the ʹABCDisputesʹ account
6. Lock domain name
7. Advise Registrant of UDRP ⁄ create New Case
8. Spreadsheet finalization

When a copy of the UDRP complaint is received:
- Make a note in the spreadsheet of where to access the complaint.

When a notice of ʺcommencement of UDRPʺ received:
- Save the domain name in the case and resolve.
- If a copy of the complaint has been attached, follow process in above.

When a notice of ʺSuspensionʺ or ʺStayʺ of proceedings is received:
Sometimes, the parties to the UDRP may reach an agreement to settle the matter outside of the UDRP. If the parties contact the registrar directly and indicate that they (the respondent) wish to transfer the domain name to the complainant, the registrar must direct them to the UDRP provider where they must have the proceedings ʺstayedʺ (sometimes called ʺsuspendedʺ). The registrar may only transfer a domain name once official notice from the provider has been received.

If a notice is received from the UDRP provider PRIOR to the registrar being contacted by the parties:
- Respond to everyone who has been emailed a copy of the notice, with the template ʺUDRP - Notice of stay of proceedings. This includes instruction that the registrar require written authorization from the respondent before releasing the domain name from registrar lock.

Once the registrar has received BOTH authorization from the current registrant, and official notice of suspension from the provider, the domain name may be transferred to the complainant.

Note, the registrar is only able to transfer the domain name to the complainant. The Registrar is not able to transfer the domain name to any other party.

When a UDRP decision is received:
When WIPO sends a notice of decision, the subject will be ʺNotification of Decisionʺ. When NAF sends a notice of decision, the subject will be ʺDECISION - Complainant v Respondentʺ

To view the decision:
1. Locate the decision
2. Scroll to the end of the decision document and note whether the decision is for the complainant or the respondent:
- A decision for the complainant will be described as ʺthe domain name is ordered to be transferred from the respondent to the complainant (follow process (a), below)
- A decision for the respondent will be described as ʺthe complaint is deniedʺ (follow process (b), below)

Responding to the email regarding the decision:
1. If decision is for the complainant:
Schedule the transfer for 10 working days time:
- Add end date to calendar
- Open the UDRP spreadsheet and make a note that the decision is for the complainant and note the date the name is scheduled to be transferred.

2. If decision is for the respondent:
Open the UDRP spreadsheet and locate the name of the reseller account (if any) which this domain name was on prior to the UDRP, then:
- Move the domain name from the ABCDISPUTES account
- Unlock the domain name
- Send the registrant the new registry key

Implementation of the decision for complainant - transfer of domain name:
1. Copy of Complaint received? - check UDRP Spreadsheet to make sure
2. Assigning domain name to new Channel Partner (CP) & Update domain name
3. Unlock the domain name
4. Change Contact Details for domain name
5. Password Recovery
6. CRM case creation ⁄ Notice of Transfer of License
7. Update UDRP Spreadsheet - indicate that the case is closed


The Question 46 ʺmost likelyʺ financial projections template, see the Q46_Mostlikely_Financial_Projection_nikon.xlsx attached.


30A. Security Policy: provide a summary of the security policy for the proposed registry, including but not limited to:To be eligible for a score of 2, answers must also include:A summary of the above should be no more than 20 pages. Note that the complete security policy for the registry is required to be submitted in accordance with 30(b).

1 DETAILED DESCRIPTION OF PROCESSES AND SOLUTIONS DEPLOYED TO MANAGE LOGICAL SECURITY ACROSS INFRASTRUCTURE AND SYSTEMS, MONITORING AND DETECTING THREATS AND SECURITY VULNERABILITIES AND TAKING APPROPRIATE STEPS TO RESOLVE THEM

NIKON CORPORATION(Nikon)ʹs selected backend registry services providerʹs (Verisignʹs) comprehensive security policy has evolved over the years as part of managing some of the worldʹs most critical TLDs. Verisignʹs Information Security Policy is the primary guideline that sets the baseline for all other policies, procedures, and standards that Verisign follows. This security policy addresses all of the critical components for the management of backend registry services, including architecture, engineering, and operations. Verisignʹs general security policies and standards with respect to these areas are provided as follows:

* Architecture
- Information Security Architecture Standard: This standard establishes the Verisign standard for application and network architecture. The document explains the methods for segmenting application tiers, using authentication mechanisms, and implementing application functions.
- Information Security Secure Linux Standard: This standard establishes the information security requirements for all systems that run Linux throughout the Verisign organization.
- Information Security Secure Oracle Standard: This standard establishes the information security requirements for all systems that run Oracle throughout the Verisign organization.
- Information Security Remote Access Standard: This standard establishes the information security requirements for remote access to terminal services throughout the Verisign organization.
- Information Security SSH Standard: This standard establishes the information security requirements for the application of Secure Shell (SSH) on all systems throughout the Verisign organization.

* Engineering
- Secure SSL⁄TLS Configuration Standard: This standard establishes the information security requirements for the configuration of Secure Sockets Layer⁄Transport Layer Security (SSL⁄TLS) for all systems throughout the Verisign organization.
- Information Security C++ Standards: These standards explain how to use and implement the functions and application programming interfaces (APIs) within C++. The document also describes how to perform logging, authentication, and database connectivity.
- Information Security Java Standards: These standards explain how to use and implement the functions and APIs within Java. The document also describes how to perform logging, authentication, and database connectivity.

* Operations
- Information Security DNS Standard: This standard establishes the information security requirements for all systems that run DNS systems throughout the Verisign organization.
- Information Security Cryptographic Key Management Standard: This standard provides detailed information on both technology and processes for the use of encryption on Verisign information security systems.
- Secure Apache Standard: Verisign has a multitude of Apache web servers, which are used in both production and development environments on the Verisign intranet and on the Internet. They provide a centralized, dynamic, and extensible interface to various other systems that deliver information to the end user. Because of their exposure and the confidential nature of the data that these systems host, adequate security measures must be in place. The Secure Apache Standard establishes the information security requirements for all systems that run Apache web servers throughout the Verisign organization.
- Secure Sendmail Standard: Verisign uses sendmail servers in both the production and development environments on the Verisign intranet and on the Internet. Sendmail allows users to communicate with one another via email. The Secure Sendmail Standard establishes the information security requirements for all systems that run sendmail servers throughout the Verisign organization.
- Secure Logging Standard: This standard establishes the information security logging requirements for all systems and applications throughout the Verisign organization. Where specific standards documents have been created for operating systems or applications, the logging standards have been detailed. This document covers all technologies.
- Patch Management Standard: This standard establishes the information security patch and upgrade management requirements for all systems and applications throughout Verisign.

* General
- Secure Password Standard: Because passwords are the most popular and, in many cases, the sole mechanism for authenticating a user to a system, great care must be taken to help ensure that passwords are ʺstrongʺ and secure. The Secure Password Standard details requirements for the use and implementation of passwords.
- Secure Anti-Virus Standard: Verisign must be protected continuously from computer viruses and other forms of malicious code. These threats can cause significant damage to the overall operation and security of the Verisign network. The Secure Anti-Virus Standard describes the requirements for minimizing the occurrence and impact of these incidents.

Security processes and solutions for the .nikon TLD are based on the standards defined above, each of which is derived from Verisignʹs experience and industry best practice. These standards comprise the framework for the overall security solution and applicable processes implemented across all products under Verisignʹs management. The security solution and applicable processes include, but are not limited to:
- System and network access control (e.g., monitoring, logging, and backup)
- Independent assessment and periodic independent assessment reports
- Denial of service (DoS) and distributed denial of service (DDoS) attack mitigation
- Computer and network incident response policies, plans, and processes
- Minimization of risk of unauthorized access to systems or tampering with registry data
- Intrusion detection mechanisms, threat analysis, defenses, and updates
- Auditing of network access
- Physical security

Further details of these processes and solutions are provided in Part B of this response.

1.1 Security Policy and Procedures for the Proposed Registry
Specific security policy related details, requested as the bulleted items of Question 30 - Part A, are provided here.

Independent Assessment and Periodic Independent Assessment Reports:
To help ensure effective security controls are in place, .nikon, through its selected backend registry services provider, Verisign, conducts a yearly American Institute of Certified Public Accountants (AICPA) and Canadian Institute of Chartered Accountants (CICA) SAS 70 audit on all of its data centers, hosted systems, and applications. During these SAS 70 audits, security controls at the operational, technical, and human level are rigorously tested. These audits are conducted by a certified and accredited third party and help ensure that Verisign in-place environments meet the security criteria specified in Verisignʹs customer contractual agreements and are in accordance with commercially accepted security controls and practices. Verisign also performs numerous audits throughout the year to verify its security processes and activities. These audits cover many different environments and technologies and validate Verisignʹs capability to protect its registry and DNS resolution environments. Figure 30A-1 lists a subset of the audits that Verisign conducts. For each audit program or certification listed in Figure 30A-1, Verisign has included, as attachments to the Part B component of this response, copies of the assessment reports conducted by the listed third-party auditor. From Verisignʹs experience operating registries, it has determined that together these audit programs and certifications provide a reliable means to ensure effective security controls are in place and that these controls are sufficient to meet ICANN security requirements and therefore are commensurate with the guidelines defined by ISO 27001.

Augmented Security Levels or Capabilities: See Section 5 of this response.

Commitments Made to Registrants Concerning Security Levels: See Section 4 of this response.


2 SECURITY CAPABILITIES ARE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY

Consistency of Business Approach and Planned Size of Registry:
Verisign, Nikonʹs selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisignʹs infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies.

Verisignʹs scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the .nikon gTLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 - Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisignʹs pricing for the backend registry services it provides to .nikon fully accounts for cost related to this infrastructure, which is provided as the ʺBackend registry servicesʺ in Section I.K.i and I.K.ii of ʺOutsourcing Operating Costsʺ Template-1 within the Question 46 financial projections response.


3 TECHNICAL PLAN ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION

Resource Planning:
Verisign, Nikonʹs selected backend registry services provider, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 - Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLDʹs initial implementation and ongoing maintenance. Verisignʹs pricing for the backend registry services it provides to Nikon fully accounts for cost related to this infrastructure, which is provided as the ʺBackend registry servicesʺ in Section I.K.i and I.K.ii of ʺOutsourcing Operating Costsʺ Template-1 within the Question 46 financial projections response.

Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force. (Current statistics are publicly available in Verisignʹs quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100 percent of the time for more than 13 years for .com, proving Verisignʹs ability to align personnel resource growth to the scale increases of Verisignʹs TLD service offerings.

Verisign projects it will use the following personnel role, which is described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support its security policy:
- Information Security Engineers: 11

To implement and manage the .nikon gTLD as described in this application, Verisign, Nikonʹs selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area.

When usage projections indicate a need for additional staff, Verisignʹs internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed gTLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internetʹs largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.


4 SECURITY MEASURES ARE CONSISTENT WITH ANY COMMITMENTS MADE TO REGISTRANTS REGARDING SECURITY LEVELS

Verisign is Nikonʹs selected backend registry services provider. For the .nikon gTLD, no unique security measures or commitments must be made by Verisign or Nikon to any registrant.


5 SECURITY MEASURES ARE APPROPRIATE FOR THE APPLIED-FOR gTLD STRING (FOR EXAMPLE, APPLICATIONS FOR STRINGS WITH UNIQUE TRUST IMPLICATIONS, SUCH AS FINANCIAL SERVICES-ORIENTED STRINGS, WOULD BE EXPECTED TO PROVIDE A COMMENSURATE LEVEL OF SECURITY)

No unique security measures are necessary to implement the .nikon gTLD. As defined in Section 1 of this response, Verisign, Nikonʹs selected backend registry services provider, commits to providing backend registry services in accordance with the following international and relevant security standards:
- American Institute of Certified Public Accountants (AICPA) and Canadian Institute of Chartered Accountants (CICA) SAS 70
- WebTrust⁄SysTrust for Certification Authorities (CA)


6 ATTACHMENT

Following figure is provided in the attachment file, see the Q30A_Figures_nikon.pdf attached.
- Figure 30A-1

Nikon and Verisign have executed agreements for the purpose of providing the necessary back-end services for fulfilling the registry services requirement under Nikonʹs Registry Agreement with ICANN. Please see the attachment of question 47a Q47a_LOI_for_RegistryServices_nikon.pdf for evidence.



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