ICANN New gTLD Application

New gTLD Application Submitted to ICANN by: OBI Group Holding SE & Co. KGaA

String: obi

Originally Posted: 13 June 2012

Application ID: 1-1739-45800


Applicant Information


1. Full legal name

OBI Group Holding SE & Co. KGaA

2. Address of the principal place of business

Albert-Einstein-Strasse 7-9
42949 Wermelskirchen
DE

3. Phone number

+4921967601

4. Fax number

+492196761019

5. If applicable, website or URL

http:⁄⁄www.obi.de

Primary Contact


6(a). Name

Mr. Hermann-Josef Kessel

6(b). Title

Managing Director Corporate Legal

6(c). Address


6(d). Phone Number

+492196761449

6(e). Fax Number

+492196761590

6(f). Email Address

gtld@obi.de

Secondary Contact


7(a). Name

Mr. Oliver Tackmann

7(b). Title

Managing Director IT

7(c). Address


7(d). Phone Number

+492196761992

7(e). Fax Number

+492196761666

7(f). Email Address

oliver.tackmann@obi.de

Proof of Legal Establishment


8(a). Legal form of the Applicant

corporation

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

Germany

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

Attachments are not displayed on this form.

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


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


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


Applicant Background


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

Dieter MessnerManaging Director International
Oliver GeilingCFO
Paolo AlemagnaManaging Director Corporate Category Management, PEM, Logistics
Sergio GiroldiCEO

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

Hermann-Josef KesselManaging Director Corporate Legal
Oliver TackmannManaging Director IT

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.

obi

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


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


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


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


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


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


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


15(a). If an IDN, Attach IDN Tables for the proposed registry.

Attachments are not displayed on this form.

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


15(c). List any variant strings to the applied-for gTLD string according to the relevant IDN tables.


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

Since the .obi gTLD is an ASCII-only string, there are no known operational or rendering problems. The situation is comparable to other strings such as .com, .net or .de, where also no issues could be identified.

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


Mission/Purpose


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

OBI is one of the leading brands in the worldwide DIY („Do it yourself“) market. Measured by the annual turnover, OBI is the seventh most profitable DIY-company in the world. In Europe, OBI has the third largest turnover and in Germany OBI is the undisputed No. 1. 
The OBI Group has 143 affiliated companies. Today, OBI operates 579 stores throughout Europe with more than 40.500 employees. Besides the German home market with actually 343 stores, OBI is also present in Austria, Bosnia-Herzegovina, Croatia, Czech Republic, Hungary, Italy, Poland, Romania, Russia, Slovenia, Switzerland and Ukraine and intends to expand to more countries.
The mission of the proposed „.obi“ gTLD is to serve as an exclusive namespace for the OBI brand. Only OBI shall be eligible to register Second Level Domains in the „.obi“ namespace. A right to use registered domain names will be granted to group companies, franchise partners and possibly a limited number of contractors subject to policies and conditions set up by OBI.

The proposed gTLD „.obi“ shall serve multiple purposes:

1. The proposed „.obi“ gTLD will make it easier for users to find information about OBI markets.
2. The proposed „.obi“ gTLD will make it easier for users to find information about products or product categories.
3. The proposed „.obi“ gTLD will make it easier for users to find corporate information.
4. The proposed „.obi“ gTLD will help forge consumer trust in e-commerce.
5. The proposed „.obi“ gTLD will open opportunities for OBI to establish new innovative business models.
6. The proposed „.obi“ gTLD will help avoid fragmentation of the company-wide use of domain names at the global level.
7. The proposed „.obi“ gTLD will help the company to improve its international unique and unified appearance.
8. The proposed „.obi“ gTLD will facilitate OBI’s digital brand management at the international level.
9. The „.obi“ namespace will provide for a safer and more secure surfing experience.
10. The proposed „.obi“ gTLD shall reduce the risk of users being deceived by offers or information allegedly originating from OBI and therefore mitigate the risk of users becoming victims of abusive behaviour and malicious conducts.

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Not only will OBI promote the new TLD as such, but also the structure and syntax of the namespace and how it is used. This will help users to intuitively find information and products they are looking for.
According to current plans, there will be different categories of domain names that will consistently be used. The following non-exhaustive list of such categories, which may be subject to change, gives examples of use cases of the „.obi“ domain names.

- country.obi, such as germany.obi, austria.obi or hungary.obi and city.obi, such as munich.obi, vienna.obi (subject to the respective procedures for geographic names)
- market.obi, such as koeln-marsdorf.obi
- productcategory.obi, such as tools.obi, wallpaper.obi
- product.obi, such as screwdriver.obi, socket.obi or mowing-machine.obi
- name-of-manufacturer-or-brand.obi, such as lux-tools.obi or montana.obi
- campaign-or-special-offer.obi, such as giftcard.obi, top-customer-card.obi or spring-competition.obi
- special service performance, such as services.obi or rental-equipment.obi
- corporate.obi, such as jobs.obi or marketing.obi
- group consolidated legal entities and franchisees, such as obigroupholding.obi

Registrations and use of domain names, in particular with geographic names, are subject to the respective policies applicable for the „.obi“ gTLD.
Such approach of structuring information provided by OBI may also support accessing and finding information by means of search engines.

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OBI will implement a consistent program to establish and forge consumer trust for the whole namespace, e.g. by means of certificates, payment methods or quality seals.

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OBI believes that new and innovative business models using the DNS can and will be rolled out in the near and mid-term future. OBI therefore wishes to be prepared in terms of the technical infrastructure should OBI choose to introduce such services.

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According to OBI’s plans, the company group will expand to new markets and intensify its presence in existing markets. As a consequence, there is no certainty whatsoever, that domain names are available for registration to ensure a unified and consistent domain use in the respective gTLD and ccTLD namespaces. The exclusive „.obi“ TLD enables OBI to establish and maintain a domain name portfolio that is consistent, under OBI’s sole control and deployable at the global level.

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OBI will use a policy framework providing including content restrictions to make the „.obi“ zone a familiy-friendly service. Additionally, there are contractual requirements and sanctions for the promotion of domain names and content or services offered thereunder. OBI deploys the Registry Service Provider’s malware scan for the whole namespace as an additional means to mitigate the risk of e.g. servers being intruded and misused for the dissemination of malicious code.

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OBI will communicate to its target group that information from the company can actually be found in the OBI namespace. By doing so, the user is educated that other domain names may not be operated by OBI or its contractors.

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

ad i – iii:
In order to avoid duplication, we refer to the information provided in response to question 18. a).
Since only OBI will be eligible to register domain names under the „.obi“ TLD, the benefits are restricted to this entity and potentially to those who are granted the right to use registered domain names.
By limiting the number of eligible users of the namespace, OBI will ensure that only information or services originating from OBI, a group company or business partner relevant to OBI’s business will be made available under the proposed gTLD. By doing so, users will be given the benefit of additional trust in the information provided. Content restrictions and acceptable use policies will give the namespace a good reputation as the user can be sure that only information he or she expects from a DIY site will be available in the namespace. This is a speciality for the namespace. In addition to the TLD as a recognition feature for OBI, OBI will also make the use of OBI styleguides mandatory for the use of the namespace. This will help increase the reputation of the namespace as a source of original information. Since there will only be one registrant, namely OBI itself, Whois will be 100% accurate.
User will benefit from directory services both that will be established under the proposed TLD in terms of categories, topics, products, locations and language.
OBI expects that more brands will make use comparable services. Further, OBI expects that Internet users will learn that new dotBrand namespaces can be used intuitively. Such services could not be established without using third level domain names prior to the establishment of new gTLDs.

iv. In order to support the goals mentioned above, OBI will issue the „.OBI Eligibility Policy“ which clearly states that the only eligible registrant for domain names under the .obi gTLD is Obi Group Holding GmbH.
Also, in the „.obi Domain Name Policy“ a demarcation of acceptable use versus abuse will be depicted. Abuse is defined as „registration abuse“ and „usage abuse“ as follows:
“Registration abuse” is:
* The use of faulty⁄falsified⁄incomplete⁄stolen person-related or company-related data on registration (danger to WHOIS accuracy, see below);
* Cybersquatting⁄typosquatting;
* Registration of illegal domain names (see question 29).
“Usage abuse” is:
* Violation of applicable laws or regulation; in particular the provisions of the German Criminal Code, the German Youth Protection Act and the German Interstate Treaty on the Protection of Minors in the Media (JMStV). Only such contents are permissible which may be made available to underaged persons without any restrictions;
* Use of a domain to publish content which incites to hatred against parts of the population or against a national, racial, religious or ethnic group, content which glorifies violence, content which violates the human dignity, content which denies or plays down acts committed under the National Socialist regime;
* Distribution of child abusive material;
* Use of a domain name for the dissemination of spam, i.e. unsolicited bulk electronic communication (e-mail, instant messaging, on websites, in forums or mobile messaging) or advertising a domain name by means of spam.
* Use of a domain name for Distributed Denial-of-service attacks (“DDoS attacks”);
* Use of domain names in phishing activities, tricking Internet users into divulging personal data such as names, addresses, usernames, passwords, or financial data;
* Use of domain names in pharming , such as DNS hijacking and DNS cache poisoning;
* Use of domain names for the intentional distribution of malicious code such as spyware, botware, keylogger bots, viruses, worms or trojans;
* Use of domain names to command and control botnets , i.e. a network of compromised computers or “zombies,”
* Use of domain names in activities intended to gain illegal access to other computers or networks (“hacking”), as well as any activity to prepare for such a system penetration; or
* Use of a domain name fast flux hosting, disguising the location of internet addresses or Internet services.

With OBI’s “.obi Abuse Reporting and Takedown Policy“ escalation procedures, response times and sanctions are clearly described to ensure that unlikely abuse cases are swiftly and efficiently dealt with and objectionable content is removed expediently, domain registrations are suspended or deleted or other threats and abuse types are adequately countered. A detailed description of the policy can be found in the answer to question 28.
Further, OBI will have contractual agreements with all parties, may they be group companies or franchisees e.g. that are allowed to use domain names to bindingly agree upon acceptable use, abuse handling and the respective sanctions.

v. Since the proposed TLD will be used for business purposes of OBI and its contractors exclusively, there will be no measures to protect the privacy or confidential information of registrants and users since there is no need for doing so. Should personal information of users be collected or processed in connection with the use of the namespace, such information must be treated in accordance with applicable data protection laws. As mentioned above, OBI will apply content restrictions as well as an Acceptable Use Policy for the proposed gTLD. Abiding by applicable data protection laws is one aspect of this. Breaches would be a violation of these rules and thereby a violation of the contract, that can lead to the termination of the registration agreement or the use of the domain name used for by the infringing party.
OBI plans to use domain names under the proposed gTLD in its communication to users and contractors and in marketing campaigns both on- and offline. By doing so, the proposed TLD and its benefits will be brought to the attention of the target audiences.
Today OBI communicates it´s current B2C website www.obi.de as cross link in any kind of communication. The media mix consists of broad media (TV and Billboard), leaflet as main activation tool, direct mailing, radio, online and other advertisement media. The proposed gTLD will be also communicated within this mix.

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

Only Obi Group Holding GmbH will be an eligible registrant for .obi domain names. This will be laid down in the OBI Eligibility Policy. In addition to that, OBI will implement all Rights Protection Mechanisms as required by ICANN. This commitment applies both for currently known RPMs as well as those yet to be defined or imposed at a later stage by means of consensus policies. 
As a consequence, there is no risk of cybersquatting or speculative registrations that could possibly cause costs, e.g. for defensive registrations.
In addition to that, OBI uses content restrictions to ensure that all contents and services offered under ʺ.obiʺ domain names are family-friendly.
As contractors such as franchisees might be granted the right to use domain names (registered by Obi Group Holding GmbH), contractual agreements with these parties including sanctions and including the policies for the .obi gTLD will ensure that the name space will be used in a compliant manner.
A clear demarcation of acceptable use versus abuse is detailed in the .OBI Domain Name Policy, which will be enforced by means of robust escalation procedures including response times to provide for swift action, if needed.

i) The only eligible registrant will be OBI, which is why multiple applications for a particular domain name will not occur. As a consequence, there will be no mechanisms to resolve such conflicts.
However, OBI wishes to grant the right of use regarding specific domain names to contractors, e.g. franchise partners that run OBI markets. Since there are multiple markets in certain cities, it is not possible to allocate a second level domain name in the format of city.obi to each market. It is therefore planned to resolve such conflicts by implementing a landing page for such cities and link the markets under their name or the name of the quarter where they are located or another unique identifier (e.g. koeln-marsdorf.obi).

ii) Since no registration fees will be charged by the registry, there are no such cost benefits.

iii) Registrations will be possible for the duration of one to ten years. Since no registration fees will be charged, no commitments in terms of price increases will be made.

Community-based Designation


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

No

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


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


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


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


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


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

Attachments are not displayed on this form.

Geographic Names


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

No

Protection of Geographic Names


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

OBI is committed to protecting geographic names at the second and other levels in the .obi gTLD. 

OBI pledges to

- adopt, before the new gTLD is introduced, appropriate procedures for blocking, at no cost and upon demand of governments, public authorities or IGOs, names with national or geographic significance at the second level of the .obi gTLD and
- ensure procedures to allow governments, public authorities or IGOs to challenge abuses of names with national or geographic significance at the second level of the .obi gTLD.

OBI will adhere to Specification 5 of the new gTLD Agreement and is ready to follow the procedure mutatis mutandis as detailed in the circular letter by the GAC Chair to Governments, distinct economies and public authorities and Members of the ICANN Governmental Advisory Committee of September 9, 2003 regarding the Reservation of Country Names in Dot Info, see https:⁄⁄gacweb.icann.org⁄download⁄attachments⁄1540128⁄dotinfocircular1.pdf?version=3&modificationDate=1318705184000.

However, should the GAC prefer to use other procedures, particularly in the light of the possibly high number of new gTLDs, OBI is ready to consider the implementation of such approach.

OBI is mindful of the fact that any procedure requires seperate approval by ICANN according to Specification 5 of the new gTLD Agreement.

Registry Services


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

1. CUSTOMARY REGISTRY SERVICES
As OBI’s 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. Verisign’s 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. Verisign’s 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. Verisign’s 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 Verisign’s registry services.
Verisign’s 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, Verisign’s 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 application’s registry.

Figure 23-1: Registry Services. Each proposed service has been previously approved by ICANN to ensure registry security and stability.

As further evidence of Verisign’s 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 Verisign’s RFC compliance and includes relevant ICANN prior-service approval actions.

Figure 23-2: ICANN RFC Compliance. Verisign currently operates TLDs in full compliance with each registry service’s applicable RFC(s). Each listed Verisign service has been previously approved by ICANN and is now operational on registries under Verisign management.

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 OBI’s 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.
Figure 23-3: Zone Server Status Information. Verisign provisions to registrars status information related to the TLD.
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 OBI’s 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 OBI’s 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 Verisign’s zone servers are provided in the response to Question 34, Geographic Diversity. Moreover, additional details of Verisign’s 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, OBI’s selected provider of backend registry services, is a proven supporter of ICANN’s 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 .obi gTLD, Verisign implements these services using the same proven processes and procedures currently in-place for all registries under Verisign’s management. Furthermore, Verisign executes these services on computing platforms comparable to those of other registries under Verisign’s management. Verisign’s 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 question’s Notes column to address registry operator services.

2.1 Inter-Registrar Transfer Policy (IRTP)
Technical Component: In compliance with the IRTP consensus policy, Verisign, OBI’s 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 “AuthInfo” 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 ‘ACK’ or acknowledge a transfer prior to the expiration of the five-day Transfer grace period
* Allows the losing registrar to proactively ‘NACK’ 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 ACK’d or NACK’d 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. OBI’s 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 OBI in a consulting capacity as needed.
Unique to the TLD: This service is not provided in a manner unique to the .obi TLD.

2.2 Add Grace Period (AGP) Limits Policy
Technical Component: Verisign’s registry system monitors registrars’ Add grace period deletion activity and provides reporting that permits OBI to assess registration fees upon registrars that have exceeded the AGP thresholds stipulated in the AGP Limits Policy. Further, OBI accepts and evaluates all exemption requests received from registrars and determines whether the exemption request meets the exemption criteria. OBI maintains all AGP Limits Policy exemption request activity so that this material may be included within OBI’s Monthly Registry Operator Report to ICANN.
Registrars that exceed the limits established by the policy may submit exemption requests to OBI for consideration. OBI’s compliance office reviews these exemption requests in accordance with the AGP Limits Policy and renders a decision. Upon request, OBI 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, OBI 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 Concerns: 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, OBI’s backend registry services provider, has had experience with this policy since its implementation in April 2009 and is available to support OBI in a consulting capacity as needed.
Unique to the TLD: This service is not provided in a manner unique to the OBI TLD.

2.3 Registry Services Evaluation Policy (RSEP)
Technical Component: Verisign, OBI’s 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, OBI’s 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 .obi TLD.

3. PRODUCTS OR SERVICES ONLY A REGISTRY OPERATOR IS CAPABLE OF PROVIDING BY REASON OF ITS DESIGNATION AS THE REGISTRY OPERATOR
Verisign, OBI’s 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 ICANN’s purview.
OBI 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 “what users know” (i.e., their user name and password) and “what users have” (i.e., a two-factor authentication credential with a one-time-password).
Registrars can use the one-time-password when communicating directly with Verisign’s 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 Verisign’s 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 .obi TLD.

Demonstration of Technical & Operational Capability


24. Shared Registration System (SRS) Performance

1. ROBUST PLAN FOR OPERATING A RELIABLE SRS
1.1 High-Level Shared Registration System (SRS) System Description
Verisign, OBI’s 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). Verisign’s 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 .obi 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 “registration add attacks” 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 user’s login process that connects to the database allocates a small segment of memory to perform connection overhead, sorting, and data caching. Verisign’s standards mandate that no more than 40 percent of the total available physical memory on the database server will be allocated for these functions.

Verisign’s 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 TLD’s business rules and requirements. The flexible internal design of the application servers allows Verisign to easily leverage existing business rules to apply to the .obi gTLD. The application servers store OBI’s 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 Verisign’s worldwide domain name resolution sites.

Figure 24-1: SRS Architecture. Verisign’s SRS is hierarchically designed to meet the forecasted registration volume of the .obi gTLD, and it can be scaled to meet future registration volume increases.
Scalability and Performance. Verisign, OBI’s 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 Verisign’s 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.

Figure 24-2: Built-in SRS Redundancy. Verisign’s SRS system is built upon multiple layers of redundancy to ensure the system remains highly available.

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 Verisign’s redundant design, Verisign can perform routine maintenance while the remainder of the system remains online and unaffected. For the .obi gTLD registry, this flexibility minimizes unplanned downtime and provides a more consistent end-user experience.

1.2 Representative Network Diagrams
Figure 24-3 provides a summary network diagram of OBI’s selected backend registry services provider’s (Verisign’s) 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.

Figure 24-3: SRS Network Diagram. Verisign’s fully redundant SRS design and geographically separated data centers help ensure service level availability requirements are met.

1.3 Number of Servers
As OBI’s 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. Verisign’s 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 .obi 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 OBI’s selected backend registry services provider’s (Verisign’s) SRS, showing how the SRS component fits into this larger system and interconnects with other system components.

Figure 24-4: Technical Overview. Verisign’s SRS provides the registrar-facing component of the system establishing the zone file needed to enable DNS and Whois services.

1.5 Frequency of Synchronization Between Servers
As OBI’s 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 “hot standby.”

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 Verisign’s 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.
Verisign’s 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 .obi 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. Verisign’s pricing for the backend registry services it provides to OBI fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) 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 OBI’s 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 gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services provided to OBI fully accounts for this personnel-related cost, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) 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 Verisign’s 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 Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s 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

25. Extensible Provisioning Protocol (EPP)

1. COMPLETE KNOWLEDGE AND UNDERSTANDING OF THIS ASPECT OF REGISTRY TECHNICAL REQUIREMENTS
Verisign, OBI’s 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.
Figure 25-1: EPP Implementations. Verisign has repeatedly proven its ability to successfully implement EPP for both small and large registries.
Verisign’s understanding of EPP and its ability to implement code that complies with the applicable RFCs is unparalleled. Mr. Scott Hollenbeck, Verisign’s 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 ICANN’s Registry Operator’s 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 Hollenbeck’s 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, OBI’s 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. Verisign’s 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 (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, OBI’s 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 Verisign’s 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.
Verisign’s 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 .obi 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. Verisign’s pricing for the backend registry services it provides to OBI fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.

3. TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION
Verisign, OBI’s 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 gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to OBI fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) 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 Verisign’s 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 Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s 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 .obi gTLD as described in this application, Verisign, OBI’s 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’s 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 Internet’s 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, OBI’s 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. Verisign’s 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. Verisign’s 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 .obi 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 Verisign’s Scott Hollenbeck)
* EPP 5730 (http:⁄⁄tools.ietf.org⁄html⁄rfc5730): Base EPP specification (authored by Verisign’s Scott Hollenbeck)
* EPP Domain 5731 (http:⁄⁄tools.ietf.org⁄html⁄rfc5731): EPP Domain Name Mapping specification (authored by Verisign’s Scott Hollenbeck)
* EPP Host 5732 (http:⁄⁄tools.ietf.org⁄html⁄rfc5732): EPP Host Mapping specification (authored by Verisign’s Scott Hollenbeck)
* EPP Contact 5733 (http:⁄⁄tools.ietf.org⁄html⁄rfc5733): EPP Contact Mapping specification (authored by Verisign’s Scott Hollenbeck)
* EPP TCP 5734 (http:⁄⁄tools.ietf.org⁄html⁄rfc5734): EPP Transport over Transmission Control Protocol (TCP) specification (authored by Verisign’s Scott Hollenbeck)
* EPP DNSSEC 5910 (http:⁄⁄tools.ietf.org⁄html⁄rfc5910): EPP Domain Name System Security Extensions (DNSSEC) Mapping specification (authored by Verisign’s James Gould and Scott Hollenbeck)

5. PROPRIETARY EPP EXTENSIONS
Verisign, OBI’s 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 Verisign’s 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 commands’ request and response formats. The current EPP implementations managed by Verisign, OBI’s 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.

Attachment 25-2: EPP Schema

6. PROPRIETARY EPP EXTENSION CONSISTENCY WITH REGISTRATION LIFECYCLE
OBI’s selected backend registry services provider’s (Verisign’s) 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.

26. Whois

1. COMPLETE KNOWLEDGE AND UNDERSTANDING OF THIS ASPECT OF REGISTRY TECHNICAL REQUIREMENTS
Verisign, OBI’s 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 .obi 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 OBI’s selected backend registry services provider’s (Verisign’s) registry service, Verisign’s Whois system is designed and built for both reliability and performance in full compliance with applicable RFCs. Verisign’s 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 Verisign’s 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 .obi gTLD registry as it is Verisign’s 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.
Verisign’s Whois response time has been less than 500 milliseconds for 95 percent of all Whois queries in .com, .net, .tv, and .cc. The response time in these TLDs, combined with Verisign’s 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.〈TLD〉 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 (Internet Engineering Task Force).
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.TLD
* For registrar: whois ʺregistrar Example Registrar, Inc.ʺ
* For name server: whois ʺNS1.EXAMPLE.TLDʺ 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.〈TLD〉
* Click on the appropriate button (Domain, Registrar, or Name Server)
* Enter the applicable parameter:
o Domain name, including the TLD (e.g., EXAMPLE.TLD)
o Full name of the registrar, including punctuation (e.g., Example Registrar, Inc.)
o Full host name or the IP address (e.g., NS1.EXAMPLE.TLD or 198.41.3.39)
* 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, OBI’s 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.
Verisign’s 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, OBI’s selected backend registry services provider. The figure details the configuration with one resolution⁄Whois site. For the .obi gTLD Verisign provides Whois service from 6 of its 17 primary sites based on the proposed gTLD’s traffic volume and patterns. A functionally equivalent resolution architecture configuration exists at each Whois site.
Figure 26-1: Whois Service Network Diagram. By distributing Whois service across multiple resolution sites, Whois transactions are highly available and performed with low latency.
1.3 IT and Infrastructure Resources
Figure 26-2 summarizes the IT and infrastructure resources that Verisign, OBI’s 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.
Figure 26-2: Whois IT and Infrastructure Resources. Verisign uses a common Whois resolution network architecture at each primary site provisioning the Whois service.
1.4 Description of Interconnectivity with Other Registry Systems
Figure 26-3 provides a technical overview of the registry system provided by Verisign, OBI’s selected backend registry services provider, and shows how the Whois service component fits into this larger system and interconnects with other system components.
Figure 26-3: Technical Overview. Verisign’s Whois services are co-located at DNS locations.
1.5 Frequency of Synchronization Between Servers
Synchronization between the SRS and the geographically distributed Whois resolution sites occurs approximately every three minutes. Verisign, OBI’s 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. Verisign’s 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, OBI’s 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 Verisign’s 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.
Verisign’s 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 .obi 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. Verisign’s pricing for the backend registry services it provides to OBI fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.

3.TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION
Verisign, OBI’s 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 gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to OBI fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) 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 Verisign’s 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 Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s 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 .obi gTLD as described in this application, Verisign, OBI’s 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’s 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 Internet’s 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
OBI’s selected backend registry services provider’s (Verisign’s) 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). Verisign’s 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.〈TLD〉, which in accordance with RFC 3912, provides free public query-based access to domain name, registrar, and name server lookups. Verisign’s 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 Operator’s Monthly Reports that Verisign files with ICANN. These reports provide evidence of Verisign’s 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, OBI’s 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.〈TLD〉 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. Figures 26-4 through Figure 26-6 provide the query and response format for domain name, registrar, and name server data objects.
Figure 26-4: Domain Name Data Object
Figure 26-5: Registrar Data Object
Figure 26-6: Name Server Data Object
1.1 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 Operator’s 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: 〉864 min of downtime (-98%)
* RDDS query RTT: 〉2000 ms, for at least 95% of the queries
* RDDS update time: 〈60 min, for at least 95% of the probes
6. SEARCHABLE WHOIS
Verisign, OBI’s selected backend registry services provider, provides a searchable Whois service for the .obi 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 Apache’s 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 registrant’s name, and contact and registrant’s postal address, including all the sub-fields described in EPP (e.g., street, city, state, or province)
* Ability to perform exact match, at least, on the following fields: registrar ID, name server name, and name server’s 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
Verisign’s 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, Verisign’s 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 OBI’s defined .obi 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, OBI’s 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 Verisign’s approach to mitigate the identified risk.
Figure 26-7: Potential Searchable Whois Forms of Abuse and Mitigation.

27. Registration Life Cycle

1. COMPLETE KNOWLEDGE AND UNDERSTANDING OF REGISTRATION LIFECYCLES AND STATES
Starting with domain name registration and continuing through domain name delete operations, OBI’s selected backend registry services provider’s (Verisign’s) 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.

Figure 27-1: Registration Lifecycle State Diagram

Figure 27-2: Registration States

1.1 Registration Lifecycle of Create⁄Update⁄Delete
The following section details the create⁄update⁄delete processes and the related renewal process that Verisign, OBI’s 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 .obi.
* 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).

Figure 27-3: Create Process Flow Chart

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 name’s 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 .obi.
* The registrar has available credit.
* The passed current expiration date matches the domain name’s 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.

Figure 27-4: Renewal Process Flow Chart

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.

Figure 27-5: Transfer Request Process

Figure 27-6: Transfer Cancel Process

Figure 27-7: Transfer Approve Process

Figure 27-8: Transfer Reject Process

Figure 27-9: Transfer Query Process

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 “sample.xyz” cannot be deleted if an in-zone host “ns.sample.xyz” exists and is a name server for “sample2.xyz.”
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.

Figure 27-10: Update Process Flow Chart

1.2 Pending, Locked, Expired, and Transferred
Verisign, OBI’s 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 doesn’t 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 customers’ high-profile or valuable domain names.
Verisign’s registry service supports the following client (registrar) and server (registry) status codes:
* clientHold
* clientRenewProhibited
* clientTransferProhibited
* clientUpdateProhibited
* clientDeleteProhibited
* serverHold
* serverRenewProhibited
* serverTransferProhibited
* serverUpdateProhibited
* serverDeleteProhibited
1.1 Add Grace Period, Redemption Grace Period, and Notice Periods for Renewals or Transfers
Verisign, OBI’s 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 name’s 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.
1.3 Aspects of the Registration Lifecycle Not Covered by Standard EPP RFCs
OBI’s selected backend registry services provider’s (Verisign’s) registration lifecycle processes and code implementations adhere to the standard EPP RFCs related to the registration lifecycle. By adhering to the RFCs, Verisign’s registration lifecycle is complete and addresses each registration-related task comprising the lifecycle. No aspect of Verisign’s 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 .obi gTLD as well as other TLDs managed by Verisign, OBI’s 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 .obi gTLD.
To accommodate a range of registries, Verisign’s registry implementation is capable of offering both a thin and thick Whois implementation, which is also built upon Verisign’s award-winning ATLAS infrastructure.

3. COMPLIANCE WITH RELEVANT RFCs
OBI’s selected backend registry services provider’s (Verisign’s) 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 .obi database. Two identical second-level domain names cannot simultaneously exist in .obi. 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 name’s 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, OBI’s 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 gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to OBI fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) 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 Verisign’s 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 Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s 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 .obi gTLD as described in this application, Verisign,OBI’s 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’s 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 Internet’s 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.

28. Abuse Prevention and Mitigation

1. Comprehensive abuse policies, which include clear definitions of what constitutes abuse in the TLD, and procedures that will effectively minimize potential for abuse in the TLD
OBI is deploying several measures to prevent or mitigate abuse.
The overarching principle not only to protect the OBI brand and its reputation, but also to protect users from being harmed when searching for information about OBI, its products or services is to establish and maintain control of the namespace to the best possible extent.
OBI recognizes that there are various threats for users seeking information about OBI or its products and services that might originate outside the namespace of the proposed gTLD, i.e. in other TLDs or even without involving any domain name, but only IP-addresses.
In the light of a holistic approach, OBI will
(i) educate its contractors, customers and target groups that reliable and trustworthy information is only found in the „”OBI” namespace; and
(ii) inform and educate its franchise partners that they should promote the new namespace as a source of reliable and trustworthy information and make this approach part of the marketing campaigns of the whole OBI group and its franchise partners.
There are known abuse scenarios and there will be more yet unknown tactics to deceive Internet users by means of using known brands. While there is little that OBI can do to prevent such abuse from taking place in areas that cannot be controlled by OBI, the risk of illegal activity causing harm to users can be diminished by means of user education. Each user that positively knows where to find original information will less likely be misguided by illegal offers. Additionally, OBI assumes that such educational activities will ultimately take away the commercial appeal or at least limit the attractiveness, if any, of scam abusing the OBI brand.
Since only OBI is an eligible registrant of .obi domain names, the risk of abuse is low. Nonetheless, OBI will comprehensively address this issue.

1.1 Abuse Prevention and Mitigation Implementation Plan
The following policies will be implemented upon the launch of the new .obi gTLD. All policies will also be published prominently on the Registry website alongside the abuse point of contact and with instructions on how to best report any suspected violations of the policies to the registry.
* The .obi gTLD will only be available to Obi Group Holding GmbH as registrant. This enables OBI to control the registration process and the WHOIS accuracy in a way most registries are not able to, thus providing a extra layer of security to prevent registration abuse.

The “.OBI Eligibility Policy” will state that only Obi Group Holding GmbH is eligible to register a .OBI domain name. The registrar or the registrars that OBI will be working with, will be required to ensure that only registration requests from persons duly authorized by OBI are processed.
It should be pointed out that the Registrant of all domain names within the .OBI namespace will be only OBI. This “single registrant” approach will ensure WHOIS accuracy and it will ensure that all complaints regarding specific domain names are handled promptly. While certain domain names may be used by group companies or contractors, OBI will be able to unambiguously identify the respective parties internally.

The “.OBI Eligibility Policy” will be made binding for all registrants by contractually obligating registrars through the RRA to pass on the “.OBI Eligibility Policy” as part of their registration agreements.

* By registering a specific domain name the registrant will further need to agree and comply with the “.OBI Domain Name Policy” (DNP). The DNP will be made binding for all registrants by contractually obligating registrars through the Registry-Registrar Agreement to pass on the DNP as part of their registration agreements.

The registered domain names shall only be used for bona fide business or commercial purposes in connection with all activities for which the OBI brand may be used legitimately, such as providing information on markets, contracted manufacturers, its products, services and the company itself.

The overall goal of the DNP is to limit significant harm to internet users, to enable OBI or registrars to investigate and to take action in case of malicious use of domain names and to deter registrants from engaging in illegal or fraudulent use of domain names. OBI 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 company policy.
OBI will distinguish here in the context of the “.OBI Domain Name Policy” between:
“registration abuse” and “usage abuse”.
“Registration abuse” is:
* Use of faulty⁄falsified⁄incomplete⁄stolen person-related or company-related data on registration (danger to WHOIS accuracy, see below);
* Cybersquatting⁄typosquatting;
* Registration of illegal domain names (see question 29);
“Usage abuse” is:
* Violation of applicable laws or regulation; in particular the provisions of the German Criminal Code, the German Youth Protection Act and the German Interstate Treaty on the Protection of Minors in the Media (JMStV). Only such contents are permissible which may be made available to underaged persons without any restrictions;
* Use of a domain to publish content which incites to hatred against parts of the population or against a national, racial, religious or ethnic group, content which glorifies violence, content which violates the human dignity, content which denies or plays down acts committed under the National Socialist regime;
* Distribution of child abusive material;
* Use of a domain name for the dissemination of spam, i.e. unsolicited bulk electronic communication (e-mail, instant messaging, on websites, in forums or mobile messaging) or advertising a domain name by means of spam.
* Use of a domain name for Distributed Denial-of-service attacks (“DDoS attacks”);
* Use of domain names in phishing activities, tricking Internet users into divulging personal data such as names, adresses, usernames, passwords, or financial data;
* Use of domain names in pharming , such as DNS hijacking and DNS cache poisoning;
* Use of domain names for the intentional distribution of malicious code such as spyware, botware, keylogger bots, viruses, worms or trojans;
* Use of domain names to command and control botnets , i.e. a network of compromised computers or “zombies,”
* Use of domain names in activities intended to gain illegal access to other computers or networks (“hacking”), as well as any activity to prepare for such a system penetration; or
* Use of a domain name fast flux hosting, disguising the location of internet addresses or Internet services.

OBI reserves the right to deny, cancel or transfer any registration, or place any domain name(s) on registry lock, hold or similar status, that it deems necessary, at its discretion (1) to protect the integrity and stability of the registry; (2) to comply with any applicable laws, government rules or requirements, requests by law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of OBI, as well as its affiliates, subsidiaries, officers, directors, and employees; (4) in accordance with the terms of the registration agreement or (5) to correct mistakes made by OBI or any registrar in connection with a domain name registration. 

Additionally, as detailed in the answer to Question 29 (Rights Protection Mechanisms), OBI takes extensive measures to protect third party rights with regard to .OBI domain names. This includes
* conducting a Sunrise phase to allow trademark holders to secure names related to their trademarks prior to general availability (due to the very strict and limiting nature of the “.OBI Eligibility Policy” this should not become relevant within the .OBI namespace);
* accessing the Trademark Clearinghouse to validate trademarks presented by registrants;
* offering the Trademark Claims Service;
* taking precautions against phishing and pharming and
* committing to full compliance with established Dispute Resolution and Suspension Procedures, including the Uniform Rapid Suspension (URS), the Trademark Post-Delegation Dispute Resolution Procedure (Trademark PDDRP), and the Uniform Domain Name Dispute Resolution Policy (URDP).
Please refer to the answer to question 29 for more detailed information on these measures.

1.2 Policy for Handling Complaints Regarding Abuse
OBI will provide Internet users with a prominent online point of contact to report “Registration Abuse” or “Usage Abuse” as defined above by using a standardized web form. The whole procedure will be governed by the “.obi Abuse Reporting and Takedown Policy” (ARTP).
The “ARTP” will provide users affected or believing they are affected by illegal .obi use with a transparent and structured route which the complaint procedure follows.

The key points of are:

- The complaints procedure is open to any user;
- Users must give at least one email address where they can be notified of the status of the complaint procedure;
- Depending on which abuse variant they select, users are obliged to supply certain additional information; there is also the option to upload e.g. screenshots or other files for the purposes of evidence;
- If the predefined abuse forms do not fit, users can enter their own information which must meet certain minimum standards for length (to prevent abuse of the form);
- Users must state in every case for which .obi domain names a complaint is being submitted;
- Users must finally declare in every case that all the information submitted is true; the form is secured by a CAPTCHA query.
The abuse point-of-contact will be responsive and effective, tasked with answering email quickly, empowered to take effective action, and guided by well-defined written criteria.
This role-based function will be performed by the legal department of the OBI group.
After sending the web form the user will be provided in all cases with an automatically generated email containing an tracking or case number.
Each report will be carefully reviewed and evaluated regarding its credibility, to determine whether the reported issue is an abuse concern, and to assess the required action(s) – if any. OBI’s abuse team will closely work together with the registrar(s) as well as the Registry Service Provider – VeriSign - to rapidly address potential threats or abuse complaints, investigate all reasonable complaints, and take any appropriate action(s),
As standard practice, OBI’s abuse team will forward all credible and actionable reports including the accompanying evidence with a recommendation what action should be taken to OBI’s legal department, which is responsible for compliance. The recommendation also states the type of infringement and the legal basis of the sanction, such as the applicable terms of use, ICANN policies, applicable laws or the DNP.
The standard procedure will be:
* OBI will identify the business unit or party that has been granted a right to use the domain name or which is responsible for the server (Respondent) for which a complaint has been received and notify its abuse team;
* The Respondent will receive the complaint by email and is obliged to process and reply to all correspondence forwarded by OBI’s abuse team without delay, and at least within 48 hours, unless a third party has set a shorter period or there is other specific need for speed;
* with the response, the Respondent must state whether he wishes cure the alleged breach or to defend against the third party allegation;
* a matter is settled when the Respondent evidences to have cured the breach within the deadline given;
* should a Respondent fail to respond to the request of OBI’s abuse team in time, OBI is entitled to delete or suspend the respective domain name or make certain content or services offered thereunder unavailable.
Reports and requests from competent authorities, law enforcement and⁄or courts receive top priority. These parties will receive priority contact options to ensure quick and proper reactions. Such requests will be handled and resolved by OBI’s abuse team without delay, the latest within 24 hrs.
In all cases OBI reserves the right to act directly and immediately in cases of obvious and significant malicious conduct. Should OBI (or the registrar) decide to suspend a specific domain name the suspension request will be fulfilled as described below.

1.3 Suspension Process for abusive domain names
In the case of domain name abuse, OBI will determine whether to take down the subject domain name. Verisign, OBI’s selected backend registry services provider, will follow the following auditable processes to comply with the suspension request.

Figure 28-2: Suspension processes conducted by backend registry services provider

OBI 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 statuses that are relevant to the suspension)
* Incident response, including surge capacity

When Verisign receives a suspension request from OBI, 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.

If required data is missing from the suspension request, or the domain name is not registered, the request will be rejected and returned to OBI with the following information:
* Threat domain name
* Registry incident number
* Verisign case number
* Error

1.4 Domain Name Abuse Prevention Measurements
Verisign, OBI’s selected backend registry services provider, provides the following domain name abuse prevention services, which OBI incorporates into its full-service registry operations. These services are available at the time of domain name registration.
1.4.1 Registry Lock.
The Registry Lock Service allows registrars to offer server-level protection for their registrants’ domain names. A registry lock can be applied during the initial standup of the domain name or at any time that the registry is operational.
Specific Extensible Provisioning Protocol (EPP) status codes are set on the domain name to prevent malicious or inadvertent modifications, deletions, and transfers. Typically, these ‘server’ level status codes can only be updated by the registry. The Registrar only has ‘client’ level codes and cannot alter ‘server’ level status codes. The registrant must provide a pass phrase to the registry before any updates are made to the domain name. However, with Registry Lock, provided via Verisign, OBI’s subcontractor, registrars can also take advantage of server status codes.
The following EPP server status codes are applicable for domain names:
(i) serverUpdateProhibited,
(ii) serverDeleteProhibited, and
(iii) serverTransferProhibited. These statuses may be applied individually or in combination.
The EPP also enables setting host (i.e. name server) status codes to prevent deleting or renaming a host or modifying its IP addresses. Setting host status codes at the registry reduces the risk of inadvertent disruption of DNS resolution for domain names.
The Registry Lock Service is used in conjunction with a registrar’s proprietary security measures to bring a greater level of security to registrants’ domain names and help mitigate potential for unintended deletions, transfers, and⁄or updates.
Two components comprise the Registry Lock Service:
OBI and⁄or its registrars provides Verisign, OBI’s selected provider of backend registry services, with a list of the domain names to be placed on the server status codes. During the term of the service agreement, the registrar can add domain names to be placed on the server status codes and⁄or remove domain names currently placed on the server status codes. Verisign then manually authenticates that the registrar submitting the list of domain names is the registrar-of-record for such domain names.
If OBI and⁄or its registrars requires changes (including updates, deletes, and transfers) to a domain name placed on a server status code, Verisign follows a secure, authenticated process to perform the change. This process includes a request from an OBI -authorized representative for Verisign to remove the specific registry status code, validation of the authorized individual by Verisign, removal of the specified server status code, registrar completion of the desired change, and a request from an OBI -authorized individual to reinstate the server status code on the domain name. This process is designed to complement automated transaction processing through the Shared Registration System (SRS) by using independent authentication by trusted registry experts.
1.4.2 Malware scanning service
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.
Verisign’s malware scanning service helps prevent websites from infecting other websites by scanning web pages for embedded malicious content that will infect visitors’ websites. Verisign’s 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 registrant’s website.

1.5 Proposed Measures for Removal of Orphan Glue Records
Although orphan glue records often support correct and ordinary operation of the Domain Name System (DNS), registry operators will be required to remove orphan glue records (as defined at http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf) when provided with evidence in written form that such records are present in connection with malicious conduct. OBI’s selected backend registry services provider’s (Verisign’s) 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 serverHold 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.

2. WHOIS Accuracy
The accuracy and access of WHOIS information is a topic of global discussion and importance. It is without question that the accuracy of data associated with any domain names registered in the .OBI space is of paramount concern. As mentioned before OBI will be following a single registrant approach to ensure WHOIS accuracy. All domain names registered within the .OBI namespace will be using identical registrant data. The .OBI Eligibility Policy will clearly state that only Obi Group Holding GmbH will be an eligible registrant. This policy will be made part of the Registry Registrar Agreement and thus be binding for registrars. Thus, WHOIS will always be 100% accurate.

3. Ensuring Proper Access to Domain Functions
OBI is aware of the risks resulting from all communication regarding the different domain functions on the registry-registrar-level. To ensure proper access to domain functions, OBI incorporates Verisign’s Registry-Registrar Two-Factor Authentication Service into its full-service registry operations. The service is designed to improve domain name security and assist registrars in protecting the accounts they manage by providing another level of assurance that only authorized personnel can communicate with the registry. As part of the service, dynamic one-time passwords (OTPs) supplement 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 “what users know” (i.e., their user name and password) and “what users have” (i.e., a two-factor authentication credential with a one-time-password).
Registrars can use the one-time-password when communicating directly with Verisign’s 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. As shown in Figure 28-1, the registrars’ authorized contacts use the OTP to enable strong authentication when they contact the registry. 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.

Figure 28-1: Verisign Registry-Registrar Two-Factor Authentication Service

4. Technical plan scope⁄scale that is consistent with the overall business approach and planned size of the registry

Scope⁄Scale Consistency
OBI has a legal department which is responsible for compliance of the OBI group. The team consists of nine fully trained lawyers, of which 5 specialize in trademark law, competition law and cyber law. They are familiar with the legal implications of online services and abuse scenarios on the Internet since they legally advise the IT departement on how to deal with abuse cases already. Since the .obi gTLD will only have one registrant, which is the registry operator itself, chances of registration abuse to occur are slim. When it comes to usage abuse, there are no new challenges since OBI is operating websites and online services for many years and is familiar with the parameters to do so in a compliant manner. Also, in the unlikely case of infringements of applicable laws by group companies or fanchisees, there is no indication that a substantial increase of cases, if any, will take place with the introduction of the new gTLD since OBI markets that would be eligible to present themselves in the new gTLD namespace already have websites. Nonetheless, the compiance ⁄ abuse department is ready to respond to challenges and workload there might be. The number of staff that can handle complaints is already much higher than necessary, but in case there should be numerous reports, OBI also has specialized law firms to which such work could be outsourced.
Scope⁄Scale Consistency Specific to Backend Registry Activities
Verisign, OBI’s 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 Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned with projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies.
Verisign’s 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 〈new string〉 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. Verisign’s pricing for the backend registry services it provides to OBI fully accounts for cost related to this infrastructure, which is provided as “Other Operating Cost” (Template 1, Line I.L) within the Question 46 financial projections response.

5. Technical plan that is adequately resourced in the planned costs detailed in the financial section

5.1 Resource Planning
Since a low volume of abuse resports that need to be managed is expected, 0.5 FTE has been allocated to this task, amongst others, in the financial plan, although the workforce of a team of nine fully trained lawyers can be used, if need be. In addition to that, resources of Obi Smart Technologies GmbH can be used when it comes to technical questions in the course of abuse management. There is an outsourcing agreement with this company, which is an OBI group company, which is included in the financial planning.

5.2 Resource Planning Specific to Backend Registry Activities
Verisign, OBI’s 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 gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to OBI fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) 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 Verisign’s 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 Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s 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 .OBI gTLD as described in this application, Verisign, OBI’s 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’s 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 Internet’s 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.

29. Rights Protection Mechanisms

1. Mechanisms Designed to Prevent abusive registrations
Rights protection is a core objective of OBI. OBI will implement and adhere to any rights protection mechanisms (RPMs) that may be mandated from time to time by ICANN, including each mandatory RPM set forth in the Trademark Clearinghouse model contained in the Registry Agreement, specifically Specification 7. OBI acknowledges that, at a minimum, ICANN requires a Sunrise period, a Trademark Claims period, and interaction with the Trademark Clearinghouse with respect to the registration of domain names for the .obi gTLD. 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, OBI cannot fully detail the specific implementation of the Trademark Clearinghouse within this application. OBI will adhere to all processes and procedures to comply with ICANN guidance once this guidance is finalized. Also, OBI is committed to implementing all potential future consensus policies. Any such requirements will be included in the Registry Registrar Agreement to ensure that registrars will be in compliance with the OBI’s policies and that such policies are incorporated in the contract language with registrants. OBI will not require any additional or alternative services than the ICANN-designed Trademark Clearing House for purposes of trademark information aggregation, notification or validation.
As described in this response, OBI will implement a Sunrise period and Trademark Claims service with respect to the registration of domain names within the .obi gTLD. Certain aspects of the Sunrise period and⁄or Trademark Claims service may be administered on behalf of OBI by OBI-approved registrars or by subcontractors of OBI, such as its selected backend registry services provider, Verisign.

Sunrise Period
As provided by the Trademark Clearinghouse model set forth in the ICANN Applicant Guidebook, the Sunrise service pre-registration procedure for domain names continues for at least 30 days prior to the general availability of domain names in the .obi gTLD.
As detailed in Question 28, the “.OBI Eligibility Policy“ will only allow Obi Group Holding GmbH as an registrant of .obi domain names. These eligibility restrictions shall apply during the Sunrise Period.
As a result of this, it is questionable whether any third parties will apply for .obi domain names during the Sunrise Period. Nonetheless, OBI will carry out the Sunrise Period in accordance with all known requirements and features which are yet to be published by ICANN. ICANN will work with expert partners during the preparation and implementation of the Sunrise Period. Policies and contracts will be drafted by legal experts in the field. The Trademark Clearinghouse will be contracted as well as an experienced Validation Agent and a reputable Dispute Resolution Provider. In addition, services rendered by Verisign and ICANN-accredited registrars will be used during the Sunrise Period.

During the Sunrise period, holders of marks that have been previously validated by the Trademark Clearinghouse receive notice of domain names that are an identical match (as defined in the ICANN Applicant Guidebook) to their mark(s). Such notice is in accordance with ICANN’s requirements and is provided by OBI either directly or through OBI-approved registrars.
OBI requires all registrants, either directly or through OBI-approved registrars, to i) affirm that said registrants meet the Sunrise Eligibility Requirements (SER) and ii) submit to the Sunrise Dispute Resolution Policy (SDRP) consistent with Section 6 of the Trademark Clearinghouse model.
During the Sunrise period, OBI and⁄or OBI-approved registrars, as applicable, are responsible for determining whether each domain name is eligible to be registered (including in accordance with the SERs).
The SER will include the following:
A. The registrant meets the requirements of the .OBI Eligibility Policy;
B1. The registrant is the owner of a word mark: (i) that is nationally or regionally registered for which proof of use – which can be a declaration and a single specimen of current use – was submitted to, and validated by, the Trademark Clearinghouse; or (ii) that has been court-validated; or (iii) that is specifically protected by a statute or treaty currently in effect and that was in effect on or before 26 June 2008; or
B2. The registrant is the owner, licensee or legal successor of a registered and existing trademark right (word mark and⁄or figurative mark), for which the claimed legal position on which the registration of the domain name is based was in effect on or before 26 June 2008 and the domain name is identical to the textual element of the mark (for which the parameters will be further defined);
C. The requirement of a representation that all provided information is true and correct;
D. The requirement that the provision of data sufficient to document rights in the trademark; and
E. The requirement that the application has been successfully validated by OBI’s Validation Agent.

Applications submitted to OBI or through an ICANN accredited registrar during the Sunrise Period are validated for completeness and accuracy in accordance with the Sunrise policy on behalf of OBI by a specialized Validation Agent, who will be tasked to
- validate trademarks against the Trademark Clearinghouse or against the respective database of the competent trademark office; and
- determine whether the trademark matches the string applied for according to the SER.
The Validation Agent can request supplementary records from the registrant at any time in the course of the validation process. Registrants are obliged to pay a fee for the application and for the respective validation. Rejected and⁄or unsuccessful applications will not be refunded.
Applications shall be rejected if,
- the application does not contain complete and accurate information as described in the Sunrise Policy, or is not in compliance with other provisions of the Sunrise Policy and⁄or other applicable .OBI policies;
- the domain name applied for obviously violates existing law, court or official orders, and is accordingly likely to endanger the operations of .OBI; or
- the Registrant fails to pay the validation fee and⁄or fails to deliver supplementary records as requested by the Validation Agent.

Domain names applied for shall be registered after the end of the Sunrise Period if,

* OBI has received only one application for a given domain name which was successfully validated, this domain name will be registered to the Applicant, if it meets the other requirements of the Sunrise policy and the other applicable .OBI policies; or
* an Applicant whose application has been validated was the highest bidder in an auction.


Should OBI receive two or more valid applications for the same domain name, it will be offered to the applicants at auction. The highest bidder will be awarded the domain.
OBI will not conduct a ʺLandrushʺ phase after Sunrise is completed. Due to the strict “.OBI Eligibility Policy” there is no need for OBI to limit the load on the shared registration system (SRS) that usually occurs during the initial run on popular, generic domain names, as .obi domain names won’t be available to the general public.
Sunrise Dispute Resolution Policy (SDRP)
After any Sunrise name is awarded to an applicant, it will remain under a “Sunrise Lock” status for at least 60 days so that parties will have an opportunity to file Sunrise Challenges. During this Sunrise Lock period the domain name will not resolve and cannot be modified, transferred, or deleted by the registrar. The domain name will be unlocked at the end of that lock period only if it is not the subject of a Sunrise Challenge. Challenged domains will remain locked until the dispute resolution provider has issued a decision, which Verisign will promptly execute.
The Sunrise Dispute Resolution Policy (SDRP) will allow Sunrise challenges based on the following four grounds:
(i) at time the challenged domain name was registered, the registrant did not hold a trademark registration of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty;
(ii) the domain name is not identical to the mark on which the registrant based its Sunrise registration;
(iii) the trademark registration on which the registrant based its Sunrise registration is not of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; or
(iv) the trademark registration on which the domain name registrant based its Sunrise registration did not issue on or before the effective date of the Registry Agreement and was not applied for on or before ICANN announced the applications received.

Trademark Claims Service
As provided by the Trademark Clearinghouse model (ICANN’s work towards the establishment of such a Trademark Clearinghouse is still in progress. Therefore, it is not yet possible to describe the actual process and technical interfaces by which Verisign will support the Trademark Clearinghouse requirements.) set forth in the ICANN Applicant Guidebook, all new gTLDs will have to provide a Trademark Claims service for a minimum of 60 days after the launch of the general registration of domain names in the gTLD (Trademark Claims period).

During the Trademark Claims period, in accordance with ICANN’s requirements, OBI or the OBI-approved registrar will send a Trademark Claims Notice to any prospective registrant of a domain name that is an identical match (as defined in the ICANN Applicant Guidebook) to any mark that is validated in the Trademark Clearinghouse. The Trademark Claims Notice will include links to the Trademark Claims as listed in the Trademark Clearinghouse and will be provided at no cost.
Prior to registration of said domain name, OBI or the OBI-approved registrar will require each prospective registrant to provide the warranties dictated in the Trademark Clearinghouse model set forth in the ICANN Applicant Guidebook. 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, OBI or the OBI-approved registrar will not process the domain name registration.
Following the registration of a domain name, the OBI-approved registrar will provide a notice of domain name registration to the holders of marks that have been previously validated by the Trademark Clearinghouse and are an identical match. This notice will be as dictated by ICANN. At a minimum OBI will recognize and honor all word marks validated by the Trademark Clearinghouse.

2. MECHANISMS DESIGNED TO IDENTIFY AND ADDRESS THE ABUSIVE USE OF REGISTERED NAMES ON AN ONGOING BASIS
In addition to the Sunrise and Trademark Claims services described in Section 1 of this response, OBI implements and adheres to RPMs post-launch as mandated by ICANN, and confirms that registrars accredited for the .OBI gTLD are in compliance with these mechanisms. Certain aspects of these post-launch RPMs may be administered on behalf of OBI by OBI-approved registrars or by subcontractors of OBI, such as its selected backend registry services provider, Verisign.
These post-launch RPMs include the established Uniform Domain-Name Dispute-Resolution Policy (UDRP), as well as the newer Uniform Rapid Suspension System (URS) and Trademark Post-Delegation Dispute Resolution Procedure (PDDRP). Where applicable, OBI will implement all determinations and decisions issued under the corresponding RPM.

After a domain name is registered, trademark holders can object to the registration through the UDRP or URS. Objections to the operation of the gTLD can be made through the PDDRP.

The following descriptions provide implementation details of each post-launch RPM for the .OBI gTLD:

UDRP: The UDRP provides a mechanism for complainants to object to domain name registrations. The complainant files its objection with a UDRP provider and the domain name registrant has an opportunity to respond. The UDRP provider makes a decision based on the papers filed. If the complainant is successful, ownership of the domain name registration is transferred to the complainant. If the complainant is not successful, ownership of the domain name remains with the domain name registrant. OBI and entities operating on its behalf adhere to all decisions rendered by UDRP providers.

URS: As provided in the Applicant Guidebook, all registries are required to implement the URS. Similar to the UDRP, a complainant files its objection with a URS provider. The URS provider conducts an administrative review for compliance with filing requirements. If the complaint passes review, the URS provider notifies the registry operator and locks the domain within 24 hours. A lock means that the registry restricts all changes to the registration data, but the name will continue to resolve. After the domain is locked, the complaint is served to the domain name registrant, who has an opportunity to respond. If the complainant is successful, the registry operator is informed and the domain name is suspended for the balance of the registration period; the domain name will not resolve to the original website, but to an informational web page provided by the URS provider. If the complainant is not successful, the URS is terminated and full control of the domain name registration is returned to the domain name registrant. Similar to the existing UDRP, OBI and entities operating on its behalf adhere to decisions rendered by the URS providers.

PDDRP: As provided in the Applicant Guidebook, all registries are required to implement the PDDRP. The PDDRP provides a mechanism for a complainant to object to the registry operator’s manner of operation or use of the gTLD. The complainant files its objection with a PDDRP provider, who performs a threshold review. The registry operator has the opportunity to respond and the provider issues its determination based on the papers filed, although there may be opportunity for further discovery and a hearing. OBI participates in the PDDRP process as specified in the Applicant Guidebook.

Contractual measurements: The answer to Question 28 (“Abuse Prevention and Mitigation”) above described OBI’s different contractual approaches to identify and address abusive usage of the .obi name space. OBI will establish upon the launch of the new .obi gTLD the “.OBI Eligibility Policy”, the “OBI Domain Name Policy” and the “.OBI Abuse Reporting Policy”.

These policies will all be part of the Registry-Registrar Agreement (RRA), which needs to be signed by all registrars interested in offering registrations under the .OBI gTLD giving OBI the possibility to impose certain sanctions against Registrants directly should this be necessary. Those contractual rights, procedures and measurements are designed as following:

By applying for and registering .OBI Domain Name(s) the Registrant enters into a direct agreement with OBI;
Furthermore OBI shall be entitled (but not obliged) to reject an application or to delete, revoke, cancel or transfer a Domain Name Registration:

- if the application or registration is not in compliance with the applicable OBI policies; or
- to protect the integrity and stability of the Shared Registry System, and⁄or the operation and⁄or management of the .obi gTLD; or
- in order to comply with applicable laws, regulations, any decision by a competent court or administrative authority; or
- to avoid any liability on behalf of OBI, its affiliates, directors, officers, employees, subcontractors and⁄or agents.

If OBI or any other party involved in the registration of the .obi domain name is directly contacted by a third party because of alleged violations of law, OBI will notify the Registrant by e-mail, either directly or through the respective registrar. The Registrant will process and reply to all correspondence forwarded by OBI without delay, and at least within 48 hours, unless a third party has set a shorter period or there is other specific need for speed.
Should the Registrant fail to reply within this time limit, OBI is entitled to stop the Domain Name from resolving via the DNS, have it deleted and⁄or to terminate the respective agreement.

In urgent cases, OBI is entitled to stop the Domain Name from resolving via the DNS, have it deleted and⁄or to terminate the respective agreement without prior notification or warning. This applies specifically to violations of criminal law and⁄or violations of youth protection law.

The Registry Restrictions Dispute Resolution Procedure (RRDRP) is not relevant since .OBI is not a community-based gTLD.

Additional Measures Specific to Rights Protection:

OBI provides additional measures against potentially abusive registrations. These measures help mitigate phishing, pharming, and other Internet security threats. The measures exceed the minimum requirements for RPMs defined by Specification 7 of the Registry Agreement and are available at the time of registration. These measures include:

- Rapid Takedown or Suspension Based on Court Orders:
OBI 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 TLD 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:
OBI 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, OBI’s selected backend registry services provider, uses two-factor authentication to augment security protocols for telephone, email, and chat communications.
- Registry Lock:
This Verisign service allows registrants to lock a domain name at the registry level to protect against both unintended and malicious changes, deletions, and transfers. Only Verisign, as OBI’s backend registry services provider, can release the lock; thus all other entities that normally are permitted to update Shared Registration System (SRS) records are prevented from doing so. This lock is released only after the registrar makes the request to unlock.
- 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 OBI’s 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 their domain names. Additionally, OBI will review information that is published on sources of Malware and Phishing, such as the findings published by the Anti-Phishing Working Group (APWG) in its Global Phishing Survey.
- 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 .OBI gTLD is DNSSEC-enabled as part of Verisign’s core backend registry services.

3. RESOURCING PLANS
3.1 Resource Planning
This task shall be primarily supported by OBI staff as already included in the financial plan. Further, the workforce of a team of nine fully trained lawyers can be used, if need be. In addition to that, resources of Obi Smart Technologies GmbH can be used when it comes to technical questions in the course of abuse management. There is an outsourcing agreement with this company, which is an OBI group company, which is included in the financial plan. As costs for the Trademark Clearinghouse are yet to be determined, a placeholder for this is included in the financial plan.
3.2 Resource Planning Specific to Backend Registry Activities
Verisign, OBI’s 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 gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to OBI fully accounts for cost related to this infrastructure, which is provided as Line IIb.G, Total Critical Registry Function Cash Outflows, 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 Verisign’s 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 Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s 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 .OBI gTLD as described in this application, Verisign,OBI’s 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’s 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 Internet’s 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.

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


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
OBI’s selected backend registry services provider’s (Verisign’s) comprehensive security policy has evolved over the years as part of managing some of the world’s most critical TLDs. Verisign’s 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.
Verisign’s 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 “strong” 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 .obi TLD are based on the standards defined above, each of which is derived from Verisign’s experience and industry best practice. These standards comprise the framework for the overall security solution and applicable processes implemented across all products under Verisign’s 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, OBI, 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 Verisign’s 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 Verisign’s 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 30 A-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 Verisign’s 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.

Figure 30 A-1: Verisign Independent Assessment Activities

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 MEASURES AT OBI
OBI’s business is governed by German law. The German Federal Data Protection Act provides for a high level of both data protection as well as data security. These requirements are particularly enshrined in Art. 9 of the Federal Data Protection Act and its appendix:

Section 9 Technical and organizational measures
Public and private bodies which collect, process or use personal data on their own behalf or on behalf of others shall take the necessary technical and organizational measures to ensure the implementation of the provisions of this Act, especially the requirements listed in the Annex to this Act. Measures shall be necessary only if the effort required is in reasonable proportion to the desired purpose of protection. 

Annex (to Section 9, first sentence)
Where personal data are processed or used in automated form, the internal organization of authorities or enterprises is to be such that it meets the specific requirements of data protection. In particular, measures suited to the type of personal data or categories of data to be protected shall be taken
1. to prevent unauthorized persons from gaining access to data processing systems for processing or using personal data (access control),
2. to prevent data processing systems from being used without authorization (access control),
3. to ensure that persons authorized to use a data processing system have access only to those data they are authorized to access, and that personal data cannot be read, copied, altered or removed without authorization during processing, use and after recording (access control),
4. to ensure that personal data cannot be read, copied, altered or removed without authorization during electronic transfer or transport or while being recorded onto data storage media, and that it is possible to ascertain and check which bodies are to be transferred personal data using data transmission facilities (disclosure control),
5. to ensure that it is possible after the fact to check and ascertain whether personal data have been entered into, altered or removed from data processing systems and if so, by whom (input control),
6. to ensure that personal data processed on behalf of others are processed strictly in compliance with the controller’s instructions (job control),
7. to ensure that personal data are protected against accidental destruction or loss (availability control),
8. to ensure that data collected for different purposes can be processed separately.
One measure in accordance with the second sentence Nos. 2 to 4 is in particular the use of the latest encryption procedures. 

As required by the Federal Data Protection Act, OBI has appointed a data protection official, who is tasked to ensure compliance with the Act and other data protection provisions.

3. CONSISTENCY OF BACKEND REGISTRY SERVICES WITH BUSINESS APPROACH AND PLANNED SIZE OF REGISTRY
Verisign, OBI’s 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 Verisign’s 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.
Verisign’s 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 .obi 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. Verisign’s pricing for the backend registry services it provides to OBI fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.

4. TECHNICAL PLAN ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION
Resource Planning
OBI Smart Technologies GmbH, an OBI group company with more than 250 employees, serves all companies in the OBI group with IT and development services. As such, it is tasked with ensuring IT security. The associated workload can be scaled according to the specific needs with the human resources available to meet the requirements. Such services would not be invoiced to OBI, which is why the associated costs are not reflected in the planned costs detailed in the financial section. OBI Smart Technologies GmbH is also working with experienced subcontractors to perform its duties. Additionally, the areas of data protection and data security are overseen by OBI’s data protection official, a position which exists regardless of OBI’s role as a registry. As such, no additional costs are associated with this.
Resource Planning Specific to Backend Registry Activities
Verisign, OBI’s 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 gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to OBI fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) 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 Verisign’s 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 Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s 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 .obi gTLD as described in this application, Verisign,OBI’s 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’s 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 Internet’s 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. SECURITY MEASURES ARE CONSISTENT WITH ANY COMMITMENTS MADE TO REGISTRANTS REGARDING SECURITY LEVELS
Verisign is OBI’s selected backend registry services provider. For the .obi gTLD, no unique security measures or commitments must be made by Verisign or OBI to any registrant.

6. 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 .obi gTLD. As defined in Section 1 of this response, Verisign, OBI’s 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)



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