ICANN New gTLD Application

New gTLD Application Submitted to ICANN by: FRLregistry B.V.

String: FRL

Originally Posted: 13 June 2012

Application ID: 1-1312-75662


Applicant Information


1. Full legal name

FRLregistry B.V.

2. Address of the principal place of business

Beurtschip 35
Heerenveen 8447 CL
NL

3. Phone number

+31 182 477 000

4. Fax number

+31 877 867 300

5. If applicable, website or URL

www.frlregistry.com

Primary Contact


6(a). Name

Mr. Evert Wouter de Graaf

6(b). Title

Business Unit Manager

6(c). Address


6(d). Phone Number

+31 628 901 768

6(e). Fax Number


6(f). Email Address

info@frlregistry.com

Secondary Contact


7(a). Name

Mr. Jan Hendrik de Jong

7(b). Title

Owner

7(c). Address


7(d). Phone Number

+31 6 5122 9332

7(e). Fax Number


7(f). Email Address

henri@mijndomein.nl

Proof of Legal Establishment


8(a). Legal form of the Applicant

Private Company (Besloten Vennootschap)

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

Dutch Law

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.

H2 Beheer B.V.

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

Henkjan de KrijgerDirector
Jan Hendrik de JongDirector

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


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

H2 Beheer B.V.Not Applicable

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

J.H. de Jong Beheer B.V.Not Applicable
J.H. de Krijger Beheer B.V.Not Applicable

Applied-for gTLD string


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

FRL

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.

The requested string is very simple and straightforward, not unlike any country- or geographic top-level domain. No specific rendering problems are to be expected with this string.

The string is not an IDN string and the character set is Latin left-to-right, so there will be no Bi-Directional issues.

To address potential operational problems, we have conferred with Matthieu Weill of the .FR registry to ask if he sees any problems with a new string that resembles the existing .FR string.

We have agreed that both strings have a very different public. There have been earlier attempts to warm the Frisian public to the FR string, but these attempts have gone without response. The Frisians recognize FRL als a common representative string of their own province, language and culture.

To further mitigate problemens that might arise between the FR and FRL registries, we have agreed with Mr Weill that a number of important .FR second-level domain names will be reserved in the FRL registry.

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.

Friesland (http:⁄⁄en.wikipedia.org⁄wiki⁄Friesland) is one of the most northern provinces of The Netherlands. The people of Friesland refer to themselves as Frisians (http:⁄⁄en.wikipedia.org⁄wiki⁄Frisians), and are a very independent and close-knit community. The Frisians have their own (internationally recognized) language, which is recognized as an official language both in The Netherlands and in Germany. All towns, villages and communities have a Dutch name and a separate Frisian name that is shown on road signs and official maps.

Friesland is governed by the Provincie Fryslân, which is the official governing body of this province. The Provincie Fryslân first started plans for its own TLD as early as 2006, but due to political issues and changing political landscape this TLD still has not been realized. Together with SIDN, the Provincie Fryslân has conducted an extensive study of the potential for a Top-Level-Domain name in Friesland. The study focussed mainly on governments and businesses in Friesland, and concluded that there is a market for at least 40.000 domain names there. If we add to this the potential consumer market, we see a business case for 37.000 domain names in Friesland.

In december 2011 the Provincie Fryslân started a public tender for the .FRL gTLD, and Metaregistrar, (former name of FRL registry BV, please review attachment 50 – Statutenwijziging.pdf for the statutory change) entered this tender. From all the parties, Metaregistrar was willing to take full responsibility for both the application and the funding, and was selected as preferred partner by the Provincie Fryslân.

During the years that an own TLD for Friesland was in the making, several alternatives were considered: .FRIESLAND (but that is Dutch language, not Frisian), .FRYSLAN (but that would need an accent on the A) or .FRYSLÂN (that would be an IDN application, which would make e-mailing difficult for many people in The Netherlands). From the alternatives, FRL was selected, because many Frisians already identify themselves with an FRL sticker on the backs of their cars, and within The Netherlands, FRL is widely recognized as short for Friesland.

According to ISO3166-2, the official code for Friesland would be NL-FR. However, both NL and FR are already taken as 3166-1 country codes, and NLFR would not be a tld that speaks to the heart of the Frisians because it still starts with NL.

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

The .FRL domain extension is targeted at Frisian people living in Friesland, Frisians living in other part of the Netherlands, and Frisians living abroad and wanting to identify themselves with the Frisian culture and heritage.

This means that the FRL top-level domain will serve the Frisians not only in the province (between 600.000 and 700.000 people), but also the Frisians that have moved into the rest of The Netherlands or abroad. Also, the northerns parts of Germany have a Frisian community that strongly identifies with the Frisians in The Netherlands. The general feeling is that people from Friesland will stay Frisian for their whole lives, and are very willing to identify themselves with anything coming from Friesland.

The Netherlands are populated with about 17.000.000 people, and the .NL registry holds almost 5.000.000 second-level domain names. If we extrapolate these numbers to the Frisian population, we can expect conservatively 37.000 second-level registrations, but 50.000 registrations would be very possible from the inhabitants of Friesland alone. And that is not counting the Frisians living in other parts of the Netherlands or Frisians living abroad. Add this to the fact that most Frisian names have 3 means of spelling: Dutch spelling, Frisian spelling without accents and Frisian spelling with accents, this all adds up to a very valid business case for a gTLD.

When enough Frisians adopt a .FRL domain name, this TLD will serve as glue between the Frisians living in Friesland and the Frisians living elsewhere, giving the people living abroad a means to visually identify themselves with the Frisian community in Friesland.

An additional benefit to using a .FRL tld is the use of Internationalized Domain Names (IDNs). The Frisian language contains many words that require special characters to be spelled correctly. For example, the government of Friesland is reachable under www.fryslan.nl, however the correct spelling would be fryslân.nl. Since SIDN has not rolled out IDN support yet, this domain name is not possible. With the use of new gTLDs, the province will be able to register the domain name fryslân.frl. We expect a boost in websites that feature the Frisian language, and many website owners wanting to register not only the IDN variant but also the variant without special characters, if only to be able to send and receive e-mail correctly.

The whois services of the FRL registry will adhere to the Dutch privacy laws. This means that for the public whois services only a limited amount of data will be shown. Any party having a legitimate right to all the whois information will be able to contact the registry and gain access to the private whois service. Connected registrars will also have access to the private whois service to enable them to execute the domain transfer policies correctly.

The web-based whois service will show more information than the publicly available port 43 whois, but will be protected with a captcha to prevent harvesting of data.

Registration of .FRL domain names will be open and unrestricted to any ICANN-accredited registrar. There are no intentions to restrict registration to people originating from Friesland only, because many Frisian people live in other parts of The Netherlands or Germany or have moved abroad. It is these people we want to give the chance of identifying with the Frisian community by registering a .FRL domain name.

As stated in the ICANN policies, all names like example.frl, www.frl, iris.frl, nic.frl and whois.frl will be reserved in the domain name system, as all the names of countries and territories that are specified in the ICANN newGtld documentation. Domain names with hyphens are allowed, but no two hyphens may be next to each other in a domain name. This way, domain names starting with xn—will not be accepted by the registry.

Numbers in domain names are allowed. Domain names can start or end with any number.
All 1 character and 2-character domain names are reserved, and can only be released after ICANN approval.

Internationalized Domain Names (IDNs) will be allowed, but only the characters that relate to the Frisian and Dutch languages. Since no character table exists in the IANA tables with that specification, a new table will be added.

In addition to this, all names of Frisian villages and cities will be reserved, where necessary in three variants: Dutch language, Frisian language and Frisian language with special characters. We are working together with the Frisian Academy for a exhaustive list of names. Together with the Province Fryslân we will encourage all local governments to claim their domain name(s), we will use an external party to verify those claims.

Every domain name can be registered for a period of 1 to 10 years. At this time, no discount pricing has been established for registrations longer than 1 year.

The sunrise and landrush stages will be performed as follows:
1. Sunrise for trademark holders and companies
Any party holding a trademark or registered name will be able to apply for domain names in the .FRL gTLD. Each claim will be checked and verified by an external party, capable of verifying these claims. Whenever a claim is approved, the trademark holder will receive an authcode for that specific domain name.
We do not expect many trademark holders wanting to claim a domain name in this period of time, so multiple applications for the same domain name will be handled on a first-come first-serve basis. That is, after the documentation supporting the claims have been verified.
At the same time, all companies and institutions will receive a letter with their company domain name that can be claimed. This will raise awareness with the new TLD. The companies and institutions can use the authcode in that letter to register their domain name. If they want to register more domain names, they will have to use the next sunrise (for the Frisian community) or the open registration (landrush) period.


2. Sunrise for the Frisian community
Worldwide acceptance of the .FRL tld will stand or fall with acceptance by the Frisian community itself. We have agreed with the Provincie Fryslân that the FRL registry will supply all addresses in Friesland with discount codes to pre-register a domain name. Each physical address will receive 2 discount codes: one for themselves and one to use for a relative or friend abroad. This way we will raise the awareness of .FRL existence, and let all people in Friesland (and Frisians abroad) know that this extension is available for registration. The discount code will give a discount of at least 50% on the regular domain name price.

The discount codes will be accepted by the EPP server of the registry, and can be used by any ICANN accredited registrar approved and connected to the .FRL registry. We will encourage people asking for the .FRL extension with their local domain name provider, because every extra selling point of domain names will benefit the whole .FRL registry.

Multiple registrations for the same domain name will be handled on a first-come first-served basis.

3. General availability
After the Frisian pre-registration, registration will open up without use of coupon codes. No restrictions are imposed on the registrants; anyone will be able to register a .FRL domain name.

Multiple registrations for the same domain name will be handled on a first-come first-served basis.

Since the Frisian community and the Provincie Fryslân are strong supporters of the independent Frisian language, our sister company Mijndomein.nl has plans to open a domain name registration page in the Frisian language.

The Provincie Fryslân has already opened a page on their website to ask the Frisian people if they are willing to register a FRL domain name, and the name of their registrar. This information will be used by the registry to actively contact the Frisian domain name registration and hosting companies and get them connected with the Frisian Top-Level domain either with their own ICANN accreditation or via a reseller agreement with one of the connected registrars.

The registry is already in contact with the (currently 11) ICANN accredited registrars in The Netherlands, and has received several intentions to connect with the registry and sell FRL domain names.

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

Multiple requests for the same domain name will be handled on a first-come, first-served basis. Since the FRL registry will become and stay a relatively small registry, we do not expect many problems in this area. Where problems arise with multipe parties wanting the same domain name, the legal personnel of the registry will solve these issues together with the parties involved.


Domain name pricing
The Provincie Fryslân has produced an extensive report on the FRL tld in 2011, stating that with a price of EUR 40 for a domain name, it would be possible to register 40.000 domains, and have a valid business case. However, this plan did not include the large consumer market in The Netherlands, consumers that are accustomed to much lower prices per domain name than 40 euro.

To accommodate the consumer market, the registry will start pricing at EUR 15,- per domain name. This will allow ICANN-accredited registrars to set their pricing at 20 – 30 euro, acceptable for consumers and businesses alike. With the Provincie Fryslân an agreement has been proposed, that on higher numbers of registrations the price will automatically drop, to a minimum of EUR 2,50 per domain name when total numbers of registrations hit 800.000 or more. Price increases are not expected. If a price increase would be deemed necessary, ICANN will be notified and asked for permission, as well as timely notification to all registrars that are connected to the registry. There are no specific plans for price increases. We are convinced that the 37.000 domain names in our plan is very well achievable, and that there is a high probability that domain name registrations will exceed 37.000 domains.

Together with the Provincie Fryslân a plan has been made to address all Frisian companies and citizens. In the first stages the sunrise (where trademark holders can apply) all companies that have a head office in Friesland will receive a letter from the Province that a top-level domain name can be registered for their company. This letter will contain a domain name for the company, and a authorization code to register specifically that domain name. The auth code is not bound to a specific registrar.

In the second stage, where all Frisians can apply, we will send letters to all Frisians and companies in Friesland with discount ⁄ auth codes. These codes will allow registration of Frisian domain names at a discount price (5,00 euro per domain name). The discount codes are not bound to a specific registrar.
When letters with discount codes are sent to the addresses in Friesland, these codes will allow any ICANN-accredited registrar to pay only EUR 5.- per domain name (the discount is part of the marketing costs⁄budget). When the ‘Frisian sunrise’ is over and the general landrush has arrived, the normal price of EUR 15 per domain name will apply. In this phase, discount codes will still be accepted, and will still only charge EUR 5,- for a domain name to the ICANN-accredited registrar during the first year.

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?

Yes

Protection of Geographic Names


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

he FRL registry will reserve all country-specific domain names that are indicated in the ICANN documentation. However, we do not expect any country (except the Dutch government) to be interested in a domain extension that is so specifically targeted at a province of The Netherlands.

The registry will reserve all names of Frisian cities, communities and villages. Together with the ʹFrisian Academyʹ, a specialist in the Frisian language, we have compiled and publishad a comprehensive list, in three ways:
- In the Frisian language, with IDN (e.g. feanwalsterwâl.frl or xn--feanwalsterwl-teb.frl)
- In the Frisian language, but without accents or special characters (e.g. feanwaldsterwal.frl)
- In the Dutch language (e.g. veenwoudsterwal.frl)

This list of reserved community, city and village domain names can be found at
http:⁄⁄metaregistrar.com⁄reserved-community-domain-names⁄

All these names will be added into the registry administration as ‘reserved’. A list of reserved names will be published as general accessible document on the website of the registry.
In the early sunrise phase, all cities and villages will receive notice about the opportunity to register their name with the .FRL registry. They will be able to register through any ICANN accredited registrar, provided that this registrar has entered into an agreement with the FRL registry.

Whenever a claim is made on a reserved domain name, the registry will use an independent law firm to check the claim on its validity. Every valid claim will give the authorities the choice of the 3 different domain names mentioned before.
Every authority that has succesfully claimed a domain name from the reserved list will receive an authcode for every claimed domain name. With this authcode the domain name can be registered through any ICANN-accredited registrar. The authcode will work only for the domain name it was issued to.


Upon a domain check, the reserved names will return the status string ‘reserved’. When the whois information is checked, these reserved names will not display whois information, nor will they be added to the DNS zone.

Protection of geographic names at the second level.
All geographic names specified by ICANN in specification 5 of the draft registry agreement will be listed as reserved and can only be registered through a special procedure.
A list of reserved country names can be found at http:⁄⁄metaregistrar.com⁄reserved-country-domain-names⁄
Any country-specific domain name that is brought to our attention by the GAC, and has passed GAC internal procedures, will be added to the list of reserved domain names, published on our website.

The ICANN specification 5 also mentions “the list of United Nations Member states in the 6 official languages of the United Nations”. To reserve these names will technically not be possible, since many of those names (russian, chinese) contain characters that are not supported by the registry. They cannot be registered with the FRL registry anyway.

Since this TLD is targeted at a specific part of a small country, we expect very little interest for country-named domain names. Even with a very large registry like .INFO many country names are still reserved. And many countries have no interest in the English version of their country name.

Any country or region interested in obtaining their own domain name that is on the reserved list, will first have to be approved by the GAC and ICANN. Only after these approvals the second-level domain name will be released to the requestor.

Registry Services


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

Overview


The internet today, with 22 generic top-level domain names and approximately 270 country code TLDs, is about to change. As the domain name space will be opened to organizations applying for gTLDs associated with particular interests and businesses sectors, this will help organizations and communities enhance branding, community building, security, and user interaction. Hundreds of new extensions may be introduced and each applicant will have to look for a stable and secure Registry system and technical provider. The Registry Operator has therefore chosen to outsource the technical back-end operations for the domain name Registry to OpenRegistry (the Registry Service Provider). OpenRegistry combines a steady track record with modular software to help applicants take advantage of this opportunity.
When it is stated that the Registry service Provider will perform certain services or comply with certain standards and processes, the Registry Service Provider will do this in the name and on behalf of the Applicant, who itself is committed to comply with these standards and processes towards ICANN under the Registry Agreement and the terms and conditions of the new gTLD program. Unless it is expressly stated otherwise, all services described in this question will be provided by the Registry Service Provider in the name and on behalf of the Applicant, who will monitor the Registry Service Provider’s compliance with its contractual terms and the requirements laid down by ICANN on a regular basis.
Registry Service Provider

This document sets out the range of services that OpenRegistry offers to its customers in compliance with ICANN’s new top level domain application process. The services are fully compliant with ICANN’s requirements regarding the deployment and management of a gTLD Registry System.
OpenRegistry’ multilingual staff have over 20 years of combined experience in developing and managing sophisticated solutions for domain name Registrars, domain name Registrants (in particular brand owners) and Registry Operators, as well as being involved in the design of policies for and managing registrar relationships with several ccTLDs.
All members of the team (including outsourced personnel) have been specifically trained on the Registry Platform and have an extensive knowledge and hands-on know-how about the DNS. OpenRegistry has offices in Luxembourg and Belgium.
OpenRegistry was founded by the three key leaders involved in the successful creation and operation of the .be and .eu Registries, which combined currently represent over four million domain names. The OpenRegistry team has 20 years of experience in developing and managing sophisticated solutions for Registrars and Registry Operators. The OpenRegistry system draws on the best features of the .be and .eu systems, combined with new technology that has been introduced, which results in best practice system protocols and software design.
OpenRegistry offers from a simple, totally outsourced product to a licensed version of the Registry software for clients who wish to manage their own infrastructure. In each and every case, the system meets and even exceeds ICANN’s Registry contract requirements. The software provides the flexibility to offer options to Registry Operators that are in line with its own specific operational and technical circumstances.
(View attachment for Figure 1: Registry Software Capabilities)
There are three key feature groups which address the ICANN evaluation process and which meet and even exceed ICANN’s mission and core values to protect the stability of the global Internet. These are the technical features, financial features and third party modules that are detailed in the next sections.
(View attachment for Figure 2: Registry Software Features Overview)
Stability & Security

The Registry Platform that will be deployed for the applied-for gTLD, which meets and even exceeds the technical requirements set by ICANN, combined with the team’s experience in running ccTLD domain extensions, provide a solid basis to assist the Applicant to meet its commitments to ICANN. As a Registry Service Provider, OpenRegistry is an operationally secure company with highly skilled staff and appropriate premises for running Registry Services conform to the ISO27001 standard.
DNS services are monitored at all times and external high quality any-cast providers are added in the mix to deliver excellent and premium class nameserver infrastructure all over the world.
The main features of the Registry Platform include a complete and extendible set of functionalities that can be controlled by the administrator. Some of the more profound features include support for IPv4, IPv6 and DNSSEC. The Registry Platform relies on standards-based software, carrier-grade hardware and protocol compliant interfaces. These include enabling dynamic zone file updates for immediate use after registration, escrow services and advanced reporting. Extensible Provisioning Protocol (EPP) transactions are only accepted from pre-registered IP addresses and all transactions, whether web or EPP are protected by Secure Socket Layer (SSL). All transactions are monitored, traced and logged.
The Registry Service Provider’s staff are industry-trained (in Java, SQL, Linux) university-certified professionals each with over a decade of experience in building and managing network infrastructure (CISCO, Juniper,… ) using quality hardware appropriate for the array of customers.
Diverse audit trails of all activities across software, hardware, staff movement, building access to ensure the security of our systems, are provided. A penalty system ensures Registrars cannot flood the Registry Platform with invalid requests, which would potentially degrade the system’s performance. New connections (SYN packets) are limited on the domain name Registry’s edge routers to minimize the impact of Denial of Service (DOS) and Distributed Denial of Service (DDOS) attacks. The system is further protected with a redundant intrusion detection⁄intrusion prevention system to exercise deep packet inspection and block risks on SQL-injection and cross site scripting.
OpenRegistry offers a range of services to increase the security of communications between the Registry Operator and Registrars. By default, the communication channel is encrypted using Secure Socket Layer (SSL)⁄Transport Security Layer (TLS). On top of encryption, the following options are available:
• User login with passwords and granular authorization;
• Trade and transfer control to prevent unintentional transfers;
• Limited access per second to avoid data harvesting;
• Monitored update allows ownership data to be changed only after manual checks;
• Temporary take-over by the Registry Operator in case of Registrar bankruptcy;
• Domain lock avoids malicious transfer or trades;
• On-hold status can be set pending an Alternative Dispute Resolution (ADR) case;
• Domain Name Monitoring module exposes typo-squatters by listing similar domain names;
• The Registrant extranet puts Registrants in charge of their domain names.
The Registry Platform provides a minimum of two anycast addresses, nodes in 52 locations around the world and a capacity of over 500 billion queries a day with a resolution rate of under one millisecond. Each node is set up in a redundant configuration so that a hardware failure on one machine does not prevent the node from responding to queries.
The Registry’s primary server location is located in Belgium, in a secure, state-of-the-art facility. Special care has been taken to provide several physical layers of security. The Registry database and application servers will be hosted there, with a mirror site in Luxembourg. The Registry Platform is connected using multiple Internet Service Providers (ISPs), all of them Tier 1 providers.
The applications run on a blade infrastructure, allowing for immediate recovery in the case of failure of any one element and providing easy scalability. The setup provides micro-cloud functionality that allows for easy scalability and multiple layers of redundancy. The local backup (warm standby) server is kept current by a stream of write-ahead log records, so it can take over as the master server with minimal delay. Name servers are distributed over the world for load balancing and robustness. External parties provide anycast functionality. The unicast nodes provided are set up in a redundant configuration so that a hardware failure on one machine does not prevent the node from responding to queries.
All the Registry data are stored on a cluster of database servers, both on the primary and on the mirror site. These databases are synchronized permanently. If the load on the production database is deemed too high to deliver excellent quality service, read-only copies are put in place for read-only service, such as WHOIS and Data Escrow, to off-load traffic from the main database. A special delayed recovery database is available on the primary site to be able to recover quickly from data corruption should it have spread to all on-line database servers.
(View attachment for Figure 3: Registry Services interfacing the Registry Database)
The Registry Platform is feature rich with a multitude of parameters that can be set to suit the applicant’s requirements. At system level software modules and functionalities can be switched on and off by the system administrator.
The Registry Platform contains all functionality required by ICANN for a TLD to operate efficiently through two main interfaces or more if necessary. The XML based EPP interface provides excellent means for Registrars who want to offer their customers a fully automated interface. A web interface provides extra functions that are difficult to automate next to a set of commands that are fully compatible with EPP.
The audit trail ensures that from day one every single activity in the system is logged and copied, including all associated data. This allows for going back in time and examining the situation both before and after a transaction took place. Journaling is built straight in the database, so it is hassle free for programmers and works with all programming languages.
The full and flexible audit log eliminates huge log files or endless searching. The audit log can be searched using filters and detailed search criteria, so the requested is found fast and efficiently.
The system was created for the current domain name Registry-Registrar-Registrant model but could easily accommodate a direct Registry-Registrant relationship, for which a web interface is particularly useful.

Demonstration of Technical & Operational Capability


24. Shared Registration System (SRS) Performance

Overview

The Shared Registration System (SRS) is a computer system for managing a domain name Registry, and allows for the registration, by authorized Registrars, of domain names and modification of information associated with that domain name on the Registry level.
The SRS has two matching subsystems: an Extensible Provisioning Protocol (EPP) server and a Registrar web interface.
High-Level SRS System Description

Infrastructure

The SRS platform consists of several services. These services provide the Registrar with access to the database. Registrarʹs access is limited to objects created and maintained by the Registrar. No other means than the SRS are provided to the Registrar to modify objects. The SRS system runs on a virtualized and strictly separated infrastructure to maintain consistency and security and provide for scalability and availability. For more information, reference is made to the relevant sections in question 31 (Technical Overview of the Proposed Registry), question 32 (System & Network Architecture) and Q33 (Database Capabilities).
Extensible Provisioning Protocol

As required by Specification 6 (section 1.2) and as detailed in the answer on Question 25 on the Extensible Provisioning Protocol (EPP), the Registry Operator will comply with the relevant existing RFCs. The Registry Operator will also, if applicable, implement the relevant RFCs published in the future by the Internet Engineering Task Force (IETF) including all successor standards, modifications or additions thereto relating to the provisioning and management of domain names using the Extensible Provisioning Protocol (EPP) in compliance with RFCs 5910, 5730, 5731, 5732, 5733 and 5734.
Extensive testing will verify that the software performs according to the performance specifications as required by Specification 10 for EPP. A detailed description of this compliance is demonstrated further on in this response.
The response to question 25 provides full details on the EPP implementation.
Security

Access to the EPP server system is restricted in three ways:
· Access control to the production EPP server is restricted by IP address filters;
· SSL encryption is required for the communication channels between the Registrarʹs client system and the OT&E (Operation Test & Evaluation) and Production EPP servers;
· Authentication by means of a user name and a strong password is required for session establishment.
The EPP server requires that all three mechanisms must be correctly adhered to before access is granted.
The IP addresses from which the Registrar wants to connect to the EPP server must be registered through the Registrar web interface (maximum 5 IP addresses per Registrar, subject to evaluation).
Registrar Web Interface

The Registry Operator will, in addition to the EPP server system, also run a Registrar web interface. This web interface can be used besides or instead of the EPP server interface to manage the registration and modifications of domain names and the information associated with those names.
The web interface has two parts: managing the objects in the domain name Registry database, and managing the Registrarʹs business account information.
Managing Objects in the domain name Registry Database

The management of the objects in the database via the web interface is based on the same software code as for the EPP server implementation. The different subparts of managing the objects in the database are: maintaining domain names, maintaining contacts and maintaining hosts.
· Maintain Domain: The interface allows to easily find, check, query, add, update, renew, transfer or delete domain names from the Registrar account. As an extra feature, the history of the domain name can be explored (if the domain name resides in the Registrarʹs account).
· Maintain Contact: The interface allows to easily find, check, query, add, update or delete contact information. Also the history of the contact can be listed (if the contact stays in the Registrarʹs account).
· Maintain Host: The interface allows to simply find, check, query, add, update or delete host information from the Registrar account. Also the history of the host object can be viewed (if the host object is in the Registrarʹs account).
Managing the Registrar Account

The Registrar Profile page allows the Registrar to
· View, add and update own contact information for administrative, technical, commercial and financial purposes;
· Add and update the IP addresses required for access to the EPP server (see above);
· Add and update the different email addresses of the Registrar where he can be reached by the Registry Operator for administrative, technical and financial purposes;
· View hitpoints (attributed when the EPP client software behaves erratically), and resume the Registrar account (when hitpoints reach a defined threshold, the Registrar account is suspended temporarily).
The financial information pages reveals
· Account balance overview;
· Overview of invoices and payments, with details;
· Overview of possible renewals in coming months.
The reports page provides customized reports on gained and lost domain names (via transfers), on nearly expired domain names and on the latest transactions (per object type and transaction type).
The export page offers downloads of full exports of contacts, domain names and hosts in different formats (CSV, XLS, XML), to allow the Registrar to consolidate and cross-check his own data.
Security

Access to the Registrar web interface is restricted in three ways:
· HTTPS encryption is required for the communication between the Registrar and the OT&E and production Registrar web interfaces;
· Authentication by means of a user name and password is required;
· Extra passphrase authorization to confirm transactional commands (create⁄modify⁄delete).
All communication is encrypted and secured using the SSL⁄TLS protocol. The main idea of HTTPS is to create a secure channel over an insecure network. Adding a trusted and verified server certificate ensures reasonable protection from eavesdroppers and man-in-the-middle attacks.
Security is augmented by requiring an extra passphrase authorization to complete all transactional commands on the SRS system.
Redundancy & Scalability

The SRS system runs on a mini-cloud virtualizing all machine infrastructures needed (for further information on, for instance the number of servers, see question 32). Not only does this improve high-availability and scalability, it also allows for very fine grained access control improving security and mitigating network cross connections. The cloud can be distributed over the two sites allowing for a full hot-standby mirror site. Using network based traffic mirroring, resources are scaled and load balancing and fail-over are implemented.
The synchronization scheme for the Registry database, which contains all information used by the Shared Registration System, is described in full detail in the response to question 33 (Database Capabilities). The database is continuously synchronized.
Dynamic updates are implemented on the nameserver infrastructure. All changes to the database are immediately synchronized to the worldwide nameserver infrastructure, with an average delay of 10 seconds.


Compliance with performance specifications

The availability of the Shared Registration System is guaranteed by the technical setup as described in the response to question 31. The selected Registry Service Provider, OpenRegistry, who is an experienced back-end registry services provider for already existing TLDs, will put this technical environment in place. According to their current reports for these already existing TLDs, OpenRegistry is already meeting these requirements.
The service levels that have been agreed between the Registry Operator and the Registry Service Provider include compliance statements and warranties regarding the technical operation of the TLD, and in particular the Registry Performance Specifications laid down in Specification 10 to the Registry Operator Agreement.
In so far and to the extent this Specification 10 would change following the outcome of the Public Comment regarding the Revised New gTLD Registry Agreement, the Registry Operator and OpenRegistry will comply with such modifications upon delegation of the TLD to the Registry.
Infrastructure

The full redundancy at the infrastructure level, even within the primary site, ensures that the unavailability of the system will be less than 864 minutes per month.
In order to determine the EPP response time as defined in Specification 10, the total EPP response time is broken down into its different components:
1. Network

1a. Bandwidth: Due to the nature of EPP the bandwidth resources used are limited. It is our experience that even under very high load, hundreds of transactions per second, the bandwidth never exceeds 10Mbps. In view of this, our infrastructure will easily handle any EPP load.
1b. latency: Due to the fact that the minimum network bandwidth over the entire data path under the control of the Registry Service Provider is at least 1Gbps, the maximum delay introduced by the network and the equipment (firewall, Intrusion Protection Systems and other network equipment) does not exceed 10ms.
2. TLS (secure) connection: The EPP server can handle several hundred simultaneous connections to handle a continuous flow of EPP transactions, minimizing the delay introduced by the TLS layer. Even if for every command a new session would be started, the introduced delay is less than 30ms on our standard x86 hardware under heavy load. In case this would not suffice, the TLS layer will be off-loaded to load-balancers with hardware acceleration that can handle more than 5000 TLS requests per second.
3. EPP server: The EPP server can easily handle several hundreds of EPP queries per second. To prevent data corruption a fine grained, hash-based locking mechanism is introduced. Due to the nature of this mechanism, several concurrent transactions can be handed over to the database without blocking each other. In single mode, the EPP server’s average response time is well below 100ms.
4. Database: At the lowest level, the transactional database can handle at least 200 read⁄write transactions per second and several hundred more in read-only. It is the database that is the limiting factor in the number of modifying transactions that can be handled by the EPP server.
As a result of the above, any EPP command is handled well within 200ms under high load (50 simultaneous connections registering domain names) within the infrastructure under the control of the Registry Service Provider. The fact that this is less than 10% (EPP query-command) or even less than 5% (EPP session- or transform-command) of the total round trip delay specified in Specification 10, provides sufficient confidence to meet the end-to-end round trip delay for any EPP commands. This is confirmed by measurements on the existing platform, with the total round-trip delay not exceeding 200ms in any case.
Concluding: in view of the number of the limited number of domain names the Registry is envisaging to register, as specified in the response to question 31, our EPP service will comply with the EPP service level specifications as lined out in Specification 10.
Ensuring Compliance

In order to ensure compliance with Specification 10 (and the other Specifications, where applicable), OpenRegistry has committed to monitor their performance, in particular in relation to SRS service levels.
OpenRegistry monitors on a periodic basis the elapsed time of every query, transform and session EPP transaction, and calculate the percentage of commands that fall within the service levels specified in Specification 10 and OpenRegistry’s internal operational levels. For this, OpenRegistry has deployed a monitoring system, which tracks the statuses of both the EPP and SRS Web services.
If the percentage of commands exceeds certain thresholds, such as the ones referred to in Specification 10, technical staff is alerted and intervene in order to ensure compliance.
Resourcing Plan

Technical Resources

Network

The Registry Platform is based on a full redundant network setup, based on different technologies that together form a reliable setup. The network setup is greatly detailed in the answer on Question 32 on Network & System Architecture, and consists of:
· Multi-homed network with own IP-range and Autonomous System number (AS) announce via Border Gate Protocol (BGP);
· Redundant routers and firewalls;
· Fully redundant internal network for interconnection between the Registry Services.
Network security measures include:
· Traffic shaping (on SYN packets) on the routers to minimize impact of (Distributed) Denial Of Service attacks;
· Stateful firewall to limit access to service ports only;
· Limiting source IP addresses per Registrar to connect to EPP server system;
· Network separation using VLAN (IEEE802.1q) technology to separate service and data plane;
· Private firewall on every server.
Servers

The EPP server and the Registrar web interface are running on their own respective machines. Virtualization is used to make the service machines independent of the underlying hardware.
Interconnectivity with other Registry Services

The Shared Registration System (SRS) maintains the objects in the core database from a Registrarʹs perspective. All other Registry systems such as the WHOIS service, the data escrow system, the (dynamic) zone file generator,... all use the core database.
The Registry Operator implements a thick Registry model, and as such the full data are present in the core database. There is no need to synchronize the data from different source databases into the master database.
As detailed in the answer on Question 33 on Database Capabilities, the Registry Operator is using hot-standby database replication for redundancy and fail-over, and if the load on the system should require so, the WHOIS system can be off-loaded to another hot-standby read-only copy of the core database, which is near-synchronous with the main database.
Note that the network and system setup on the primary site is duplicated on a mirror site.
(View attachment for Figure 1: Interplay of Registry Services)
Other services such as the dynamic updates of the zone file, zone file generation and escrow use the database or a trigger mechanism to update the relevant resources when the Registrar updates objects in the database.
All changes to the database are tagged and linked to a transaction description also specifying the relevant time stamp, user and IP address. The information can be used to provide a full audit trail or to pinpoint invalid or illegal behavior.
Personnel

With regards to resourcing, reference is made to the global resourcing scheme as part of response to Question 31 (Technical Overview of the Proposed Registry). Implementation and maintenance of the Shared Registration System is under the authority of the Software Developer, under control of the Operations Manager. The technical infrastructure is implemented and maintained by the Network & System Administrator.

25. Extensible Provisioning Protocol (EPP)

1. Overview
The Registry Operator will comply with the latest version of the Extensible Provisioning Protocol (EPP). The domain name Registry is designed to strict EPP standards from the ground up. No proprietary EPP extensions have been developed. Upon selection of the Trademark Clearinghouse (TMCH) provider by ICANN, the EPP implementation will be complemented with an interface towards the TMCH, in line with community defined interface specifications.
2. EPP Registry – Registrar Model
The domain name Registry implementation features a ʺthickʺ model as represented by the rich object store managed by the centralized domain name Registry.
This object store can be managed by accredited Registrars via the EPP interface that will be using the interface protocol specified by the current EPP standard.
The EPP specification is broken up into an extensible object design with each of the primary objects given an individual but consistent interface that meet the base EPP framework as described below.
EPP Protocol Highlights
RFC 5730 - Extensible Provisioning Protocol (EPP)
This document describes the foundation upon which all the specific objects (Domain names, Hosts, Contacts) must adhere to in order to maintain a consistent interface. A standard domain name Registry specific extensible object management framework is also described in this document to handle any extra information need to satisfy policy or other agreements the domain name Registry may be required to sustain.
RFC 5731 - Extensible Provisioning Protocol (EPP) Domain Name Mapping
This document describes an EPP mapping for the provisioning and management of Internet domain names stored in a shared central repository. Specified in XML, the mapping defines EPP command syntax and semantics as applied to domain names.
RFC 5732 - Extensible Provisioning Protocol (EPP) Host Mapping
This document describes an EPP mapping for the provisioning and management of Internet host names stored in a shared central repository. Specified in XML, the mapping defines EPP command syntax and semantics as applied to host names.
RFC 5733 - Extensible Provisioning Protocol (EPP) Contact Mapping
This document describes an EPP mapping for the provisioning and management of identifiers representing individuals or organizations (known as ʺcontactsʺ) stored in a shared central repository. Specified in XML, the mapping defines EPP command syntax and semantics as applied to contacts.
RFC 5734 - Extensible Provisioning Protocol (EPP) Transport over Transmission Control Protocol (TCP)
This document dictates the TCP connection strategies to use. The implemented transport layer is conform to RFC 5734 and RFC 2246. RFC 5734 specifies the low level transport and allows for a typical TCP connection to be used to serve as a client-server communication channel. To secure the communication between client and server, an obligatory Transport Layer Security (TLS) layer is run on top of the TCP connection, as specified in RFC 2246.
A number of security settings no longer comply with current security needs and are prohibited in RFC 6176. The security algorithms that are allowed to communicate were chosen to be secure and compliant with a wide variety of implementations currently in use on most operating systems. These security algorithms include Advanced Encryption Standard (AES) and Triple Data Encryption Standard (TripleDES) for encryption and RSA for negotiation.
RFC 5910 - Domain Name System (DNS) Security Extensions Mapping for the Extensible Provisioning Protocol (EPP)
This document describes the DNSSEC Extensions Mapping for EPP for the provisioning and management of DNS security extensions stored in a shared central repository. Specified in XML, the mapping defines EPP DNSSEC extensions to the command syntax and semantics as applied to domain names.
RFC 3915 - Domain Registry Grace Period Mapping for the Extensible Provisioning Protocol (EPP)
This document describes the Registry Grace Period (RGP) Extensions Mapping for EPP for the management of domain names subject to “grace period” policies defined by ICANN. Specified in XML, the mapping defines EPP RGP extensions to the command syntax and semantics as applied to domains.
Supported Command Set
A full set of EPP commands is implemented, as specified in the above mentioned RFCs. The EPP service provides all commands specified in the RFCs 5730, 5731, 5732, 5733, 3915 and 5910 in a fully functional fashion. The commands are implemented conform the specifications set forth in the RFCs. The fully compliant XSD schema describing the XML layout which can be used to validate the XML command can be found in RFC 5730-5733, 3915 and 5910.
Please note that two extensions are implemented:
• RFC 3915 is a specific extension to implement the “grace period” policies, both in providing extra information to the Registrar, as well as the possibility to restore a domain name from redemption.
• RFC 5910 is a specific description to comply with the DNSSEC extension, as is required by the Applicant Guidebook, to manage the DNSSEC keys of the domain name.
The domain name Registry will provide the following command sets to support the Registry Service:
• Greeting
• Session management
• Object Query
• Object Transform
All commands from the EPP client to the EPP server run over an encrypted connection. The EPP client has to identify itself by using the predefined session management command 〈login〉 using unique and out-of-band communicated credentials.
The command sets are described in detail below.
Greeting
The EPP server will respond to a successful connection by returning a greeting to the client. The greeting response includes information such as:
• The name of the server
• The serverʹs current date and time in Coordinated Standard Time (UTC)
• The features supported by this server, which may include:
o One or more protocol versions supported by the server
o One or more languages for the text response supported by the server
o One or more 〈objURI〉 elements which identify the objects which the server is capable of managing
o An optional 〈svcExtension〉 element that contains one or more 〈extURI〉 elements that contain namespace URIs representing object extensions supported by the server. Here the EPP server will announce support for rgp-1.0 (as defined in RFC 3915) and for secDNS-1.1 (as defined in RFC 5910).
At any time a 〈hello〉 command can be used to receive a 〈greeting〉 response.
Session Management
EPP provides two commands for session management: 〈login〉 to establish a session with a server, and 〈logout〉 to end a session with a server.
• Login: The EPP 〈login〉 command is used to establish a session with an EPP server in response to a greeting issued by the server. A 〈login〉 command MUST be sent to a server before any other EPP command.
• Logout: The EPP 〈logout〉 command is used to end a session with an EPP server.
Object Query Commands
EPP provides three commands to retrieve object information:
〈info〉 to retrieve detailed information associated with a known object,
〈check〉 to determine if an object is known to the server, and
〈transfer〉 to retrieve known object transfer status information. These are described into further detail below.
• Info: The EPP 〈info〉 command is used to retrieve information associated with a known object. The elements needed to identify an object and the type of information associated with an object are both object-specific, so the child elements of the 〈info〉 command are specified using the EPP extension framework.
• Check: The EPP 〈check〉 command is used to determine if an object is known to the server. The elements needed to identify an object are object-specific, so the child elements of the 〈check〉 command are specified using the EPP extension framework.
• Poll: The EPP 〈poll〉 command is used to discover and retrieve notification messages queued by the server for individual Registrars. Some elements are object-specific, so the child elements of the 〈poll〉 response are specified using the EPP extension framework.
• Transfer (Query): The EPP 〈transfer〉 command provides a query operation that allows a client to determine real-time status of pending and completed transfer requests. The elements needed to identify an object that is the subject of a transfer request are object-specific, so the child elements of the 〈transfer〉 query command are specified using the EPP extension framework.
Object Transform Commands
EPP provides five commands to transform objects:
〈create〉 to create an instance of an object with a server,
〈delete〉 to remove an instance of an object from a server,
〈renew〉 to extend the validity period of an object,
〈update〉 to change information associated with an object, and
〈transfer〉 to manage changes in client sponsorship of a known object. These are described into further detail below.
• Create: The EPP 〈create〉 command is used to create an instance of an object. An object may be created for an indefinite period of time, or an object may be created for a specific validity period. The EPP mapping for an object MUST describe the status of an object with respect to time, to include expected client and server behavior if a validity period is used.
• Delete: The EPP 〈delete〉 command is used to remove an instance of a known object. The elements needed to identify an object are object-specific, therefore the child elements of the 〈delete〉 command are specified using the EPP extension framework.
• Renew: The EPP 〈renew〉 command is used to extend the validity period of an object. The elements needed to identify and extend the validity period of an object are object-specific, therefor the child elements of the 〈renew〉 command are specified using the EPP extension framework.
• Transfer: The EPP 〈transfer〉 command is used to manage changes in client sponsorship of a known object. Clients may initiate a transfer request, cancel a transfer request, approve a transfer request, and reject a transfer request.
• Update: The EPP 〈update〉 command is used to change information associated with a known object. The elements needed to identify and modify an object are object-specific, therefore the child elements of the 〈update〉 command are specified using the EPP extension framework.
All above transform commands can be processed by the Registry Operator in two ways:
• immediately process the requested action;
• initiate processing the requested action, but allow for off-line review or further interaction before completing the requested action. The response of the EPP server will clearly note that the requested action is “pending”.
In the latter case the state of the corresponding object will clearly reflect processing of the pending action. For more information on the domain name states, reference is made to the response to Question 27 (Domain Name Lifecycle).
Functionality to provision Registry services
To comply with the current EPP standard, a fully functional set of commands is at the Registrar’s disposal. These functions are based on the CRUD (Create – Read – Update – Delete) principle. The state of the data is maintained by creating (C), reading (R), updating (U) and eventually deleting (D) the data from the database.
The following basic objects exist in the database:
• Domain: The domain object contains all relevant information to the domain name. This includes registration date, renewal date, status and DNSSEC key material.
• Host: A host object defines a hostname which might be linked to a domain name. It is intrinsically needed to get the domain name working. It contains at least a domain name, possibly IP addresses and other references.
• Contact: The contact object specifies a person or an organization. It contains various fields to identify such party. When linked to a domain name, a specific role is attributed to the relation.
The following commands, per object, allow for the full CRUD cycle to be implemented conform the above specified relevant RFCʹs. Please note that the read commands as referred to in the CRUD terminology are defined as query commands in the EPP-centric documentation. All objects are attributed to a specific Registrar and remain under its supervision. No other Registrar is granted access to these objects.
Registrars should first verify if the object is manageable (and owned) by using the 〈check〉 command. To get the content of an object, use the 〈info〉 command.
(View attachment for Table 1: Commands per object type)
By assigning a Registrar to all objects, a unique identifiable party is assigned to any object as the owner that is allowed to change and delete the object. To maintain a history of all changes, both a full trace log identifying Registrar, IP address, time and command as well as a history of the objects are stored in the database. This allows for a swift reconstruction of any interaction with the system. For more information we refer to the response to Question 33 of the evaluation criteria (Database Capabilities).
3. EPP Extensions
In order to be compliant with ICANNʹs Applicant Guidebook, an additional extension to maintain the domain object is needed to integrate with the Trademark ClearingHouse (Module V of ICANN’s Applicant Guidebook).
At the moment, no party has been appointed to perform the TradeMark Clearinghouse function, hence no specifications for interfacing have been established.
The function of the TradeMark Clearinghouse is to enable trademark holders to register their right in a central database, from where the trademark holder receives a validation code that can be used to apply for a domain name in a new TLD.
To that extent, ongoing community effort led already to a Launch Phase Mapping for EPP. This Internet-Draft describes an extension mapping for EPP that specifies a flexible scheme that can be used to implement several common use cases related to the provisioning and management of launch phase extension in a domain name Registry.
This mapping enables the Registrar to apply for⁄claim a domain name in the sunrise phase using the Pre-Validation Result Code 〈pvrc〉 from the TM Clearinghouse.

Security
It is imperative to make sure the service is not blocked by Denial Of Service attacks (DOS). To prevent this from happening, a number of security barriers are in place:
• rate limiting the number of connections on the border router;
• allowing only specific IP addresses specified by the Registrar;
• limiting the number of concurrent connections per Registrar.
The EPP service will run on its own virtual machine. Resources available to the machine are constantly monitored. Early warnings are sent out in case any of the resources are deemed to be inadequately provisioned.
Security is enhanced by limiting the access to the EPP server to a Transport Layer Security (TLS) connection using high-grade encryption.
The Registrar is authenticated using the predefined session commands as defined in the above RFCs. The initial credentials are exchanged between the Registry Operator and the Registrar over an out-of-band channel.
A strict object-to-Registrar link exists such that a Registrar can only view, access and modify its own managed objects.
4. Resourcing Plan
Technical Resources
This service is delivered by a JAVA application running on a TOMCAT server. To ensure the database is consistent at all times, a lock is set per Registrar to ensure multiple connections set up by a Registrar are serialized at the application level. To maintain high speed at all time, a locking mechanism is also active at the domain name level, ensuring no two domain name registrations for the same domain name are modified, while still allowing the necessary concurrency.
Experience has learned that, under high load conditions, the bottleneck will rather be located at the database level, and not at the application level. If extra CPU power is required to deal with high volumes, an extra EPP service will be provided using an alternate IP address or using a load balancer.
To improve database security, the EPP serverʹs access to the database is limited to a specific separate network. For a more complete and detailed picture, reference is made to the response to Question 32 of the evaluation criteria (System & Network Architecture).
Personnel
With regards to resourcing, reference is made to the global resourcing scheme as part of response to Question 31 (Technical Overview of the Proposed Registry). Implementation and maintenance of the Extensible Provisioning Protocol is under the authority of the Software Developer, under control of the Operations Manager. The technical infrastructure is implemented and maintained by the Network & System Administrator.

26. Whois

Overview
The Registry Operator will operate a WHOIS service available via port 43 in accordance with RFC3912. This standard service is intended as a lookup service for Registry Operators, Registrars, Registrants, as well as for other individuals and businesses that wish to query details of domain names or nameservers stored in the domain name Registry and that are public. The standard WHOIS service provides a central location for all authoritative data the Registry has on the domain name. The Registry Operator also provides a front-end web interface to allow for convenient user access to the WHOIS service.
The Registry Operator will also operate a Domain Availability Service (DAS) via port 4343. Reference is made to section 5 of this response for further detail.
All WHOIS⁄DAS services are connected to the main domain name Registry database. If and when it is necessary for operational stability reasons, the WHOIS server can be duplicated, and connected to one or more read-only hot standby database mirrors. These mirrors are updated a-synchronously via streaming replication, which results in a near real-time data duplication. 
WHOIS Service
RFC-3912 Compliant WHOIS
The RFC3912-conformant WHOIS service is engineered to handle moderate transaction load and is part of the standard suite of Registry Services. The WHOIS service will return a single response per domain name or nameserver query. The RFC3912-conform WHOIS service will comply with the requirements of Specification 4 of the Registry Agreement.
The RFC3912-compliant service provided by the Registry Operator will have the following features:
• Standard protocol accessible over the common WHOIS port 43;
• Near real-time updates;
• The format of responses follows a semi-free text format outline below, followed by a blank line and a legal disclaimer specifying the rights of the Registry Operator, and of the user querying the database;
• Each data object is represented as a set of key⁄value pairs, with lines beginning with keys, followed by a colon and a space as delimiters, followed by the value;
• For fields where more than one value exists, multiple key⁄value pairs with the same key are allowed (for example to list multiple name servers). The first key⁄value pair after a blank line should be considered the start of a new record, and should be considered as identifying that record, and is used to group data, such as hostnames and IP addresses, or a domain name and Registrant information, together;
• The format of the following data fields is: domain status, individual and organizational names, street, city, state⁄province, postal code, country, telephone and fax numbers, email addresses, date and times conform to the mappings specified in EPP RFCs 5730-5734 so that the display of this information (or values return in WHOIS responses) can be uniformly processed and understood.
WHOIS Service data elements
The RFC3912-conform service will include the following data fields:
• The name of the domain name registered;
• The IP addresses of the primary nameserver and secondary nameserver(s) of the name registered, if applicable, and the corresponding names of those nameservers;
• The identity of the Sponsoring Registrar;
• The original creation date and term of the registration;
• The name, postal address, e-mail address, voice telephone number, and (if available) fax number of the domain name Registrant;
• The name, postal address, e-mail address, voice telephone number, and (if available) fax number of the technical contact for the domain name registered;
• The name, postal address, e-mail address, voice telephone number, and (if available) fax number of the administrative contact for the domain name registered.
WHOIS Data update frequency
The Registry Operator will be running a thick Registry model, so the data will be readily available and doesnʹt need to be collected from the Registrars. The WHOIS service will query the main database, or, if database load or operational reasons demand, will query a hot standby read-only database mirror. In case of querying the main database, the data is always up-to-date, in case of querying a mirror database, the data is updated continuously via streaming replication and is near real time up-to-date (in a matter of seconds or minutes).
Privacy Capability
The Registry Operator will protect the privacy of an individual where required. If the Registrant of a domain name is an individual, the WHOIS service could disclose only limited information on the Registrant. If the Registrant wishes to disclose more information, he can instruct the Registrar to update the corresponding contact object in the Registry database (e.g. using the 〈contact:disclose〉 statement in EPP according to RFC5733).
If legislation mandates to avoid automatic harvesting of the Registrantʹs details (because port 43 WHOIS is plain text), the WHOIS service could omit the Registrant details and refer the initiator of the query to the web-based WHOIS where the WHOIS data will be disclosed in a multiple-step process.
Query Control – Object Type Control
The following keywords restrict a search to specific object type:
• Domain: Search only by domain objects. The input string is searched in the Domain Name field.
• Contact: Search only contact objects. The input string is searched in the Contact ID field.
• Nameserver: Search only by nameserver objects. The input string is searched in the nameserver field and the IP address field.
• Registrar: Search only Registrar objects. The input string is searched in the Registrar ID and Registrar Name fields.
By default, if no object type control is specified, then the Name field of the Domain object is searched.
WHOIS Output fields
Domain Records
Introduction
The WHOIS server can answer a domain name query in three different ways:
• The domain name is registered in the domain name Registry database, a typical response is detailed in section 3.1.2;
• The domain name is not registered, nor available for registration, because of various reasons, such as appearing on the blocked or reserved list, as specified in the Applicant Guidebook (see article 2.6 of the Registry Agreement), or for policy reasons. A typical response is detailed in section 3.1.3.
• The domain name Registry has no information on the domain name in the request. A typical response is detailed in section 3.1.4.
Domain Name is registered
A WHOIS query that results in domain name information will return the following fields from the domain object and the associated data from host and contact objects. This set of data is also referred to as the Domain Record.
• Domain Name (both A-label and U-label for IDN domain names, see response to Question 44 on Internationalized Domain Names);
• Domain ID;
• Domain Status (several domain status codes can be shown here, such as OK or INACTIVE, a pending action status and⁄or restriction flags. An overview can be found in the response to Question 27 on Domain Name Lifecycle);
• Sponsoring Registrar (IANA-assigned identifier) and name of Registrar
• Registrant, Administrative, Technical Contact Information including:
• Contact ID
• Contact Name
• Contact Organization
• Contact Address, City, State⁄Province, Country
• Contact Postal Code
• Contact Phone, Fax, E-mail
• Names of Nameservers and IP addresses (IPv4 and⁄or IPv6) associated with this domain
• Creation Date
• Domain Expiration Date
• Domain Last Updated Date
• DNSSEC status of delegation (signedDelegation, unsigned)
For domain names that are registered in the sunrise phase, the WHOIS can show additional labels containing sunrise information (depending on the information provided by Trademark ClearingHouse, in accordance with Specification 7 in the Applicant Guidebook).
Domain Name is not registered, but not available
A WHOIS query for a domain name that is not registered in the domain name Registry database, but is also not available for registration, will result in a single line with the reason of non-availability (f.i. “Reserved by Registry” or “Blocked by Registry”).
No information on Domain Name
A WHOIS query for a domain name for which the domain name Registry has no information, will result in a single line stating “NOT FOUND”.
Nameserver Record
A WHOIS query that results in nameserver information will return the following (this set of information is referred to as the Nameserver Record)
• Nameserver name
• IP address (if applicable, IPv4 and⁄or IPv6)
• Sponsoring Registrar (IANA-assigned identifier)

27. Registration Life Cycle

Overview
The registration life cycle for an open brand Domain Name Registry follows the same life cycle as for a general gTLD.
The following sections give an overview of the different actions that the Registrar can perform to influence the state of a domain name. Some might just change the state of the domain name. Others might alter the domain nameʹs information such as name servers, contacts, DNSSEC keys and client flags.
Some actions also involve interaction from the Domain Name Registry.
There are two distinct phases in the TLDʹs lifespan which lead to different behavior. The first phase does not allow free registrations. It typically consists of a number of sunrise periods where different parties under different circumstances are allowed to register certain domain names. The second phase is what is referred to as general availability. It could start with a so called ʹland rushʹ period that allows the Domain Name Registry to identify popular names.

Registration Lifecycle
The time line of a domain name is schematically provided in Figure 1.
(View attachment for Figure 1: Domain Timeline)
In the following paragraphs we give more detail on the different steps in the time line.
Registration (or Sunrise)
• The Domain Name Registry Operator receives the domain create command
• The domain name goes into state pendingCreate during sunrise
• The clearing house does validation of the domain name for the registrant
• The domain name is registered if properly validated, or canceled otherwise.
• Domain is registered
Update
• Add, remove or change of tech, admin, billing contacts possible
• Add, remove or change of name servers possible
• Add, remove or change of DNSSEC keys possible
• Change of registrant is possible

Transfer
• Transfer: changing Registrar, same Registrant
• Transfer command secured by authentication code
• Losing Registrar notified to accept or reject the transfer (after consulting registrant and⁄or admin contact)
• A successful transfer extends the registration period with one year (up to a maximum of ten years)

Renew
Registrars use the Renew Domain command to extend the registration period of a domain object. A Registrar can only renew domain names for which it is the sponsoring registrar. The Renew Domain command must be specified with a registration period, from one to ten years. The resulting expiry date must not lay more than 10 years in the future.
• Domain name is renewed automatically on expiry date
• Explicit renewal of period possible (registration period can be extended up to 10 years)
Delete
• Deletion puts domain name in redemption status
• Deleted from zone file instantly (serverHold)
Redemption
• Domain name is no longer available in zone file (serverHold)
• Domain name can be restored before the end of the redemption grace period (RGP)
• The domain name will be purged after the pendingDelete interval
Available
• Domain comes back in the pool of available domain names

RFC5731-Compliant Domain Name Status Codes
The status information on a domain name object is in line with the flags described in RFC5731, section 2.3. It is a combination of the following Status Value Descriptions:
• clientDeleteProhibited, serverDeleteProhibited: Requests to delete the domain name will be rejected.
• clientHold, serverHold: DNS delegation information is not published for the domain name .
• clientRenewProhibited, serverRenewProhibited: Requests to renew the domain name are rejected.
• clientTransferProhibited, serverTransferProhibited: Requests to transfer the domain name are rejected.
• clientUpdateProhibited, serverUpdateProhibited: Requests to update the domain name , other than to remove this status value, are rejected.
• Inactive: Delegation information has not been associated with the domain name . This is the default status when a domain object is first created and there are no associated host objects or host attributes for the DNS delegation. This status can also be set by the server when all host-object associations are removed.
• Ok: This is the normal status value for an domain name that has no pending operations or prohibitions. This value is set and removed by the server as other status values are added or removed.
• PendingCreate: Request to create a new domain name has been received and is being processed or evaluated.
• pendingDelete: Request to delete an existing domain name has been received and is being processed or evaluated.
• pendingRenew: Request to renew an existing domain name has been received and is being processed or evaluated.
• pendingTransfer: Request to transfer an existing domain name has been received and is being processed or evaluated.
• pendingUpdate: Request to update an existing domain name has been received and is being processed or evaluated.
Following combinations are excluded :
• ok cannot be combined with any other status
• pendingDelete status cannot be combined with ʺclientDeleteProhibitedʺ or ʺserverDeleteProhibitedʺ status
• ʺpendingRenewʺ cannot be combined with ʺclientRenewProhibitedʺ or ʺserverRenewProhibitedʺ status
• ʺpendingTransferʺ status cannot be combined with ʺclientTransferProhibitedʺ or ʺserverTransferProhibitedʺ status
• ʺpendingUpdateʺ status cannot be combined with ʺclientUpdateProhibitedʺ or ʺserverUpdateProhibitedʺ status
• pendingCreate, pendingDelete, pendingRenew, pendingTransfer and pendingUpdate cannot be combined
The status flags starting with the word ʹclientʹ can be changed and updated by the Registrar. The status flags starting with ʹserverʹ are handled by the Domain Name Registry Operator.
The Domain Name Registry will implement the above statuses in full.
RFC3915-Compliant Domain name status code
RFC3915 defines extra flags on the domain name that can be set or referenced by EPP.
These flags are referred to as the RGP flags (Registry Grace Period). The following flags are defined and can be found in a separately available EPP extension called the RGP extension (RFC3915).
• addPeriod: This “add grace period” is provided after the initial registration of a domain name. If the domain name is deleted by the registrar during this period, the domain name registry provides a credit to the registrar for the cost of the registration.
• autoRenewPeriod: This “auto-renew grace period” is provided after a domain name registration period expires and is extended (renewed) automatically by the registry. If the domain name is deleted by the registrar during this period, the registry provides a credit to the registrar for the cost of the renewal.
• renewPeriod: This “renew grace period” is provided after a domain name registration period is explicitly extended (renewed) by the registrar. If the domain name is deleted by the registrar during this period, the registry provides a credit to the registrar for the cost of the renewal.
• transferPeriod: This “transfer grace period” is provided after the successful transfer of domain name registration sponsorship from one registrar to another registrar. If the domain name is deleted by the new sponsoring registrar during this period, the registry provides a credit to the registrar for the cost of the transfer.
• redemptionPeriod: This status value is used to describe a domain for which a 〈delete〉 command has been received, but the domain has not yet been purged because an opportunity exists to restore the domain and abort the deletion process. This status must be combined with the pendingDelete status in the EPP domain mapping.
• pendingRestore: This status value is used to describe a domain that is in the process of being restored after being in the redemptionPeriod state. This status must be combined with the pendingDelete status in the EPP domain mapping.
• pendingDelete: This status value is used to describe a domain that has entered the purge processing state after completing the redemptionPeriod state without succesful restoration. This status must be combined with the pendingDelete status in the EPP domain mapping.
The Domain Name Registry will partially implement the above RGP statuses: the statuses concerning the redemption of the domain name (redemptionPeriod, pendingRestore, pendingDelete) and autoRenewPeriod.
We will not implement the following statuses:
 addPeriod: because no “domain name tasting” will be allowed
 renewPeriod: because the registrar has explicitly and successfully issued the renew command, no refund is granted;
 transferPeriod: because the registrar has explicitly and successfully issued the transfer command, no refund is granted.
Status code matrix
There are two types of status values. These may change as a result of the Client initiating a transform command referring to the commands referenced in the ʹClientʹ column or by the domain name Registry referring to the ʹServerʹ column. The last column referred to as ʹGeneralʹ contains flags that transitional status values.
(View attachment for Table 1: Status Code Matrix)
The Prohibited flags have no influence on the status of the domain object. They prevent the denoted command from being executed on the domain name object. As such when set, they prevent the transform command from being executed and hence block the specified domain name life cycle transition.
Status transitions
Global status transitions
The following domain name states can be determined
• The domain name status is defined as ʹavailable for registrationʹ (in short ʹavailableʹ) if the domain name is conform to the registration policy and the domain name object does not exist.
• The domain name is registered (no pending actions).
• The domain name has a pending action. This can be one of the following
o pendingCreate
o pendingTransfer
o pendingDelete
o pendingUpdate
o pendingRenew
(View attachment for Table 2: Exhaustive list of transitions)
Some transitions might be influenced by the registration policy. For instance
• The create has to be verified by the domain name Registry to see if no conflicts or infringements are detected.
• The name servers added to the domain name object have to comply with certain rules set forth in the policy.
• Change of ownership has to be verified.
• Domain name matches predefined rule set needing registry acceptance.
This is a non-exhaustive list which should reflect domain name registration policy regulations.
Registry grace period status transitions
The following domain name states are added to the domain name object when it has the EPP pendingDelete status:
• redemptionPeriod
• pendingRestore
• pendingDelete
(View attachment for Table 3: Exhaustive list of 3c pendingDelete state transitions)
Registration state diagram
The Registration state diagram shows all possible states and transactions between those states.
The domain name life cycle can be found in the attached flow chart (Figure 2).
(View attachment for Figure 2: Registration State Diagram)

Transition commands
The following domain object commands, requested by the registrar, can be used to trigger status transitions:
(View attachment for Table 4: Transition commands)
Registry transitions
The Domain Name Registry triggers also status transitions in case of expiration, time-outs or resolution of pending actions:
(View attachment for Table 5: Registry status transitions)
Resourcing Plan
Personnel
With regards to resourcing, reference is made to the global resourcing scheme as part of response to Question 31 (Technical Overview of the Proposed Registry). Implementation and maintenance of the Registration Lifecycle in the Registry Platform is under the authority of the Software Developer, under control of the Operations Manager.

28. Abuse Prevention and Mitigation

Introduction
Next to ensuring that a TLD is operated in a technically stable and secure manner, it is also of utmost importance that the Internet community at large is safeguarded from abusive and malicious behavior. Existing TLDs have often suffered from such behavior and, gradually, best practices have been developed in order to not only counter abusive or malicious conduct, but also prevent such issues from happening.
Abusive use of a domain name generally includes, but is not limited to the following:
1) illegal or fraudulent actions;
2) using domain names in the TLD in order to send or forward unsolicited bulk messages, generally referred to as “spam”;
3) distribution of malware: using domain names in order to disseminate software (e.g. computer viruses, keyloggers, etc.) that is designed to damage or harm the integrity of computers;
4) phishing: displaying web pages that are intended to mislead Internet users, with the aim of obtaining in a malicious manner from such users their sensitive data such as logins and passwords of the pirated websites;
5) pharming: redirecting Internet users to fraudulent website, which is generally done by hijacking or poisoning the DNS or changing host files on the victim’s computer;
6) fast-flux hosting and botnets;
7) Illegal access to Other Computers or Networks: Illegally accessing computers, accounts, or networks belonging to another party, or attempting to penetrate security measures of another individualʹs system (often known as ʺhackingʺ). Also, any activity that might be used as a precursor to an attempted system penetration (e.g., port scan, stealth scan, or other information gathering activity);
8) Using domain names in the TLD in order to disseminate illegal content, such as child pornography

Control
Considering the fact that the applied-for gTLD will relate to a specific region, the Applicant ⁄ Registry Operator will put in place various tools in order to mitigate or even exclude the possibility that the reputation of the region and its identifiers are not harmed in any way. Especially, these tools and techniques will ensure that the Applicant will have the ability at all times to exercise control over:
1) the registrant;
2) the domain name;
3) the contact information associated with any domain name; and
4) the products, services and information provided under such domain name.

In order to effectuate this, a limited number of identified individuals within the Applicant’s organization will be able to control the applied-for TLD and any and all domain names registered herein from one portal, which may have the following functionalities, if and when required:

1) validating the registrant’s eligibility and user rights in order to register domain names in the applied-for TLD;
2) validating whether an (about to be) registered domain name in the applied-for TLD corresponds to the naming conventions that will be established by the Registry Operator for domain names registered in the applied-for TLD;
3) validating contact information associated with registered domain names, in particular these contacts that can exercise control over the domain name itself, the name servers associated with such domain name, etc.;
4) validating specific commands, including create, update and delete commands;
5) approving for some or all domain names any transfer or trade requests, or intervene in the execution of such requests where the Registry Operator suspects that such transfer or trade requests are initiated in bad faith; and
6) review whether the use that is made of a particular domain name corresponds with the Registry Operator’s use policy, and suspend domain name registrations or even delete name servers associated with domain names that are being used in a manner that does not comply with the types of uses that are allowed by the Registry Operator.
Access to this portal will be given to the administrators of the Registry Operator; furthermore, the Complaints Point of Contact will also obtain access to a limited number of features explained above.

Reporting
Also, the Registry Operator will obtain access to reports generated by its back-end registry services provider, which reports include:

1) number of DNS queries for each particular domain name registration;
2) number of new domain names registered;
3) number of new contacts created;
4) etc.

If any suspicious activity is being detected following analysis of these reports, the Registry Operator will thoroughly investigate the matter and take appropriate action where required.
Anti-abuse policy
Prior to the delegation of the TLD, the Registry Operator will publish the terms and conditions for the registration of domain names in the applied-for TLD, which will include an anti-abuse policy. Highlights of such policy will include:
Complaints Point of Contact: the Registry Operator will put in place a Complaints Point of Contact. The Complaints Point of Contact’s contact details will be mentioned on the home page of the Registry Operator, including on the web-based WHOIS interface.

Virus & Malware Monitoring
The Registry backend service provider, appointed by the applicant, will put in place certain tools and methodologies in order to proactively screen for malicious conduct. Such tools include scanners that automatically scan for viruses or other forms of malware on all services deployed under applied-for domain names.
These tools will operate in the background, and will not effect the functioning of the applied-for TLD.
Prevention of Orphan glue records
In compliance with SSAC recommendations, the Registry backend service provider, appointed by the applicant, will check for the existence of glue records following the receipt of a deletion request for a particular domain name registration. If it would appear that no other domain names other than the domain name that is up for deletion are using the glue records associated with that domain name registration, the Registry Operator will remove such glue records after the domain name is deleted.
Furthermore, any interested party will be entitled to file a complaint before the Complaints Point of Contact if it would appear that orphan glue records would still exist. If it would appear, following investigation by the Registry Operator, that orphan glue records would still exist in the zone file, such records will be promptly deleted from the zone file.
Glue record
RFC 1034 defines glue as
A zone contains ʺglueʺ resource records which are not part of the authoritative data, and are address resource records for the servers.
And specifies further that
These resource records are only necessary if the name serverʹs name is ʺbelowʺ the cut, and are only used as part of a referral response.
In this specific case a glue record is the IP address of a name server held at the domain name registry. They are required when a set of name servers of a domain name point to a hostname under the domain name itself. For example, if the name servers of example.com are ns1.example.com and ns2.example.com: to make the domain name system work, glue records (i.e. the IP addresses) for ns1.example.com and ns2.example.com are required. Without the glue records for these name servers the domain name would not work as anyone requiring DNS information for it would get stuck in a loop.
Example:
What is the name server for example.com? -〉 ns1.example.com
What is the IP address of ns1.example.com? -〉 donʹt know, try looking at name server for example.com
What is the name server for example.com? -〉 ns1.example.com
With the glue record in place the registry will hold the IP address and the loop will not occur.
Example:
What is the name server for example.com? -〉 ns1.example.com
What is the IP address of ns1.example.com? -〉 [IP Address]
Orphan glue
The zone generation process could publish A-records ʺaddress-recordsʺ (also called ʺglueʺ records) regardless of whether or not the name server is referenced by any NS (name server) records. If an A-record is published and no zone delegations reference to such a record, it is called an orphan. Its presence in the zone is undesirable for a number of reasons, both administrative and technical.
Out-of-bailiwick records
Records pointing to names of other zones besides the relevant registry zone, are called out-of-zone records or even out-of-bailiwick records. Any IP addresses linked to these names should in all circumstances be refused by the registry since they do not form part of the registryʹs zone. Most modern nameserver software will ignore these records by default.
Exclusion
Glue records can only be inserted following the registration of a domain name and the creation of a host object. They can also only be included when the name servers have the same extension as the domain name.
Example:
A glue record can only be inserted if the name server of example.com is located in example.com
These address records only live by the grace of the domain name itself. Since the IP address is always linked to the domain name, the address will also disappear from the zone as soon as the domain name is eliminated from the registration database. This limits the possibility to register name servers within a domain name, because setting up circular referencing name servers is not allowed. In view of the possible risks and dangers, this is a very balanced choice of limitations and it allows for a flexible and consistent handling of glue records.

WHOIS accuracy
The Registry Operator will include in its domain name registration policies the obligation to keep all information contained in the WHOIS accurate and up-to-date.
As mentioned in response to Question 26, the applied-for WHOIS will be a “thick” WHOIS, where all key contact data relating to every domain name registered in the applied-for TLD will be stored at the level of the Registry Operator.
Working closely with the accredited registrars for the applied-for TLD, Registry Operator will put in place measures whereby registrants are obliged to keep their WHOIS information accurate and up-to-date. Clauses will be inserted in the Registry-Registrar Agreement to that effect, in particular:

1) under the terms of the Registry-Registrar Agreement, accredited registrars will be required to impose upon their clients the obligation to maintain accurate and up-to-date WHOIS data at all times;
2) furthermore, accredited registrars will be instructed to send their customers who have registered a domain name in the TLD a request to confirm the accuracy of their WHOIS data and⁄or an email message whereby their obligation to keep WHOIS data accurate and up-to-date will is restated.
3) accredited registrars will have to demonstrate, upon the Registry Operator’s request, their compliance with the above, as well as any changes that have been made to WHOIS data following submission of such instructions.
The above processes and requirements will in particular be relevant as of the moment that the applied-for TLD will no longer be a single registrant TLD, which entails that certain parties, other than the Registry Operator, will be entitled to register domain names in this extension.
Furthermore, the Applicant ⁄ Registry Operator will display on the web-based WHOIS interface a link to the Complaints Point of Contact. Any party who is of the opinion that certain WHOIS data is inaccurate, incomplete or not up-to-date can contact the Complaints Point of Contact. The latter has the authority to commence investigations, and – in case of registrant non-compliance – take measures against such registrant. These measures include, but are not limited to, putting the domain name on hold, or revoking the domain name registration.
WHOIS abuse prevention measures
Considering the fact that a WHOIS database contains quite some sensitive information that is available to Internet users at large over a web-based interface, the Registry Operator will put in place various methods in order to avoid abuse of such information by third parties.
First of all, the Registry Operator will only display search results in response to a search query after the user has successfully entered the displayed CAPTCHA code together with such query, this in order to prevent the automatic harvesting of WHOIS data.
Furthermore, private individuals (if at all allowed by the Applicant ⁄ Registry Operator to register and hold domain names within the TLD) will be allowed to indicate – through their registrars or via a web-based portal provided by the Applicant ⁄ Registry Operator – that certain personal data will not be automatically displayed following a successful WHOIS query. This measure is taken in order to comply with particular applicable laws and regulations regarding data privacy.
However, parties demonstrating to the Registry Operator that they have a right or legitimate interest in order to obtain access to this hidden data can request access to a particular, identified record upon request to the Registry Operator. Positive responses to legitimate requests shall not be unreasonably withheld or delayed.
The features described above can be temporarily or permanently disabled for specific eligible parties, such as law enforcement agencies, and this upon simple request by a competent authority. These eligible parties will then obtain access to all WHOIS information via a secure, web-based portal.

29. Rights Protection Mechanisms

Introduction
ICANN has implemented in the Applicant Guidebook a number of new Rights Protection Mechanisms, including but not limited to a mandatory Sunrise process, a Trademark Claims process, and a Uniform Rapid Suspension process, next to the existing Consensus Policies regarding the registration of domain names that infringe the trademark rights of others.

This section describes how the Applicant will comply with the above policies and procedures, and even implement additional processes, in order to ensure that the reputation and good name of the applied-for gTLD is safeguarded at all times.
Preventing abusive domain name registrations
In order to prevent abusive domain name registrations in the applied-for TLD, the Applicant ⁄ Registry Operator will be entitled and have the ability to intervene in various steps of the domain name lifecycle. In order to enable the Applicant ⁄ Registry Operator to do this, it will provide access to a control panel (“portal”) to key individuals within the Applicant’s organization. By way of this portal, these users can exercise at any time control over the applied-for TLD and any and all domain names registered in this extension, and in particular:
1) validate whether a (about to be) registered domain name in the applied-for TLD corresponds to the naming conventions that will be established by the Registry Operator for domain names registered in the applied-for TLD;
2) validate contact information associated with registered domain names, in particular these contacts that can exercise control over the domain name itself, the name servers associated with such domain name, etc.;
3) validate specific commands, including create, update and delete commands;
4) approve for some or all domain names any transfer or trade requests, or intervene in the execution of such requests where the Applicant ⁄ Registry Operator suspects that such transfer or trade requests are initiated in bad faith; and
5) review whether the use that is made of a particular domain name corresponds with the Applicant’s ⁄ Registry Operator’s use policy, and suspend domain name registrations or even delete name servers associated with domain names that are being used in a manner that does not comply with the types of uses that are allowed by the Applicant ⁄ Registry Operator.
Therefore, it is likely that for the term of the Registry Operator Agreement that will be executed between the Applicant and ICANN following award of the applied-for TLD by the latter to the Applicant, the Registry Operator will do its best efforts in order to carefully monitor domain name registrations that are being made in the applied-for gTLD.
This way, the Applicant ⁄ Registry Operator will put measures in place on a continuous basis whereby, first of all, the rights and legitimate interest of third parties are safeguarded, and secondly the good reputation of the applied-for gTLD is maintained.

Internal verification and validation processes
One of the safeguards that will be implemented by the Applicant ⁄ Registry Operator will be the screening of domain names before such domain names get registered and⁄or entered into the zone file of the applied-for TLD.
This process will be implemented for each and every domain name reserved by the Registry Operator and Friesland local authorities and registered prior to the launch of the Sunrise process described below.
During any of such screenings, the relevant legal and risk management departments of the Applicant will consider the following factors:
1) the likelihood of trademark infringement, if and when such domain name would become registered;
2) the legitimate interests the Registry Operator or the local authorities would have when using such domain name. This is in particular relevant if the domain name represents a generic, dictionary word that could be protected as a trademark;
3) any potential harm being done to trademark owners when registering and using a particular domain name in the applied-for TLD, and the benefit such domain name would have for the registrant.
Furthermore, the Applicant ⁄ Registry Operator may also implement a process whereby it would be screening on an ongoing basis the use that is being made of any domain name registered in the applied-for TLD and will implement reasonable measures in order to avoid harm being done to third parties. This can be done by randomly checking a portion of the domain names registered in the applied-for gTLD.
Although the above processes will make it extremely unlikely that the Applicant ⁄ Registry Operator will engage or encourage potentially malicious or infringing activities to be carried out under the applied-for TLD, these cannot be completely excluded.
Therefore, in addition to monitor any domain names registered under the applied-for TLD and the use that is made of such domain names, the Registry will – in accordance with its domain name registration policies – at all times be entitled to intervene if any illegal, malicious or fraudulent activities have been detected. Measures that can be taken include the suspension, revocation and blocking of any domain name registration and, in general, take any action necessary in order to limit or outright avoid any harm being done to the interests and reputation of third parties, the Registry Operator and the applied-for gTLD.

Sunrise
As required by the Registry Operator Agreement, the Registry Operator will implement a Sunrise period and a Trademark Claims service during the start-up phases for registration in the applied-for gTLD.
These mechanisms will be supported by the established Trademark Clearinghouse as indicated by ICANN.
The Trademark Clearinghouse is a central repository for information to be authenticated, stored, and disseminated, pertaining to the rights of trademark holders.
The Applicant ⁄ Registry Operator will implement a Sunrise process for the applied-for gTLD, during which eligible rightsholders are offered an early opportunity to register domain names in the gTLD.
During this process, holders of certain trademark rights will be entitled to safeguard the domain names that are identical to the name(s) to which they hold rights, as specified in the Trademark Clearinghouse model accompanying Module 5 to the Applicant Guidebook.
The standards for participation in the Sunrise, which have been aligned with the requirements for inclusion in the Trademark Clearinghouse, are:
- nationally or regionally registered word marks from all jurisdictions;
- any word mark that has been validated through a court of law or other judicial proceeding;
- any word mark protected by a statute or treaty in effect at the time the mark is submitted to the Clearinghouse for inclusion;
- other marks that constitute intellectual property.
- protections afforded to trademark registrations do not extend to applications for registrations, marks within any opposition period or registered marks that were the subject of successful invalidation, cancellation or rectification proceedings.
In accordance with the provisions set out by ICANN in relation to Sunrise processes, recognize and honor all word marks:
(i) nationally or regionally registered and 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 have been court-validated; or
(iii) that are specifically protected by a statute or treaty currently in effect and that was in effect on or before 26 June 2008
Applicant’s ⁄ Registry Operator’s back-end registry operator has significant experience in managing Sunrise processes. In particular, various key staff members were heavily involved in designing and implementing Sunrise processes that preceded the launch of the .EU ccTLD, which is generally considered the most successful Sunrise process that has ever been implemented.
The Registry Service Provider has been involved in the implementation of the Sunrise process for the .SX TLD. Therefore, the Applicant ⁄ Registry Operator can rely on significant experience and expertise in order to deploy these processes in an efficient and swift manner.
Based on this experience, the Registry Service Provider has designed its registry platform in order to comply with ICANN’s requirement to integrate the registry platform with the Trademark Clearinghouse platform appointed by ICANN.
Furthermore, the Applicant may opt to implement a phased Sunrise process, allowing eligible trademark owners who are residing or have been established in the area of Friesland (Phase I) the opportunity to safeguard their trademarks in the gTLD before other eligible rightsholders will be entitled to do so (Phase II). Furthermore, the Applicant may opt to implement a process whereby eligible trademark owners would be entitled to permanently block their trademarks in the gTLD.
Applicant will be setting different fees for each of the specific processes and procedures it will develop, taking into account the overarching concern that it is in the best interest of the applied-for gTLD to have clear and detailed processes in place that protect the interests of trademark holders.

Trademark Claims
The Applicant ⁄ Registry Operator will support ICANN’s Trademark Claims process. Depending on the actual process that will be put in place by the Trademark Clearinghouse, the Applicant will implement these processes for at least the duration indicated in ICANN’s Applicant Guidebook or may even have this process in place for a longer term.
Similar processes have been put in place by various staff members of the Applicant’s back-end registry operator, so also here the Applicant can bow on significant and hands-on experience in handling these types of processes.


Complaints Point of Contact
As is the case for various other processes and proceedings whereby third parties’ interests can be harmed, the Complaints Point of Contact that will be put in place by the Applicant ⁄ Registry Operator will also here play a pivotal role.
Any party claiming that his trademark(s) are infringed due to the registration and use of a domain name in the applied-for TLD is able to file a complaint before the Complaints Point of Contact of the Applicant ⁄ Registry Operator. Filing these complaints will be free of charge. The Complaints Point of Contact will generally provide a written response or even resolution of the matter within 5-10 business days following the receipt of the complaint.
Within this timeframe, the Complaints Point of Contact will investigate the complaint, and carry out ex officio investigations. As mentioned previously, the Complaints Point of Contact is entitled to suspend domain name registrations, delete name servers associated with infringing domain name registrations, or even outright revoke and block domain names from further registration if the Complaints Point of Contact is of the opinion that such domain name potentially infringes the rights of a third party, that no legitimate use is being made by the registrant of such domain name, and that there is bad faith involved.
It is the true desire of the Applicant ⁄ Registry Operator to have potential issues resolved by the Complaints Point of Contact. Therefore costly litigation can be avoided and issues resolved amicably.

UDRP and URS
The Applicant ⁄ Registry Operator will implement all domain name dispute resolution policies designed by ICANN, including but not limited to those described in Consensus Policies and the Applicant Guidebook. For the sake of clarity, the Applicant shall comply with the Trademark Post-Delegation Dispute Resolution Procedure (PDDRP) when final procedure is adopted by ICANN. The Applicant shall agree to implement and adhere to any remedies ICANN imposes (which may include any reasonable remedy, including for the avoidance of doubt, the termination of the Registry Agreement pursuant to Section 4.3(e) of the Registry Agreement) following a determination by any PDDRP panel and to be bound by any such determination.
In this respect, the Applicant ⁄ Registry Operator will put any registered domain name on hold following receipt of a notification from the Uniform Dispute Resolution Policy or the Uniform Rapid Suspension Policy dispute resolution service provider that a complaint under such policies have been received.
Furthermore, it will implement decisions rendered by such dispute resolution service providers, however taking into account at all times that eligibility restrictions may be in force for domain name registrations made in the applied-for TLD.
This could entail that the only remedy available to a third party that is not entitled by the Applicant ⁄ Registry Operator to register domain names in the applied-for TLD will be the revocation ⁄ deletion of the domain name. In order to ensure maximum compliance with any such decision, the Applicant ⁄ Registry Operator will put such domain name on a blocked list (i.e. make this domain name unavailable for further registration) insofar and to the extent the UDRP ⁄ URS dispute resolution service provider was of the opinion that the domain name registered by any party other than the Registry Operator or other members of the Applicant meets the requirements set out in the UDRP or URS.

Resourcing Plan
The Applicant foresees that 1,5 FTE resource will suffice in order to oversee and execute the tasks described herein, in addition to the technical and operational resources put at the disposal by OpenRegistry in this respect

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

The Registry Operator has outsourced the technical back-end registry operations to OpenRegistry S.A., the (backend) Registry Service Provider. Within the OpenRegistry group, Sensirius, doing business as OpenRegistry Belgium, as an Affiliate of OpenRegistry S.A., is the operational entity that will be running the registry operations for the entire group.

The Registry Service Provider has put in place an Information Security Management System (ISMS) for its registry operation activities. For a full description of the ISMS, reference is made to the response to question 30b.

The ISMS has been recently audited by Deloitte Bedrijfsrevisoren, Belgium. The report for this independent assessment of the security system is attached to question 30b.

For reasons of confidentiality, all elements related to security (including elements indicated in question 30a and a summary of the security policy) have been addressed in the response to question 30b. Attached to the response to question 30b are also the policies that are put in place by the Registry Service Provider for assuring the registry operations on behalf of the Registry Operator.



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