Application number: 1-1280-72896 for Valuetainment Corp.

Valuetainment Corp.

Wigaertlistr. 10
Taegerwilen 8274
CH

+41 71 6772020

+41 71 67720222

http:⁄⁄www.valuetainment.com

Mr. Dirk Hamm

CEO

+41 71 6772020

dirk.hamm@votingtool.de

Ms. Julika Riekenberg-Hamm

COO

+41 71 6772020

julika.riekenberg@votingtool.de

Corporation

Registered in Switzerland at the Register of Corporations of the Province Thurgau with the number CH-440.4.017.893-5.

Not Available

Dirk Hamm
CEO

Hamm Holding Corp.
Holding

voting

Not Available

There should be no rendering issues since the .voting string is an ASCII string and should be no problem with all browsers. While the string .voting is unusually long, today there are already strings of identical length with the .museum and .travel TLDs.
As far as IDNs on the second level are concerned, the applicant is using character sets which are used by the .de ccTLD with almost 15 million domain registrations without any known operational issues and the cyrillic character set is used by the .ru ccTLD wit more than 3,7 million domain names.
However, it is expected that there will be problems using .voting domain names as login credentials since they might not pass the plausibility checks. Also, there will be issues with e-mail clients.
There are almost no possibilities for the applicant to influence countermeasures. However, the applicant knows that software developers recognize the new gTLD program and are working on solutions. For the time being, the applicant will clearly describe potential issues on the registry website and inform its registrants accordingly.

The proposed .votinggTLDwill be the trustworthy online space dedicated to carrying out votes, polls, surveys or hosting forums for the exchange of opinion. It will
- make it easier for users to find information about polls or forums
- provide for a safer and more secure surfing experience and reduce the risk of users being deceived by illegitimate offers, and so mitigate the risk of users becoming victims of abusive behaviour and malicious conduct.
- help leverage the potential of the Internet and its users to voice their opinion and exchange thoughts.

The applicant, Valuetainment AG, Switzerland, was founded in 2005 and has a lot of expertise in the area of conducting polls. The applicants offers the so called Votingtool (votingtool.com), which gives private and commercial customers the possibility to obtain the opinion of readers, viewers, customers, friends, employees, fans or other target groups. The subject of such polls may be political questions, products, movies, pictures, to name a few examples. At the time of drafting this text, the Votingtool is used by more than 30,000 customers. The experience in this business led to the idea of the .voting gTLD.
Current situation:
Today, Internet users are confronted with the a multitude of opportunities to participate in polls, surveys or give their opinion. Often, users are asked to provide personal data when participating in such activities. 
However, the user often does not know 
- to whom the information is provided;
- what is done with the information; and 
- whether personal information such as an e-mail address will then be used for marketing purposes or even passed on to third parties.
Such uncertainty makes it
- difficult for those seeking the opinionsof Internet users to achieve favourable response rates and
- difficult for users to decide whether or not they should participate in such activities.
As a consequence,
- the Internet cannot be used in the best possible way with its virtually unlimited possibilities for participation of all users and
- users will not be eager to use all the opportunities they are offered to participate.
 
The proposed .voting gTLD will help overcome these shortcomings.

The proposed .voting gTLD will offer a namespace dedicated to carrying out polls and surveys or operating forums. 

Both registrants and Internet users will benefit from transparent rules for the TLD, in terms of acceptable use versus abuse and also in the area of data protection. This will make it easier for registrants to achieve their goal, namely obtaining opinions from as many users as possible, and also easier for Internet users to participate, since they will know that .voting domain names are governed by policies ensuring a high quality standard and high reputation.
Since the .voting gTLD allows for IDN registrations in either Latin or Cyrillic character sets at the second level, the namespace is attractive to both registrants and Internet users in Europe, Russian speaking countries and the US and Australia, which are the key markets for the applicant.
The applicant will have information on the registry’s website in all respective languages and provide FAQs and support in German, English, French, Spanish, Italian, Polish, Czech, Hungarian and Russian.

adi-iii.
In order to achieve this, the .voting gTLD will be based on the following pillars:
A. The namespace will indicate to Internet users that their opinion will be asked for. As a self-explanatory TLD, it will make it easier for those who are conducting a survey, a poll or providing a forum for discussion to direct Internet users immediately to such offers.
B. The proposed .voting gTLD is a place on the Internet run exclusively for surveys, polls or forums. No other content or services are allowed (with the exception of the domain names run by the registry itself).
C. All websites accessible via a .voting domain name must have information on the provider of the service if personal data of the users is collected, and have a privacy policy which clearly explains to the user how the information that is collected will be used.
D. Freedom and diversity of expression is a core value of the .voting Registry. Thus, forums for the exchange of information can be provided without disclosing the identity of the operator. However, this may only be done in compliance with the rules established by the .voting Registry and provided that no information on the user is gathered beyond the information that is inevitably submitted by the user’s computer and that such information is not stored by the website operator beyond potential legal requirements.
Summarising,the .voting registry will establish and communicate three rules:
- You will never be asked financial information such as your credit card number on a .voting domain name (except on websites operated by the registry).
- Whenever you are asked to provide your name, address or e-mail address or other personal data, you can expect to be told who is collecting the information and to be given a clear explanation of what information is collected and how it is going to be used.
- If the operator of a website does not disclose its identity, you should never be asked for any personal data.
The .voting Registry will not only provide robust policies which clearly present the content restrictions and requirements, but also provide a response mechanism which enables users to report websites not abiding by the rules. .voting Registry will be responsive to such reports and escalate actionable reports in accordance with its Anti Abuse Policy.
In order to stimulate (i) the use of the domain names as such and (ii) the creation of unique content, the applicant will offer all registrants of .voting domain names the “advanced” version of Votingtool, which they can customize to carry out their polls or surveys or use to manage their forum for free. Additional functionalities are present in the “premium” version of Votingtool, which can be purchased from the applicant. 
The Votingtool would be “glued” to the domain name as follows: The customer creates an account with Votingtool. During this process, the customer’s e-mail address is verified. The customer then downloads a preliminary installation package, which is a single file with a generated authentication token. This file is placed on the webserver connected to the .voting domain name. The customer then sends a verification request to Votingtool via a web interface. This establishes that the user of the Votingtool is actually the registrant of the domain name. Once the token has been verified, the service is unlocked and the customer can download the Software Development Kit (SDK) using the web interface on his web server.
The applicant will provide the Votingtool in all languages covered by the proposed IDN characters. Support will be provided in German, English, French, Spanish, Italian, Polish, Czech, Hungarian and Russian.

ad iv.
In addition to the rules and policies mandated by the new gTLD Agreement, .voting will include the following in its policies:

In order to support the goal of creating a namespace with unique content the applicant has chosen to give special treatment to certain domain names. 
Certain Premium Names will be blocked from general registration and will be sold and⁄or auctioned off by the applicant. By doing so, the applicant reduces the risk of speculative domain registrations for domain names that are important for the namespace. It can be expected that such domain names will be primarily invested in by parties wishing to use the domain names to offer content or services. 
The applicant further has the right to reserve certain .voting domain names for personal and⁄or internal use and to provide information or services to populate the namespace with valuable information relevant to the TLD. With this measure, the applicant will help population of the namespace with unique content from the very beginning, in order to stimulate the creation and publication of content relevant to TLD.

Further, the applicant will use an Acceptable Use Policy (AUP) which provides for clear demarcations of acceptable use versus abuse. 

The AUP will differentiate between “registration abuse” and “usage abuse” (together “malicious use”).

“Registration abuse” is:
- use of faulty⁄falsified⁄incomplete⁄stolen person-related or company-related data on registration (danger to WHOIS accuracy, see answer to q28);
- cybersquatting⁄typosquatting;
- registration of illegal domain names, which themselves constitute a breach of applicable laws;

“Usage abuse” is:
- violation of applicable laws or regulation; in particular the provisions of the German Criminal Code, the German Youth Protection Act and the German Interstate Treaty on the Protection of Minors in the Media (JMStV); content and services that are not liable to detrimentally affect the development of young persons and no adult material may not be offered without restrictions;
- use of a domain to publish content which incites hatred against parts of the population or against a national, racial, religious or ethnic group, content which glorifies violence, content which violates human dignity, content which denies or plays down acts committed under the National Socialist regime;
- distribution of child abusive material; 
- use of a domain name for the dissemination of spam, i.e. unsolicited bulk electronic communication (e-mail, instant messaging, on websites, in forums or mobile messaging) or advertising a domain name by means of spam;
- use of a domain name for Distributed Denial-of-service attacks (“DDoS attacks”);
- use of domain names in phishing activities, tricking Internet users into divulging personal data such as names, addresses, usernames, passwords, or financial data;
- use of domain names in pharming , such as DNS hijacking and DNS cache poisoning;
- use of domain names for the intentional distribution of malicious code such as spyware, botware, keylogger bots, viruses, worms or trojans;
- use of domain names to command and control botnets , i.e. a network of compromised computers or “zombies,”
- use of domain names in activities intended to gain illegal access to other computers or networks (“hacking”), as well as any activity to prepare for such a system penetration;
- use of domain name fast flux hosting, disguising the location of Internet addresses or Internet services;- use of a domain name for financial transactions (with the exception of the applicant)- use of a domain name for collecting personal data (beyond information that is automatically transmitted by the user’s computer) without publishing (i) a statement showing the correct name, address, name of representative and e-mail address of the website operator and (ii) a privacy policy, both of which are recognizably linked with each web page (provision of such data is independent of potential legal requirements to provide additional information).

The AUP will be enforced by means of robust escalation procedures including response times to provide for swift action, if needed. 

Due to the fact that the AUP is based on the rigid youth protection provisions in Germany, registrants are required to make adult material available only in closed user groups using age verification systems that follow standards issued by the Commission for the protection of minors in the media (www.kjm-online.de) and material which is detrimental to the development of minors or harmful to minors may only be made available when criteria laid down in the respective legislation are met and which will be further specified in a transparent manner in the policies). This will help providing for a high level of protection and exceptional user experience.

v.
Preserving diversity and freedom of opinion is one of the core values of the applicant. Within the boundaries of applicable laws, these constitutional rights will be supported by the applicant’s registry. Thus, the use of proxy and privacy services to protect the privacy or confidential information of registrants or users will be allowed at the discretion of registrars and registrants. However, the applicant will implement all policies and requirements ICANN may impose on the subject of privacy and proxy services. In addition to this, the registry will conduct its business in compliance with German⁄European data protection laws, which provide for a high level of protection. Finally, the use of privacy or proxy services does not release the registrants or website operators from abiding by all .voting policies.

In order to raise awareness for the .voting gTLD, the applicant will issue press releases and offer background briefings to specialist journalists. In addition, information will be published on the registry’s website and information packages offered to registrars containing banner ads, tutorials and videos. The information will also be issued to the existing customer base via e-mail and regular mail.

The applicant will use various measures to eliminate or minimize social costs. 

First, the applicant will implement all Rights Protection Mechanisms as required by ICANN. This commitment applies both for currently known RPMs and those yet to be defined or imposed at a later stage by means of consensus policies.
Second, the .voting TLD will be marketed as a namespace for a very specific purpose and with clear content restrictions. As a consequence, the TLD will most likely not be interesting for abusive registrations since users will be informed that e.g. no financial transactions are permitted, which will deter the majority of those engaging in criminal activity, such as phishing data or selling pirated goods. 
Today, the vast majority of all UDRP cases relate to .com, .net and .org domain names, all of which address Internet users at the global level and none of which have content restrictions. 
Third, certain Premium Names will be blocked from general registration and will be sold and⁄or auctioned off by the applicant. 
Fourth, the applicant has the right to reserve certain .voting domain names for personal and⁄or internal use and for the provision of directory services to populate the namespace with valuable information relevant to the TLD. 
All these measures help mitigate the risk of abusive or speculative registrations. There is accordingly expected to be littleneed for defensive registrations.

i.
As a general principle, the applicant will deal with multiple registrations for a domain name on the first-come, first-served basis. However, the applicant reserves the right to auction certain names during the sunrise period or either auction or sell premium names at a later stage.

ii.
As of today, no cost benefits are planned. There is the option for all registrants to use the advanced version of the Votingtool for free. However, the applicant reserves the right to implement cost benefits at a later stage. Should registrants opt for the advanced or premium version of Votingtool, the applicant will honour this with a commission, to be credited to the registrar’s deposit for .voting domain names.

iii.
Registrations will be offered in accordance with all ICANN requirements, such as registration terms of one to 10 years. 

No

Not Available

No

Valuetainment is committed to protecting geographic names at the second and other levels in the .voting gTLD. 

Valuetainment pledges to

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

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

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

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

Response to Question 23 – Registry Services

Technical operations of the Registry will be outsourced to “TLD-Box Registrydienstleistungen GmbH”, and a signed contract for the provision of those services with TLD-Box exists. A more detailed description of that outsourcing relation is described in response to question 31.

The Registry operating the proposed gTLD will provide the following Registry Services (Services are numbered according to the Questions and Notes in ICANN’s application guidebook):

• (A), (i): “Receipt of data from registrars concerning registration of domain names and name servers”:The interface for receipt of such data (Shared Registry Service – SRS) is fully based on the Extensible Provisioning Protocol (EPP) and conforms to the relevant RFCs (see answer to Question 25). Beyond the standard EPP object mappings and commands, no proprietary EPP extensions are used (unless ICANN requirements necessitate the use of draft level specifications, i.e. for the Trademark Clearing House integration). This Registry Service is operated on a cluster of at least two physically independent servers asan active-active load-balanced groupwhich interactwith a clustered registry database backend (detailed in response to Question 33). Access to that interface is controlled by two-factor authentication mechanisms with one factor being the IP address of the registrar’s EPP clientand the second factor being the registrar’s credentials (username⁄password). Traffic is encrypted with TLS. Access attempts from an IP addresses that is not registered with the Registry Operator are denied. A detailed specification of the EPP interface is contained in answer to Question 25, while the architecture of the EPP frontend is included in response to Question 32. The software used to provide the EPP service is readily available at the time of this writing. The software is based on the EPP software used to provide Registry services for the “.at”, “.no” and “.bh” ccTLDs with the domain lifecycle and periods adapted to the requirements for new gTLDs. The EPP service is available over both IPv4 and IPv6 transport.
• (ii): “Provision to registrars of status information relating to the zone servers for the TLD”: The registry operator will operate an announcement mailing list where updates regarding the operational status of the zone servers of the TLD will be posted. Additionally, registrars can query for the zone server status of an individual domain name under the TLD via the EPP or WHOIS interfaces – both interfaces will contain the relevant EPP status values (refer to the answer toQuestion 27 Registration Life Cycle which lists the domain’s zone server status depending on the domain status).
• (B), (iii): “Dissemination of TLD zone files”:Zone generation and the subsequent DNSSEC signing of that zone is performed in parallel on two physically separate zone generators based on the current data in the registry database. After performing offline checks for the integrity of the zone file, the TLD zone file is loaded onto two hidden master nameservers (the zone file of the second zone generator is only used in case of an emergency situation with the first zone generator). These hidden masters supply the public nameserver network with the current zone file. For zone dissemination the standard DNS mechanisms of NOTIFY and IXFR⁄AXFR, protected by TSIG, are used. Integrity checks are performed to detect errors such as incomplete zone generation,incorrectDNSSEC key usage, key signing keysnot matching DS records in the parent zone oran NSEC⁄NSEC3 chain problem. 

The DNS query based verification procedures include the following set of checkson thepublished KSK and ZSK:

** Check if the published KSK matches a published DS-Record in the parent zone 
** Check if the signature of the SOA and the Zone-NS-Records are included and correct
** Query (with DO-bit set) for 20 predefined existing domain names, check the results and validate the received signatures
** Query (with DO-bit set) for 20 predefined non-existing zonenames, check the results and validate the received signatures
** Query (with DO-bit set) for 20 new (or changed) domains since the last zone generation, check the result and validate the received signatures (the zone generator generates a diff-file with the changes made and the verification tools choose 20 records randomly)
** Query (with DO-bit set) for the predefined end-of-zone-record of the zone, check the results and validate the received signatures. 

Only if these checks succeed is the zone file propagated to the hidden masters – otherwise the rollout of this zonefile is stopped and operations staff are notified.Consistency checks of the loaded zonefile are also performed on the hidden masters. Zone file access as required by ICANN is also provided. These proceduresare the result of practical experience and knowledge gainedfromoperating the “.at” TLD for over 15 years.

• (iv) “Operation of the Registry Zone servers”: The TLD zone servers will consist of a mix of Anycast and Unicast servers in order to ensure high availability in accordance with ICANN SLA requirements and to achieve a high level of diversity in terms of software and IP connectivity. A stable high-performanceDNS network with 100% availability is one of the major key components of a successful gTLD operation. As a result the DNS network is carefully designed to fulfil those requirements. Anycast-DNS with multiple geographic locations is utilized to minimize latency, distribute traffic and increase resilience against attacks. Unicast servers are used to increase diversity across the DNS network. The zone for the TLD will not contain any wildcards or other means to modify NXDOMAIN responses. More details about the DNS network structure is contained in response to Question 35.
• (C), (v) “Dissemination of contact and other information concerning domain name registrations”(WHOIS service):A port-43 WHOIS (and a lightweight alternative) as well as a web-based WHOIS will be provided. In accordance with Specification 4 of the Registry Agreement, the WHOIS serviceis fully compliant with RFC 3912, and provides information about domain names, registrars and nameservers. Free public access to that informationis granted. Web based access is also supported. The service is based on a scalable and redundant architecture to meet the required SLAs. To address privacy considerations, rate limiting on a per-IP-address basis is employed on the WHOIS interfaces. In addition to the WHOIS service, the Registry will also offer a “Domain Availability Service” using the “Finger” protocol as defined in RFC 1288. This service can be used by registrars to check whether a domain name is available or not but does not provide any other information. The implementation is fully RFC compliant. Since finger is a very simple protocol with a minimum of overhead, requests can be processed quickly by the registry systems, which saves on computing resources for both the registry and registrar. The Finger service is a read-only interface and does not pose any security risks for the registry. Instead, providing such an interface (which is functionally identical to the IRIS dchk) offloads pure “availability” checks from the more heavyweight WHOIS and EPP interfaces which helpsto improve the overall performance of those services.
• (D) “Internationalized Domain Names”: The registry will offer IDNs as detailed in the response to Question 44.IDN support in the proposed registry will strictly adhere to all relevant standards. Only labels with explicitly permitted codepoints will be allowed. The registry will be conservative in allowing additional codepointsand will only allow codepoints that do not carry risks such as user confusion or technical issues caused by lack of client support etc.
• (E) “DNS Security Extensions (DNSSEC)”:The registry will perform zone signing activitiesin accordance with ICANN requirements and industry best practice. The respective Delegation Signer (DS) Records will be sent to IANA for inclusion in the root zone to establish a chain of Trust. The EPP interface of the Registry will also accept key material to extend that chain of trust down to individual domain name registrations. Further information about DNSSEC procedures is contained in response to question 43.

Regarding ICANN’s “Consensus Policies”, the Registry will provide the necessary services to comply with these policies (as well as any Temporary Policies as adopted by ICANN). This includes support for ICANN’s UDPR and URS processes. The Registry Operator will also restrict Registrar use of the “Add Grace Period” (AGP) as required by the “Add Grace Period Limits Policy”.

The registry system (software, documentation, test infrastructure) providing the above mentioned Registry Services is readily available at the time of this writing and most of the components are in production use by one or more TLDs.

All registry services are based on well-knownindustry standards and implement RFCs developed by the Internet Engineering Task Force. 

The Registry will not operate any services that are specific or unique to the particular TLD. Hence, it is expected that potential registrars will require only minimal effort to connect to the Registry Systemsto be able to perform registrations of domain names under the TLD.

Registrar Web: Registrars will be provided with a “Registrar Web”, a web site specifically targeted at registrars that will support registration proceduresand allow registrars to change the configuration of their Registry account. This will include administration of their EPP login (particularly their client IP addresses) details, invoice downloads and financial functions such as topping up prepaid credit with the registry. Terms and conditions as well as registry policies are also available for download.Moreover the registrar web page provides statistics to registrars, gives them an overview oftransactions requiring payment and shows available credit.
Registrar Helpdesk: A helpdesk will also be provided for registrars. This helpdesk will handle technical, legal and administrative inquiries from registrars. Helpdesk agents can be reached via email, telephone and fax. A professional ticketing system and qualified agents will ensure that all queries are handled within an appropriate turnaround time. Helpdesk services will be available during working hours on business days and an additional emergency contact will be available 24⁄7. 

Security: The Registry Operator takes significant measures against (1) the unauthorized disclosure, alteration, insertion or destruction of Registry data and (2) the unauthorized access to or disclosure of information or resources on the internet. This includes a detailed security policy (contained in answer to Question 30), a secure architecture (see response to Question 32), a multi-layered backup strategy (details in response to Question 37) and a domain name lifecycle that makes it extremely unlikely that third parties can gain control over the registration record of a domain (see response to Question 27).

Stability:The operation of the TLD and the Registry Services offered do not involve any technology or business practice that has the potential to adversely affect the stability of the TLD’s services and⁄or the DNS as a whole. All protocols used are based on authoritative standards published by well-established and recognized standards organizations. For example, the DNS service provided for the TLD is in strict compliance with the relevant RFCs created by the Internet Engineering Task Force and as a result will be fully compatible withexisting and deployed internet technology. Specifically, the TLD will not engage in any DNS “tricks” such as wildcard or NXDOMAIN redirection and will ensure that no conditions affecting the throughput, response time, consistency or coherence of responses to Internet servers or end systems arise.

In order to fulfill the functions described above, the Registry Backend Operator also performs operations of standard business components, such as:

• Permanent office location infrastructure in two cities (Vienna and Salzburg), including three meeting rooms, with additional emergency office space contracted.
• Rented datacenter space at various locations.
• Billing and Financial administration and infrastructure
• Technical office infrastructure such as IT systems (file storage, email⁄fax systems, document management), call-center enabled PBXes with integrated mobile devices, Teleconferencing equipment, fail-safe networking infrastructure between office locations themselves, and between office anddatacenter locations.

These basic “business building blocks” are established since nearly 15 years, and are used for the day to day operations of the registry backend operations. Since some of the the elements listed above are assumed to be standard business commodities that are not specific to the operations of a gTLD registry, they are not described in further detail in subsequent answers (eg. enterprise PBX). 

A number of the Registry Back-end Operator’s staff are actively engaged in numerous working groups within the Internet Engineering Task Force, particularly thosefocused on DNS, ENUM, emergency services and geographic location. In addition several of these employees are authors of published and draft IETF RFCs.

1 High-level SRS systems description:

The Shared Registry System is based on the Extensible Provisioning Protocol (EPP) and employs a multi-tiered architecture with public facing interfaces completely segregated from backend functions (such as database and management interfaces). An overview of the functionality provided by the SRS is as follows:

• Registrars connect to and authenticate against the EPP frontend systems.
• Those frontends receive and parse all EPP commands to perform checks of business logic (including any policy requirements) and subsequently perform (or reject) the requested action against the back-end data storage.
• The back-end data storage is handled by a Relational Database Management System (described in detail in response to Question 33).

The server elements used for the SRS employ a number of technologies to ensure service availability and reliability. These include the use of multiple, virtualised Linux servers and several layers of high-availability functionality such as active-active load balancing, standby components and replication of full virtual machine images. A significant amount of design and implementation effort has focussed on removing any potential single point of failure in the SRS architecture. This architecture hasalso been fully tested and verified on a functionally identical prototype system, and is operational for the “.bh” migration. Some of that work included training andverification by independent third party system architecture experts, in particular the critical system availability functions such as cluster failover and real-time block device level replication.

The SRSsoftware itself is readily available at the time of this submission. It is implemented and operated in accordance with the requirements ofSpecification 6 („Registry Interoperability and Continuity Specifications“) and the respective SLAs in Specification 10. The SRS uses EPP as its core provisioning protocol and supports, amongst other RFCs, the followingprovisioning RFCs as required in Section 1.2 of Specification 6:

• RFC 5730 (EPP Base Specification)
• RFC 5731 (EPP Domain Name Mapping)
• RFC 5732 (EPP Host Mapping)
• RFC 5733 (EPP Contact Mapping)
• RFC 5734 (EPP TCP Transport). 
• RFC 3735 (EPP Extension Guidelines)
• RFC 5910 (DNSSEC Mapping)
• RFC 3915 (Grace Period Mapping)

For maximum interoperability, only EPP functionality that is documented in the above RFCs is implemented – i.e. there are no proprietary EPP extensions used in the SRS. Further details about the implementation of the EPP Registry Services are contained in response to Question 25 (“EPP”).

It is understood that SRS availability and 100% data integrity are absolute key requirements for the deployment of a successful TLD operation. As a result the SRS implementation was developed with a strong focus on those key factors.

The core software platformemployed by the SRS, with its powerful modular policy functionality has been in production use for the „.at“ ccTLD (nic.at) since 2003, additionally the „.no“ ccTLD (norid) successfully migrated to the registry software over the course of 2010. Another installation of the software was recently rolled out to support the migration of the “.bh” ccTLD (Kingdom of Bahrain) from the incumbent operator to the Regulatory Authority of Bahrain. Furthermore, this core software is currently being used to provide SRS implementations for ENUM (Electronic Numbering) Registries in Austria (+43) and Ireland (+353).Finally, test instances of this customised software for ENUM are deployed in The Netherlands and Australia.

The modular and highly extensible structure of the SRS software allows for customized per-TLD policies that are implemented on top of an identical core registry system. This allows for code reuse between different TLD implementations, regardless of the policy framework required.

The implementation of this software, specifically for this new gTLD, has been customized to the needs of the registry operator and to meet or exceed ICANN’s policy and SLA requirements set out in the Applicant Guidebook for new gTLDs. A detailed description of thearchitecture supporting the SRS software is contained in answer to Question 32 (Architecture). 

Details for the DNS elements of the TLD service, including zone file creation, signing, disseminationand testing procedures are contained in answers to Question 35 (DNS) and answers to Question 43 (DNSSEC). 

Policy and additional documentation about Internationalized Domain Name (IDN) usage in the TLD is contained in answer to Question 44 (IDN). 

The SRS is fully IPv6 compliant: It accepts IPv6 addresses as Glue Records for host objects and isreachable via native IPv6 transport. Additional details about IPv6 support are contained in answer to Question 36 (IPv6). 

For reference, the Performance Specifications relevant to the SRS as required by Specification 10 (Registry Performance Specifications) are included in Table Q24-01. As indicated, the SRS performance meets or exceeds all SLA requirements and significant effort has been taken to verify these SLA requirements on a physical installation of the SRS architecture⁄software. Hence, the performance metrics included in Table Q24-01 are real measurements, rather than theoretical assumptions or estimations.

Note: The performance SLAs have been verified by setting up a prototype system that is functionally and architecturally identical to the registry system, but has limited hardware resources compared to the proposed production architecture. Hence, the performance of the actual production system is expected to exceed the measured performance values on the prototype system indicated in Table Q24-01. Details on the measurements are contained in the responses to Question 33.

Table Q24-01: see attachment

The measurementsused to achieve the individual Service Levels are discussed in the following sections:

1.1 Performance – Shared Registry Service (EPP)

1.1.1 EPP service availability

The EPP interface of the SRS is provided by two front end server processes on two physically separate machines. Both front ends are accessible via a single IP address, and the load is dynamically shared between these two frontends. In the case that a single frontend system is unresponsive, it is automatically removed from the load balanced group. When a frontend returns to service, it is automatically added back into the load balanced group configuration. In addition, alerts to the NOC are triggered for all such events so that the operations team is notified of error conditions immediately.

For security reasons, access to allEPP interfaces is restrictedand is only permittedfrom network ranges of authorized registrars. 

Using this architecture, the SRS for the proposed TLD will exceed ICANN’s „EPP service availability“requirement of 98%. A production implementation of the Registry System (for the “.at” TLD) with similar software & architecture has surpassed 99.6% monthly availability for each month during 2009, 2010 and 2011 (with most months above 99.9% availability). 

1.1.2 EPP command performance notes

The performance of the SRS for EPP session, query and transform commands was extensively evaluated. Please refer to the response to question 33 for the measurements and figures indicating the performance under a realistic base load of the proposed registry system. These figures show that the EPP session, query and transform command RTTsclearly meet the 2000ms and 4000ms thresholds, respectively, for at least 90% of the commands.

1.1.3 Additional Performance figures

The response to Question 33 (Database) contains some additional performance figures for the SRS, again gathered on a prototype system.

2 Network Overview & Number of Servers

The SRS servers make use of the two data center locations “Vienna” and “Salzburg”, (distance approximately 300km⁄185miles). The data centers are equipped with multiple, independent upstream connections to the internet (from different service providers) and two Layer 2 crosslinks. The backend registry operator also operates a Local Internet Registry (LIR), allocates IP space from its own address pool, and operates its own Autonomous Systems (ASes). The high-level network structure is shown in Figure Q-24-02.

As shown, a significant focusof the network design work has been to remove any single point of failure. Also, each server is connected to two access routers, so that an outage of any single network component does not affect server and consequently service availability. More information about the network infrastructure at each individual location is contained in response to Question 35.A complete and detailed overview of machinery in place for this TLD is given in Table Q32-11 of the answer to Question 32.

The server infrastructure of the gTLD’s SRS consists of the following set of machines (this list does not include the actual DNS network):

• Two physically separate, dedicated servers running SRS frontend instances and the production database, clustered in active-active (Frontends) and active-standby (Database) configuration. Database as well as SRS frontends are segregated from each other via virtualization. In terms of scalability, should the TLD exceed 500,000 registered domains, provisions are in place to add further, dedicated machines as needed.
• A total of 6 physical machines provide the additional functions of the gTLD, including zone generation, DNSSEC signing, zone deployment (via Hidden Masters), backup, management, and a test instance of the SRS. The functions on those 6 “infrastructure” machines are shared among up to 4 gTLD installations, and adding more machines is planned depending on growth projections for each individual TLD. The existing infrastructure scales to at least 500,000 domain names per TLD without requiring additional servers. Services on those physical servers are again segregated from each other using virtualization.
• Additionally, several other servers are involved in supplementary functionality, such as monitoring, tape backup, logging & reporting services.

All servers used for the operation of the TLD are (and will be) rack mountable, data center grade machines with active maintenance contracts from the supplier.

2.1 Interconnectivity with other Registry Services

The SRS, as well as the infrastructure required to perform the other critical Registry Services are installed on servers located in the same data center (under emergency conditions, services may be moved to servers in the backup data center). Therefore, the services are inter-connected using either Local Area Networking (LAN) or redundant private layer 2 links (linking the “Vienna” and “Salzburg” locations). In addition to the redundant layer 2 links, infrastructure is in place to securely tunnel traffic between those two locations over the public internet in the unlikely case that both the private site cross-links fail. From a security perspective, multiple firewall layers are used to filter network traffic between the various network segments, i.e. between the public Internet, perimeter and internal networks.

Zone dissemination or transfer from the hidden primary to the public nameserver network is performed over the public internet however all such communications are cryptographically secured. Both locations have redundant upstream connectivity from independent providers with a minimum total bandwidth of 2x1 Gbit⁄s.

Both networks are also connected to the “Vienna Internet Exchange” (VIX), where peering relationships with many other organizations have been established. This provides an optimal routing path to the Registry Systems and services for those organisations.

In terms of data integrity and consistency the following provisions have been put in place to ensure correct synchronization of Registry systems:

• The active and standby database servers are synced in real-time using block device level replication functionality provided by the DRBD technology.
• DNS zone servers are synchronized every 15 minutes.
• For failover purposes, full machine images or snapshots of all virtual machines are copied to the standby data center once per day (please see the response to Question 37 for details)
• Synchronization between SRS and registry helpdesk systems occurs every few minutes.
• It is important to note that as WHOIS data is provided directly from the backend registry database there is no need to synchronize WHOIS data.

The synchronization strategy used differs from service to service. For the SRS frontends themselves, an active-active setup with OSPF-based load-balancing is employed. The registry database uses an active-standby setup with real-time synchronization and automatic failover.

2.2 Resourcing Plan

It should be noted that the architecture and basic development work for the SRS software has already been completed at the time of this submission (except policy adjustments for the TLD), which reduces the time and number of personnel required to perform the necessary development and maintenance work.

The Registry Backend Operator employs 4 developers (totalling to 3 FTEs) responsible for developing and maintaining the SRS software, for example implementing per-TLD policy customisations. Those developers also work on the development and maintenance of RDDS, and their work is shared amongst the operation of multiple TLDs.

Additionally, 2 system engineers (2 FTEs) are responsible for performing the actual deployment of the SRS for a new TLD including the subsequent hand over of the newly installed systems to the Network Operations team.

A minimum of 8 people are fully trained to perform day-to-day and ongoing maintenance operations of the SRS systems and software.

The required hardware for the SRS is described above and all related costs are bundled with the “Software as a Service” fees that the Registry Operator pays to the Registry Backend Operator. This also includes all resources that are required to operate the hardware for the SRS, such as data center or other infrastructure expenses, maintenance contracts and hardware replacement.

1 Overview 

The SRS of this proposed gTLD will use EPP for communication with registrars. The EPP interface is and in full compliance with the following RFCs and, where possible, entirely based on common standards:

• RFC 5730 - Extensible Provisioning Protocol (EPP)
• RFC 5731 - Extensible Provisioning Protocol (EPP) Domain Name Mapping
• RFC 5732 - Extensible Provisioning Protocol (EPP) Host Mapping
• RFC 5733 - Extensible Provisioning Protocol (EPP) Contact Mapping
• RFC 5734 - Extensible Provisioning Protocol (EPP) Transport over TCP
• RFC 5910 - Domain Name System (DNS) Security Extensions Mapping for the Extensible Provisioning Protocol (EPP)
• RFC 3915 - Domain Registry Grace Period Mapping for the Extensible Provisioning Protocol (EPP)
• RFC 3735 - Guidelines for Extending the Extensible Provisioning Protocol (EPP)

Note that the objective is to base the EPP interface entirely onpublished RFCs and it is hence not planned to use any proprietary EPP commands. However, it is understood that some functionality required by ICANN cannot be implemented by means of EPP extensionsspecified in published RFCs. This includes support for:

• Trademark Clearing House: integration in the domain registration process (sunrise and claiming phase)
• IDN: exposure of language tags in the EPP interface
• IDN: selection of variants to be included in the DNS zone

Currently the following documents related to the topics listed above are available:

• draft-tan-epp-launchphase
• draft-obispo-epp-idn
• draft-kong-epp-variants-mapping

The registry backend operator participates in the standardization process and understands that the community is currently working on the respective documents.It is expected that specifications are published and implementable before the registry goes operational, which allows the registry operator to stick to its strategy of using only IETF RFC specified EPP extensions. 

However, if such specifications are not available in a timely manner before the registry intends to go operational, draft specifications that reflect industry and community consensus will be considered instead in order to cover ICANNs functional requirements. 

Via EPP, the following objects can be managed by registrars:

* domain objects
* host objects
* contact objects

The following commands are supported by the EPP interface:

* Session Management
** Login
** Logout
** Poll
** Hello
* Domain Commands
** Check domain
** Info domain
** Create domain
** Delete domain
** Renew domain
** Transfer domain
** Update domain (including “restore”)
* Host commands
** Check host
** Info host
** Create host
** Delete host
** Update host
* Contact commands
** Check contact
** Info contact
** Create contact
** Delete contact
** Update contact

According to the definitions in RFC 5730, the registry operator will apply for an EPP repository identifier with the IANA registry (http:⁄⁄www.iana.org⁄assignments⁄epp-repository-ids) as follows:

ID: #x0056 #x004F #x0054 #x0049 #x004E #x0047
Registrant Contact: Valuetainment AG〈registry@valuetainment.com〉

The only language supported for message elements in EPP is English.

2Session Management

The transportlayerbetween EPP clientsandthe SRS EPP interfaceis
protectedusing TLS with X.509 certificates. The registry will onlyuse
strong ciphers such asthoserequiredbythe EPP RFC andlistedbelow,
but reservestherighttomodifythelistofciphersdepending on
cryptographicdevelopments.

* TLS 1.0 [RFC2246]: TLS_DHE_DSS_WITH_3DES_EDE_CBC_SHA
* TLS 1.1 [RFC4346]: TLS_RSA_WITH_3DES_EDE_CBC_SHA
* TLS 1.2 [RFC5246]: TLS_RSA_WITH_AES_128_CBC_SHA

On top ofthe TLS basedidentityverification, logintotheSRSʹs EPP
interfaceisprotectedusingtwo additional authenticationfactors, with
onefactorbeingthe IP addressoftheclientandtheotherfactorbeing
theclientsʹ credentials. Failedloginattemptsareloggedandreported.
The administrationofauthorised IP addressrangescanbeperformedby
registrars via theRegistrarʹs web interfaceorbycontactingthe
helpdesk. Passwords canbechanged via the EPP logincommandas
described in RFC 5730, Section 2.9.1.1.

EPP sessions will be terminated by the server either after an idle timeout of 20 minutes or after the maximum session length of 24 hours. The registry operator reserves the right to restrict the number of concurrent EPP sessions per registrar (a limit of three sessions is currently defined but this may be amended depending on registry and TLD scaling requirements). 

The EPP service also employs infrastructure elements and software measures to perform rate-limiting of EPP sessions (such measures may, for example, be required during landrush phases).

The SRS does not support EPP command pipelining. 

3Object Management

The registry supports the provisioning of contact, host and domain objects as defined in the respective RFCs and according to the lifecycle described in response to question 27.

Registration periods apply for domain objects only (in one year increments). The default initial registration and renewal period is 1 year. The client may choose another period of up to 10 years when issuing the respective request (total registration period of a domain must never exceed 10 years).

Since the registry uses grace periods, the grace period mapping of RFC 3915 is supported by the EPP interface. In particular, a restore command is issued as an extension to the update command, as described in this RFC. Furthermore, the restore report is also delivered to the registry via EPP.

The registry operator reserves the right to perform a garbage collection process on unlinked contact and unlinked external host objects. Internal hosts follow the lifecycle of their superordinate domain and are not subject to garbage collection (for details refer to responses to question 27, 28).

For contact objects, only internationalized postalInfo elements are supported. All child elements as listed in the RFC are supported. Note that since the registry does not support contact transfers, contact authInfo is not used. 

For the provisioning of DNSSEC trust chains, the EPP interface supports the extension described in RFC 5910 for accepting DS data (key data interface is not supported). Details on DNSSEC support are contained in response to question 43.

4Domain Transfer

The domain transfer command has several subcommands. Note that a transfer can only be requested on domain objects but that the registry system will automatically transfer subordinate host objects when the superordinate domain is transferred. Contact objects are never transferred.

The set of transfer commands consists of the following subcommands: “request”, “approve”, “reject”, “cancel” and “query”. To request a domain transfer, the requestor sends a transfer request with a valid authInfo. The losing registrar is subsequently notified and can either reject or approve this request. In the event that the losing registrar doesn’t explicitly reject or approve the request, the registry will auto-approve the request after 5 calendar days. Before the transfer is approved, auto-approved or rejected, (i.e., the domain is in pendingTransfer state) the requestor may cancel it. A detailed description of the domain transfer lifecycle is contained in response to question 27 (Figure Q27-02).

AuthInfo is required for all domain objects. This information is necessary in order to authenticatea domain transfer process. The registry system requires that the authInfo is at least 8 characters long with a maximum length of 32 characters. Furthermore, at least one alphanumeric character (‘A’ to ‘Z’; both lower and uppercase letters), and at least either one numeric character (‘0’ – ‘9’) or one special character are required for each authInfo.

5Status values

The domain object supports the following status values (as described in Section 5 of RFC 5731):

• inactive (to indicate that no hosts are associated with the object). This status value is set automatically by the server.
• ok(default status) set automatically by the server. This status value is never combined with any other status values.
• pendingTransferis set by the server when the domain name is subject to a pending transfer
• pendingDeleteis set by the server when the domain name is subject to deletion. Note that the registry also supports the RGP grace periods - redemption and pending delete as listed below.
• serverHold⁄clientHold set when the domain object should not appear in the zone.
• serverUpdateProhibited⁄clientUpdateProhibitedset when the domain name cannot be updated due to server or client policy.
• serverTransferProhibited⁄clientTransferProhibitedset when the domain name cannot be transferred due to server or client policy.
• serverDeleteProhibited⁄clientDeleteProhibitedset when the domain name cannot be deleted due to server policy or client provisions.
• serverRenewProhibited⁄clientRenewProhibitedset when the domain name is not eligible for renewal.

Each domain object will always have at least one associated status value.
Additionally, domain objects support the following status values related to the grace period mapping as per RFC 3915, Section 3.1:

• addPeriod
• autoRenewPeriod
• renewPeriod
• transferPeriod
• redemptionPeriod
• pendingRestore
• pendingDelete

The contact object supports the following status values (as described in Section 2.2 of RFC 5733):

• linked(when the object is used in at least one domain name object)
• ok(default status)
• serverUpdateProhibited⁄clientUpdateProhibited(for server or client policy reasons, modifications to the object are not allowed)
• serverDeleteProhibited⁄clientDeleteProhibited(for server or client policy reasons removal of the object from the registry is not allowed)

Each contact object will always have at least one associated status value.

The host object supports the following status values (as described in Section 2.3 of RFC 5732):

• linked: Set by the registry when a host is referenced by at least one domain
• ok(default status)
• pendingTransfer: Set on internal host objects when the superordinate domain is pending transfer.
• serverDeleteProhibited⁄clientDeleteProhibited(for server or client policy reasons removal of the object from the registry is not allowed)
• serverUpdateProhibited⁄clientUpdateProhibited(for server or client policy reasons, modifications to the object are not allowed)

Each host object will always have at least one associated status value.

6EPP Server Implementation

The EPP server implementation is based on the Apache HTTP server, with the HTTP protocol handler replaced with a custom, Perl-based EPP handler. This allows for the reuse of Apache’s session management, logging and resource allocation functionality. EPP systems based on this software have been deployed in production since 2004. The software has been continuously developed, in order to accommodate policy changes and scalability requirements.

The EPP software variant for the proposed TLD is already available and has already been deployed on prototype systems (with the exception of functionality where specifications are unclear at the time of this writing, i.e. Trademark Clearing House integration).

Since no proprietary extensions are planned, no EPP templates and no EPP extension schemas are provided in response to this question. Schemas and examples of the commands supported are included in the respective RFCs.

7Resource Planning

The technical resources required for the operation of the EPP server (as part of the SRS) are described in response to questions 32 and 24. For EPP development and evaluation of related issues, the Registry Back-End Operator has a highly skilled research & development team of 5 persons, of which 3 people are intimately familiar with the details of the EPP protocol. They also monitor and contribute to the discussions within the IETF regarding future developments of EPP (“provreg” mailing list). 

All technical staff are trained on the day-to-day operations of the EPP service. The helpdesk team is trained and experienced in troubleshooting EPP support problems with Registrars, and can escalate to the EPP experts or even core developers in case of more complex problems.

Overview

As detailed in Specification 4 “Specification for Registration Data Publication Services” (RDPS), the Registry Operator will operate a fully compliant “Registration Data Directory Service” (RDDS), will provide “Zone File Access” as required and will grant ICANN the required “Bulk Registration Data Access”. These services will fulfil the requirements stated in the respective specification, and will also meet or exceed the respective RDDS SLAs as required in Specification 10.

In addition to the requisite WHOIS service, a lightweight variant of theRDDS, aso-called “Domain Availability Interface”, based on the “finger” protocol, will be provided. This service will supplement the WHOIS service, and exposes a very limited subset of the information already available via the RDDS, namely, whether or not a certain domain name is available for registration.

1 Registration Data Directory Services

A WHOIS service will be available via port 43 in compliance with RFC3912. Additionally a web-based directory service, to be made available at “whois.nic.voting”, will provide a free, publicly accessible, query-based interface which will provide information regarding “Domain Name”, “Registrar” and “Nameserver” objects. The data format used for those objectsis specified below. It is understood that ICANN reserves the right to require alternative formats and protocols, and upon such specification, such changes will be implemented as soon as reasonably practicable.

Specifically, the WHOIS service fulfils the following requirements:

• The server is fully compliant with RFC 3912
• Free public query-based access is provided
• The services runs on “whois.nic.voting” on TCP port 43
• Data objects represented by key⁄value pairs, with multiple key⁄value pairs with the same key in case of fields with more than one value
• Additionally, web-based access on “whois.nic.voting” is provided
• In order to prevent abuse, highly configurable volume access limitations are deployed
• The architecture is robust, implements a number of failsafe mechanisms and is in compliance with the RDDS SLA’s outlined in Specification 10.

1.1 Architecture

The technical architecture of the WHOISsystem (servers, switches, routers, etc.) is depicted in Figure Q26-02, and employs the following components:

• Connectivity to the internet is handled via the two redundantaccess routers of the registry system. Each server is connected to each of the two routers, with one connection serving as an active path, and the second path (to the other router) serving as a failover path in case of failure of the first.
• Two virtual machines on physically separate hardware run the frontend Whois⁄Finger⁄HTTP daemons.
• The WHOIS service on each server operates as partof an active-active cluster. Both serversannounce their respective service addresses to the routers via OSPF with the routers distributing traffic between the two frontends by means of OSPF load sharing logic. 
• Both active instances are connected to the active registry database using persistent database connections to reduce session handling overhead. The frontend servers switch automatically to the registry standby database in the event of a database failover.
• In the casewhere one of the frontend servers fails, the OSPF announcement for that server automatically ceases and traffic is redirected to the remaining active node within a few seconds.
• Access is restricted to TCP port 43 (for Whois), TCP port 79 (for Finger) and TCP port 80 (HTTP) using firewall access lists on the routers.
• The codebase for the WHOIS and Finger servers was developed in-houseusing the “C” programming language and is based on state-of-the art design concepts to ensure a robust and stable operation. Thissoftware hasbeen actively developed for a number of years and is currently inproductionat the “.at” and “.no” TLD registries.
• The software is also highly configurable, allowing query limits to be set based onsource IP address⁄blocks forbothIPv6and IPv4 addressing formats. It also allows for fine grained control of specificrate-limits on a pernetwork block basis.
• The software actively generatesaccess and service statistics for monitoring and management purposes.
• The RDDS uses the “live” registry database and as a result updates to the registry database are reflected in real-time to the WHOIS server. However, in the event that the WHOIS load starts to impact the performance of the Registry database, provisions are in placeto move the WHOIS server to an alternate read-only replica of the “live” database if necessary.

1.2 Access Limitations and Access Restrictions

Access control lists (ACLs) protect the RDDSservice hosts against unwanted access but grant public access to the defined services (WHOIS, finger, HTTP). 

In addition to this general protection of the service infrastructure, the RDDS must also make provision to address the following scenarios:

• Bulk requests from public unknown sources (e.g. to grab data)
• High speed ⁄ high volume requests from known source addresses(e.g. from registrars)

In order to handle the above scenarios the WHOIS software supports the following configurable service policies:

• The number of allowed requests (within a specific time frame) on a per IP address (or per IP subnet) basis, for either IPv4 or IPv6 and with support for a “most specific” matching rule of those entries. This provides the ability to set different limitations for different user groups ⁄ network ranges. Violations of those limits are included in the daily WHOIS service reports sent to the operations team.

1.3 WHOIS Input Format

Thedata format complies with the requirements of Specification 4 of the “new gTLD agreement”. The definitions belowapply to the command line WHOIS interface (port 43) as well as the web interface:

• Queries can be issued for domain name, registrar and nameserver objects
• Queries that include the argument “registrar” trigger a search for registrar data objects. If the argument is “nameserver”, a search for nameserver objects is actioned, while queries without any such prefix trigger a search for a domain or nameserver.
• Wildcard searches and substring searches are not supported.
• Using the option “-C” (“charset”) as part of the command line WHOIS query specifies a character encodingfor the protocol. This setting applies to the both the input and output character encoding, and supports the following values: “US-ASCII”, “ISO-8859-1” and “UTF-8”. The default character set is “UTF-8”. On the web interface the character encoding will always be set to UTF-8 with modification of this option not available.
• In the case of IDNs, the search string must be in the A-Label format of the domain or nameserver. Searches based on the U-Label format are not supported.

Example queries (including the command line “whois” client itself):

• Domain name data: whois-h whois.nic.〈TLD〉 example.tld
• Domain name data (with character set parameter): whois-h whois.nic.〈TLD〉 -- -C us-asciiexample.tld
• Registrar data: whois-h whois.nic.〈TLD〉“registrar Example Company”
• Nameserver data by name: whois-h whois.nic.〈TLD〉 ns1.example.tld
• Nameserver data by IP address: whois-h whois.nic.〈TLD〉 “nameserver 10.0.0.10”

Note: In the case where a host is registered for the origin of a delegated domain, i.e. both domain “example.〈TLD〉” and nameserver “example.〈TLD〉” exist, the query will match and return both the domain name and nameserver data objects.

1.4 WHOIS Output Format

The output format of the WHOIS server follows thatoutlinedin Specification 4 of the “new gTLD agreement”:

Domain Name Data: 

Domain ID: D1234567-TLD 
Domain Name: EXAMPLE.TLD 
Updated Date: 2009-05-29T20:13:00Z 
Creation Date: 2000-10-08T00:45:00Z 
Registry Expiry Date: 2010-10-08T00:44:59Z 
Sponsoring Registrar: EXAMPLE REGISTRAR LLC 
Sponsoring Registrar IANA ID: 5555555
Domain Status: clientDeleteProhibited
Domain Status: clientRenewProhibited
Domain Status: clientTransferProhibited
Domain Status: serverUpdateProhibited
Registrant ID: 5372808-GTLD
Registrant Name: EXAMPLE REGISTRANT 
Registrant Organization: EXAMPLE ORGANIZATION 
Registrant Street: 123 EXAMPLE STREET 
Registrant City: ANYTOWN 
Registrant State⁄Province: AP
Registrant Postal Code: A1A1A1 
Registrant Country: EX
Registrant Phone: +1.5555551212 
Registrant Phone Ext: 1234 
Registrant Fax: +1.5555551213 
Registrant Fax Ext: 4321 
Registrant Email: EMAIL@EXAMPLE.TLD 
Admin ID: 5372809-GTLD
Admin Name: EXAMPLE REGISTRANT ADMINISTRATIVE 
Admin Organization: EXAMPLE REGISTRANT ORGANIZATION 
Admin Street: 123 EXAMPLE STREET 
Admin City: ANYTOWN 
Admin State⁄Province: AP
Admin Postal Code: A1A1A1 
Admin Country: EX 
Admin Phone: +1.5555551212 
Admin Phone Ext: 1234 
Admin Fax: +1.5555551213 
Admin Fax Ext: 
Admin Email: EMAIL@EXAMPLE.TLD 
Tech ID: 5372811-GTLD
Tech Name: EXAMPLE REGISTRAR TECHNICAL 
Tech Organization: EXAMPLE REGISTRAR LLC 
Tech Street: 123 EXAMPLE STREET 
Tech City: ANYTOWN 
Tech State⁄Province: AP
Tech Postal Code: A1A1A1 
Tech Country: EX 
Tech Phone: +1.1235551234 
Tech Phone Ext: 1234 
Tech Fax: +1.5555551213 
Tech Fax Ext: 93 
Tech Email: EMAIL@EXAMPLE.TLD 
Name Server: NS01.EXAMPLEREGISTRAR.TLD 
Name Server: NS02.EXAMPLEREGISTRAR.TLD 
DNSSEC:Signed
DS Key Tag 1:54135
Algorithm 1: 5
Digest Type 1: 1
Digest 1: 〈DIGEST〉
DS Key Tag 2: 54135
Algorithm 2: 5
Digest Type 2: 2
Digest 2:〈DIGEST〉

% Copyright (c) 20XX by NIC.〈TLD〉
% Restricted rights.
% Response generated on: 2011-10-13 11:11:25 UTC

Note that the “Domain Name” field will always contain the A-Label format of the domain. In cases where an IDN response is returned (and an appropriate character encoding was requested), the response will contain an additional field,the so-called “Domain U-Label”, containing the U-Label format of the respective Domain, for example:

Domain U-Label: exämple.〈TLD〉

In the case where data for an unsigned domain is returned, the “DNSSEC” field will contain the value “unsigned” and the other DNSSEC-related fields will be excluded from the response.

Registrar Data: 

Registrar Name: Example Registrar, Inc. 
Street: 1234 Admiralty Way 
City: Marina del Rey 
State⁄Province: CA
Postal Code: 90292 
Country: US 
Phone Number: +1.3105551212 
Fax Number: +1.3105551213
Email: registrar@example.tld 
Registrar IANA ID: 55566677

% Copyright (c) 20XX by NIC.〈TLD〉
% Restricted rights.
% Response generated on: 2011-10-13 11:11:25 UTC

Nameserver Data:

Server Name: NS1.EXAMPLE.TLD
IP Address: 192.0.2.123 
IP Address: 2001:0DB8::1
Registrar: Example Registrar, Inc.
Registrar IANA ID: 55566677

% Copyright (c) 20XX by NIC.〈TLD〉
% Restricted rights.
% Response generated on: 2011-10-13 11:11:25 UTC

1.5 Web-based RDDS

In addition to the command line based WHOIS service described above, the Registry Operator will, in line with requirements, provide a web-based WHOIS interface. The web-based interface supports the following classes of users in accordancewith stated policies:

• The general public (“anonymous access”):Anonymous users can retrieve a limited amount of responses from the web based interface. To avoid unwanted bulk access and to prevent users from data harvesting the following access restrictions are deployed:
• Valuetainment will not allow wild card searches.
• Valuetainment will throttle requesting parties if the number of queries exceeds a limit to be defined.
• Specific IP addresses from which requests originate can be blocked temporarily or permanently.
• Valuetainment will use Completely Automatic Public Turing Test to Tell Computers and Humans Apart (CPTCHA) requiring manual interaction to prevent automated data mining .
• Registrars and other authenticated users:Registrars and other approved users are issued withan authentication token that allows them to retrieve a greater number of WHOIS records via the web interface. 

All transactions on the web-based WHOIS are also logged and daily usage reportsare sent to operations staff. The web-based WHOIS supports the same object types and query formats as the command line interface above, with the exception of the „-C“ (character set) switch. The contents of a response from the web-based WHOIS service arealso identical to the command line service, but may be reformatted and styled using HTML⁄CSS to aid presentation and display.

1.6 Searchable WHOIS

Searchable WHOIS functionality is not provided. This is to prevent bulk data harvesting and further data merging using extensive request combinations and Booleansearch techniques. This is done intentionally to comply with data protection laws and privacy obligations.

Any request from legal institutionsand law enforcement agenciesfor information outside of that supplied by any of the WHOIS services is dealt with directly by the legal department of the registry.

As a result there is no future intention to offer a broad search functionality, this applies to both the WHOISprotocol interface (port 43)and the web-based WHOIS interface

1.7 Lightweight RDDS Access (“Finger”)

In addition to the required WHOIS interface a lightweight domain availability interface is supported. This interface is based on the “Finger” protocol, specified in RFC 1288, and exposes a very limited subset of data (already available in WHOIS), namely whether or not a certain domain name is available for registration. It provides faster response times than the standard WHOIS interface and places less load on the registry systems. The service will be operated accordingly:

• Lightweight access based on the “finger” protocol according to RFC 1288
• Lightweight access runs on finger.nic.〈TLD〉 on port 79
• No exposure of any information additional to that already available via the WHOIS RDDS
• Query format (command line example): “finger example.〈tld〉@finger.nic.〈tld〉”
• Response format (example): “example.〈TLD〉 IS NOT available”

1.8 IPv6 Support

All RDDS services (WHOIS, web-based WHOIS, Finger and bulk data access) fully support IPv6. In summary there is no difference in service quality levels or service responses between IPv4 and IPv6 for these services.

A detailed description of IPv6 support can be found in response to Question 36.

1.9 Service Level Compliance

The RDDS service complies with the SLA requirements (as defined in Specification 10) as follows:
Table Q26-01: please see attachment

1.1.1 RDDS Availability

The redundant and resilient architecture of the WHOIS system is described above, and is served by architecture as outlined in response to question 32. It is designed, at a minimum, to meet the required availability levels of 98%. It is understood that a reliable RDDS system is vitally important for TLD operations.

1.1.2 RDDS query RTT

The internal response time of the WHOIS system is significantly below the RDDS query RTT limit of 2000 ms so that it can be expected that for 95% of the queries this SLA requirement will be met. On test installations of the service, the query RTT is less than 500 ms, even in the event of a significant number of concurrent connections.

1.1.3 RDDS update time

Since the WHOIS system queries the “live” registry database, there is no update delay and hence the RDDS update time of 60 minutes for 95% of the updates can be assured. 

2 Zone File Access

In accordance with Section 2 of Specification 4 of the Agreement („Zone File Access“), the Registry Operator will enter into an agreement with any internet user to provide access to download the zone file data and will cooperate as required with Centralized Zone Data Access (CZDA) Providers. This will be facilitated as follows:

• A dedicated FTP server will be set up for access to the zone file data. The name of that server will be: 〈TLD〉.zda.icann.org (pending allocation of that hostname by ICANN zone administrators). The zone file and associated checksum files will be available for download for the previous 3 days. Files will be generated once a day and named according to Section 2.1.3 of the Agreement.
• The file format follows exactly the specification which is based on the Master Zone File format defined in RFC 1035, according to Section 2.1.4 of the agreement.
• A specific user ID and password has to be assigned for each user to restrict access to accredited users and to prevent unauthorized access. This user has to access the server with this specific user ID to be able to transfer data.
• Access will be free of charge but limited to one download per day.
• All logins and data transfers are logged, monitored and reported. Access statistics will be available to the registry operator as well astoothersif required.

The Registry Operator will also cooperate with ICANN and CZDA Providers as required in Section 2.2 of the agreement. Additional access is granted to ICANN itself (or its designee) and any designated Emergency Operatorif required.

3 Bulk Registration Data Access

As an operator of a Thick Registry, the Registry Operator will operate in compliance with Section 3.2 of Specification 4 of the „new gTLD Agreement“ („Exceptional Access to Thick Registration Data“) as well as in compliance with Section 3.1 of Specification 4 („Periodic Access to Thin Registration Data“), and will provide ICANN with the required data in the required format. 

The data will be provided in conformance with Specification 2 („Escrow“) of the Agreement, as required.

4 Resources

Regarding development of the RDDS interfaces, it shall be noted that most of the work is already complete at the time of this writing (eg. WHOIS and finger daemon are fully deployed and operational for other TLDs). Therefore, only minimal development work is required, and hence within TLD-Box’s development team, only a half FTE is necessary (and planned for) for the continuous adaption and maintenance of the RDDS software itself.

For the actual operation of the RDDS interfaces, all technical operations staff members are trained on the various infrastructure and software components of the system, and manpower resources are accounted for in the general Network Operations Center budget.

The research & development team of the Registry Backend Operator is aware of ICANN’s SSAC work regarding WHOIS (eg. http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac051.pdf), and also participates in the IETF’s proposed “WEIRDS” working group, in order to stay up-to-date with developments in the fields of domain data related publication services.

The RDDS makes use of virtual machines on the hardware provisioned for the TLD (and described in responses to Question 32 and 24). Therefore, no additional hardware resources are needed, however, the required bandwith in order to provide the RDDS services are accounted for in the general network topology of the Registry System.

1 Introduction

The domain registration lifecycleof .voting follows ICANNs “Life Cycle of a Typical gTLD Domain Name” (http:⁄⁄www.icann.org⁄en⁄registrars⁄gtld-lifecycle.htm). By using this standardmodellifecycle, Registrars have only minimal effort in order to become familiar with the registration procedures under the proposed TLD. Figure Q27-01 shows the lifecycle of a domain with the various states. The description below lists EPP status values, DNS status, and typical allowed transactions for each of the domain states. It also describes whether Whois information is available and what information is provided in a finger request (note: for reasons of clarity the transfer process is shown in a separate figure).

Since the registry system supports the Redemption Grace Period (RGP) extensions as specified in RFC 3915, the domain states ‘REDEMPTION’ and ‘PENDING DELETE’ refer to the respective RGP states.

2 Typical Lifecycle of a Registration

A typical domain lifecycle is initiated by a create domain EPP command for an AVAILABLE name. Thedomain is now in a‘REGISTERED’ state. Whilst in this state the information associated witha domain may be updated by the respective registrar (using the update domain command). A domain may also be transferred to another registrar (domain transfer, see detailed state diagram below). A domain is always registeredfor a specific period (maximum 10 years). At any time Registrars can manually renew domains (given that the maximum registration period is not exceeded).The registry system is also supportingan auto-renew option. The auto-renew option can be deactivated on the request of a Registrar (on a per-Registrar basis), but is enabled by defaultto ensure that domains do not expire unintentionally.

When a domain is deleted by either the ‘delete domain’ command, or alternatively expires (not manually renewed and auto-renew disabled for the registrar), the domain first enters the ‘REDEMPTION’ state. Whilst in this state, a registrar is allowed to restore domains for the respective domain holder in case the non-renewal was unintentional. When the domain is successfully restored while in the REDEMPTION state (a restore report via EPP is required), the domain enters the ‘REGISTERED’ state again. Domains which are not restored after 30 days in the‘REDEMPTION’ state enter the ‘PENDING DELETE’ state. Whilst in this state, a domain cannot be restored and will become AVAILABLE for re-registration after a period of 5 days.

Note that domains do not enter the‘REDEMPTION’ state when they are deleted within the add grace period. Instead, such a domain is immediately deleted and AVAILABLE for re-registration. 

Furthermore, additional EPP status values set on a domainmay affect the allowedtransactions (operations), e.g. status values of serverUpdateProhibited or clientUpdateProhibited, serverTransferProhibited or clientTransferProhibited, serverDeleteProhibited or clientDeleteProhibited and serverRenewProhibited or clientRenewProhibited will prohibit the respective transaction. Such server states are for example used when a domain is LOCKED.

To discourage and to address problems with abusive registrations, the proposed registry will follow policies described in response to question 28.
For domains under dispute, the registry will use the LOCKED status, and will also set appropriate status values on the associated host and contact objects, as required by the specific dispute scenario (e.g. URS).

3 Domain States and Properties

This section describes the individual Domain States, as outlined in figure Q27-01. For each of these states, it is described what the trigger points to reach the status are, whether the domain is included in DNS, which transactions are allowed on the object, whether WHOIS information is available, and what the boolean response for the lightweight RDDS interface (finger) is. Furthermore the EPP (base and RGP) status values set on the domain are listed.

Note that in addition to the commands listed below “check domain” is always possible and the commands “info domain”and “transfer query” are always allowed on existing domain objects, regardless of their status.

Also note that in addition to the EPP status values listed below, the value “inactive” is set for domains without associated host objects.

AVAILABLE: 

Trigger points: Initial status of “new” domains, final deletion of a “PENDING DELETE” domain, deletion of a domain during Add Grace Period.
in DNS: No
Allowed Transactions: create domain
in WHOIS: No
Finger results: “available”
EPP status values: n⁄a

REGISTERED:

Trigger points: “create domain” command, Restore Report received, disputes resolved
in DNS: Yes(*)
Allowed Transactions: update domain, transfer domain (request), delete domain, renew domain
in WHOIS: Yes
Finger results: “unavailable”
EPP status values: serverTransferProhibited (during first 60 days), ok (after the first 60 days if not inactive and no other status value is set)

REDEMPTION:

Trigger points: “delete domain” command, domain expiration, disputes resolved, restore report not received.
in DNS: No
Allowed transactions: restore domain
in WHOIS: Yes
Finger result: “unavailable”
EPP Status values: pendingDelete, serverUpdateProhibited, serverHold, serverTransferProhibited, serverRenewProhibited, rgp:redemptionPeriod

PENDING DELETE:

Trigger points: domain not restored, delete locked domain
in DNS: no
Allowed Transactions: none
in WHOIS: Yes
Finger result: “unavailable”
EPP Status values: pendingDelete, serverUpdateProhibited, serverHold, serverTransferProhibited, serverRenewProhibited, rgp:pendingDelete

PENDING RESTORE:

Trigger points: “restore domain” command, dispute resolved
in DNS: Yes(*)
Allowed transactions: update domain (including delivery of the restore report), delete domain, renew domain. 
in WHOIS: Yes
Finger result: “unavailable”
EPP status values: pendingDelete, serverTransferProhibited, rgp:pendingRestore

LOCKED:

Trigger points: Opening of a dispute over the domain name
in DNS: Yes(**)
Allowed transactions: renew domain
in WHOIS: Yes
Finger result: “unavailable”
EPP status values:serverUpdateProhibited, serverDeleteProhibited, serverTransferProhibited, (serverHold**)

(*)Note: Domain is only included in the DNS if the domain object is linked to host object(s), and neither serverHold nor clientHold are set on the domain object.
(**)Note: Depending on the individual dispute case, the Registry may be instructed to set the serverHold flag on the domain, and subsequently, the name would be excluded from the DNS.

The EPP status values pendingCreate, pendingRenew and pendingUpdate are never set on domain objects since there is no human review or third-party action necessary to complete these actions.

4 Transfers

The transfer lifecycle of the proposed gTLDs complies with ICANNs “Policy on Transfer of Registrations between Registrars” (http:⁄⁄www.icann.org⁄en⁄transfers⁄policy-12jul04.htm), specifically to its Section 6 (Registry Requirements). The lifecycle is illustrated in Figure Q27-02.

A transfer request must have valid ‘authInfo’ in order to be successful. Note that only one transfer request for a domain can be pending at any one time. Transfer requests for a domain name object that is already in the “pending Transfer” state are hence rejected.

Additionally, only domains that have been registered for more than 60 days (counted from the date of the initial registration) can betransferred.

Pending transfers can be either approved or rejected by the currently sponsoring Registrar. After a period of 5 days, any un-actioned requests are auto-approved by the Registry. Pending transfers may also be cancelled by the requesting registrar.

In the “pending Transfer” state, the following transactions on a domain name are not allowed:

• transfer (op=request)
• delete

(update, renew, and all other transfer sub-commands are allowed). All EPP commands are specified in RFC 5731.

A successful transfer extends the validity period of the transferred domain. The default validity period extension is 1 year but clients may request longer periods in the “transfer op=request” command), between one and 10 years(whole years only; as always, the maximum registration period is capped at 10 years).

5 Host Objects

The lifecycle of host objects is contained in the response to this question because internal host objects can be affected by transactions on their respective superordinate domain (parent domain). They “follow” the status of their parent domain in order to avoid issues with stale glue records.

Figure Q27-03 shows the lifecycle of internal host objects (comprised of a domain name in the .TLD namespace), and Figure Q27-04 shows the simpler lifecycle of an external host object (comprised of a domain name outside the of .TLD namespace). In Figure Q27-03, bold solid lines indicate states and transactions created by transactions on the host object itself, while dotted lines indicate effects on the internal host object that are created indirectly by transactions⁄states on the superordinate domain of the host object.

Internal host objects can only be created when the superordinate domain exists.
When the superordinate domain is deleted within the create grace period, the internal subordinate host is also immediately released.

The description of the individual states of the Host objects is as follows:

• AVAILABLE: The host object does not exist in the Registry, and can be created using the “create host” EPP command.
• REGISTERED: The host object exists, and can be used in domain names in order to refer to the domain name’s nameserver.

Internal hosts additionally follow the states of their respective superordinate domain as follows (Status values in the list below refer to the status of that domain):

• REGISTERED (PENDING TRANSFER): The host object will be transferred together with the superordinate domain (in case the transfer is completed successfully).
• REDEMPTION: For the redemption period of the superordinate domain, the host object glue will continue to be included in the TLD, even if the superordinate domain is not included in the zone anymore.
• PENDING DELETE: The glue record will not be included in the DNS anymore. On final deletion of the host object, all references to this host object will be removed too.

More information regarding this process in order to avoid stale glue records is included in response to Question 28 (Abuse Prevention and Mitigation).

6 Grace Periods

The following grace periods are supported for domains:

• add grace period: the add grace period lasts 5 calendar days from the date of initial registration. When a domain is deleted in this period, it is immediately deleted and available for re-registration. The registrar is credited for an amount corresponding to the registration fee (unless the registrar is already over its monthly allowance of add grace transactions). A ‘renew’ command ends the add grace period. Note that it is impossible to perform a domain transfer in the add grace period (in fact, the first transfer is only allowed after 60 days of registration). To prevent misuse and domain tasting in particular, a policy applies as to the number of delete requests per month that are refunded during the add grace period (see below). Deletions in the add grace period exceeding this limit are not refunded. 
• transfer grace period: the transfer grace period is currently 5 calendar days following a successfully completed domain transfer. If a domain is deleted in this timeframe, the sponsoring registrar is credited for the amount billed during the domain transfer. The transfer grace period is terminated when a restore, renew or subsequentdomain transfer is performed. 
• renew grace period: after each renew command, a 5 calendar day long renew grace period starts. When the domain is deleted in this timeframe, the registrar is credited for the corresponding fee and the domain enters REDEMPTION. A deletion, restoration orapproved transfer of a domain immediately ends the renew grace period. 
• auto-renew grace period: every auto-renew is followed by an auto-renew grace period (45 calendar days). If a domain is deleted or transferred within this period the fee for the renewal is refunded to the registrar. However, when a renew command is performed there is no grace period credit any more. 

Refunds for deleting domains during an add grace period will follow ICANN’s Add Grace Period Limits Policy, available at: http:⁄⁄www.icann.org⁄en⁄tlds⁄agp-policy-17dec08-en.htm (including implementation notes). 

The registry system supports the following pending periods in which certain operations are not allowed:

• Redemption Grace Period: consisting of
** Redemption Period: Whilst in this 30 day period, a domain can be restored after a deletion action (only if domain is not within the add grace period) 
** Pending Restore: in order to successfully restore a domain in the redemption period, a restore report is required. This report has to be submitted within 7 days of this pending restore period. If no restore report is submitted, a new 30 day long redemption period begins. 
** Pending Delete: If a domain is deleted and not restored, it is placedintothe pending delete period following the redemption period. After 5 days in this period, the domain is finally available for re-registration. 
• Pending Transfer Period: lasts for a maximum of 5 days after the initial transfer request command. The losing registrar has 5 days to approve or reject the request. The requestor may also cancel the transfer within this period. If no action is taken by the losing or gaining registrar, the registry auto-approves the transfer.

This registration lifecycle matches the business model of the proposed gTLD. The proposed registry software fully supports thislifecycle and the technical resources needed to run a registry based on the lifecycle as described are readily available.

7 Resourcing

Three staff members of TLD-Box (the Registry Back-End Operator of the proposed gTLD) are experts in domain name life cycle, and have designed life cycles for the “.at”, “.bh” TLD, as well as consulted some other TLDs on their domain life cycle. 
All other technical staff members as well as support staff are trained on the operational aspects of the Domain Name Lifecycle. 

There are only minor staff and⁄or infrastructure resources needed for the day to day operations in relation to the domain lifecycle itself (since once developed, the resources to run the lifecycle come from resources operating the EPP servers). In terms of ongoing maintenance, it is expected that about 5 person days per year are required in order to clarify details, corner cases and relations to other business processes of the registry. Those 5 person days are budgeted for in the general maintenance time & resource budget of the registry.

1. Overview

Valuetainment is not blind to the fact that in theory certain abuse scenarios and activities are thinkable and therefore several measures to prevent and to mitigate abuse will be deployed. In particular Valuetainment will implement the following policies upon the launch of the new .VOTINGgTLD, which will also be made available prominently on the Valuetainment’s website:

• .VOTING Domain Name Policy (DNP)
• .VOTING Abuse Reporting and Takedown Policy (ARTP)

2. General Provisions against Abuse under .VOTING
2.1 Legal Safeguards
All policies will be made binding for all registrants by contractually obligating sponsoring registrars through the Registry-Registrar Agreement (RRA) to pass on the above mentioned policies as part of their registration agreements.
These abuse protection mechanisms will described in the following.

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

The DNP will clearly state, that the registrant will enter into a direct agreement with Valuetainmentapplying for and registering a .VOTING domain name giving the registry the right to reject an application for a .VOTING domain name and⁄or to delete or cancel a .VOTING domain name registration directly. 

Abusive activities during the operation of the .VOTINGgTLD registry system will be categorized as follows:

• Abusive registrations of names under the .VOTINGgTLD.
• Abusive use of a domain name under that TLD („Malicious Use“)
• Abuse of the registration processes, the technical interfaces, infrastructure of the Registry systems and the DNS network itself.

With respect to the first (and also parts of the second) category, ICANN’s “RAP” WG (Registration Abuse Policies Working Group) has produced an illustrative categorization of known abuses in their “Registration Abuse Policies Working Group Final Report” (http:⁄⁄gnso.icann.org⁄issues⁄rap⁄rap-wg-final-report-29may10-en.pdf, dated 29 May 2010). The anti-abuse measures of the proposed gTLD registry largely follow the RAPs recommendations for the individual abuse scenarios. More details on the individual countermeasures are included below.

Furthermore, the proposed registry also takes into considerationthe ICANN Security and Stability Advisory Committee’s document “SAC 048” (“SSAC Comment on Orphan Glue Records in the Draft Applicant Guidebook”) as well as “SAC 023” (“Is the WHOIS Service a Source for email Addresses for Spammers?”).
2.2 WHOIS Accuracy Measures
Valuetainment understands that WHOIS accuracy is of prime importance to keep the .VOTINGS namespace safe and to gain the public’s trust for the namespace. 

As .VOTINGgTLDs will principally be available to the general public without pre-validation prodecures, Valuetainment is well aware of the fact that strict and enforceable mechanisms are needed to keep the WHOIS accurate at all times. 

As described in the answer to Question 26, WHOIS records for .VOTING will be provided as a so called “thick” WHOIS. All relevant information and data of a .VOTING registration will be stored in a general location.All sponsoring registrars will need to agree to RRA provisions making them responsible to provide current, accurate and complete information from the respective registrars. 

The .VOTINGregistry operator will be responsible for monitoring such information and records to ensure that registrars are complying with the contractual agreements to provide accurate and complete data. Incomplete and⁄or blatantly inaccurate data will result in a notification send to the respective sponsoring registrars who has submitted the inaccurate data. Registrar or registrant are required to respond to such inquiries regarding the accuracy of the Whois data within 30 days. Sponsoring registrars unable to verify the accuracy of the Whois data or fail to receive such missing information from the registrant within thirty (30) days are obliged to delete the name at the end of the thirty-day period. 

Valuetainmentwill grant such .VOTING domain names a redemption grace period during which the registrant may only re-activate the domain name upon verification of the accuracy of its Whois data. Should the registrant fail to do so, the .VOTING domain name will be made available for public registration. It will however be possible for Valuetainment and⁄or a sponsoring registrar to suspend or delete a domain name in less than 30 days, should the circumstances require such actions (i.e. sponsoring registrars and⁄or registrants who fraudulently submitted Whois data.).

Third parties will be able to report Whois inaccuracies by using the abuse point of contact described below in detail. Such reports will, after they have been validated by Valuetainment’s abuse team, result in the procedure describe above. 

Additionally , ICANN’s WHOIS Data Problem Reporting System (WDPRS) will be available to anyone wishing to file a complaint regarding the accuracy or sufficiency of WHOIS records within .VOTINGgTLDs.

3. Abuse Contact and Abuse Handling Provisions

The .VOTING registry operator will establish and publish a single abuse point of contact on its website. This contact is responsible for addressing matters requiring expedited attention and for providing a timely response to abuse complaints concerning all names registered in the .VOTING, through all registrars of record, including those involving a reseller.

The whole procedure will be governed by the .VOTING Abuse Reporting and Takedown Policy (ARTP). The “ARTP” will provide third parties affected or believing they are affected by illegal .VOTING use with a transparent and structured route which the complaint procedure follows.

The key points of are:

• The complaints procedure is open to any user;
• Users must give at least one email address where they can be notified of the status of the complaint procedure;
• Depending on which abuse variant they select, users are obliged to supply certain additional information; there is also the option to upload e.g. screenshots or other files for the purposes of evidence;
• If the predefined abuse forms do not fit, users can enter their own information which must meet certain minimum standards for length (to prevent abuse of the form);
• Users must state in every case for which .VOTING domain names a complaint is being submitted;
• Users must finally declare in every case that all the information submitted is true; the form is secured by a CAPTCHA query.

The abuse point-of-contact will be responsive and effective, tasked with answering email quickly, empowered to take effective action, and guided by well-defined written criteria. After sending the web form the user will be provided in all cases with an automatically generated email containing an tracking or case number. 

As standard practice, the .VOTING registry operator will forward all credible and actionable reports to the legal team at Schollmeyer&RickertRechtsanwaltsgesellschaftmbH (www.anwaelte.de), a law firm which will ensure that the abuse point-of-contact has broad familiarity with current industry knowledge and a high-level awareness of evolving online security risks. The responsible partner is Attorney at law Thomas Rickert, who has considerable expertise in this area. Thomas Rickert has been the manager of a hotline taking complaints about illegal content and conduct on the Internet operated by eco Verband der deutschenInternetwirtschafte.V. (www.eco.de) for several years. In addition to that he has been in the project managment of a tip line operated by eco and FreiwilligeSelbstkontrolleMutimediadienstee.V. (see www.internet-beschwerdestelle.de). Further, he was President of the Inhope Association (www.inhope.org), an international network of such hotlines, who co-operate with Law Enforcement, Internet Service Providers, Governments and NGOs to provide for efficient counter measures against the downside issues on the Internet, in particular child abusive material. 

Thomas Rickert has also been advising registrars and working on domain disputes for 14 years and is a well-known expert in this area. Thomas Rickert has also been in the project management of the Spotspam project, a pilot project financially supported by the European Commission aiming at the facilitation of international co-operation in the fight against unsolicited electronic communication. He was also project manager of the ICRAdeutschlandindustry consortium which aimed at promoting user autonomous filtering systems to protect minors from being exposed to harmful content online.
The law firm has seven attorneys so that an efficient abuse management can be granted even if the volume of complaints should be high at times. 

After receiving the report, the law firm will determine the appropriate actions and notify the respective sponsoring registrar with a recommendation on what action should be taken. The recommendation also states the type of infringement and the legal basis of the sanction, such as the applicable terms of use, ICANN policies, applicable laws or the DNP. 

The standard procedure will be:

• the registrant will receive the complaint by email and is obliged to process and reply to all correspondence forwarded by the abuse contact ⁄ the registrar without delay, and at least within 48 hours, 
 unless a third party has set a shorter period or there is other specific need for speed;
• with the response, the registrant must state whether he wishes cure the alleged breach or to defend against the third party allegation;
• a matter is settled when the registrant evidences to have cured the breach within the deadline given; 
• should a registrant fail to respond to the request of the abuse contact ⁄ the registrar in time, the following procedures (but are not limited to) to stop malicious shall apply:
o locking the domain and putting it on hold in order to prevent changes to the domain and to remove it from the .VOTING name space,
o deleting the domain name and blocking it from further registration to prevent future abuse.

Reports and requests from competent authorities, law enforcement and⁄or courts receive top priority. These parties will receive priority contact options to ensure quick and proper reactions. Such requests will be handled and resolved by Valuetainment’s abuse team without delay, the latest within 24 hrs. 

Escalation rules (defining which steps are to be taken in which order and conditions for moving on to the next, more drastic measure) are part of the policy. In all cases Valuetainment reserves the right to act directly and immediately in cases of obvious and significant malicious conduct. Should Valuetainment (or the sponsoring registrar) decide to suspend a specific domain name the suspension request will be fulfilled as described below. 

The ARTP will be announced to sponsoring registrars and to registrants and will be part of the Registry-Registrar Agreement (RRA) and the DNP.


4. Potential Registration Abuse Categories and Countermeasures

As outlined above ICANN’s RAPWG has identified a number of potential abuse categories (see chapter 5 of their document). These correspond to the first bullet point of the potential abuses of a Registry as listed in section 1 above (“Abusive Registrations”). 

The proposed registry system addresses these individual categories as follows:

4.1 Reserved ⁄ blocked .VOTING domain names

As a first layer of security on the registration level Valuetainmentwill exclude (blocked from and⁄or reserved for registration and⁄or internal usage by Valuetainment) certain domain names for abuse prevention reasons from registration:

• names which are reserved on behalf of ICANN are not available at the second level and at all other levels within the .VOTINGgTLD;
• certain pornographic, defamatory or discriminatory words and expressions will be blocked from registration;
• the official names of cities, authorities, institutions and regions are blocked from general registration and will only be available to the respective entitled parties;
• as .VOTING gTLDs might be of particular interest to official political parties, Valuetainment will reserve such domain names making them only available to the respective political parties;
• certain Premium Names will be blocked from general registration and will be sold and⁄or auctioned off byValuetainment;
• finallyValuetainmenthas the right to reserve certain .VOTING domain names for personal and ⁄ or internal usage.

4.2 Cybersquatting

Abuses from cybersquatting cases in the proposed gTLD will be addressed by using ICANN’s existing and well know Uniform Dispute Resolution Process (“UDRP”). However, registry staff will also closely follow developments regarding Rights Protection Mechanisms within ICANN and will investigate potential paths towards adoption of such processes once they are clearly defined for the gTLD registry space.

Please refer to the answer to Question 29 for more detailed information on these measures.

4.3 Front-Running

Even though the RAP does not recommend any specific action regarding this issue, the proposed registry will a) treat all logfiles and any other information that reflectsuser interests in a particular domain name as confidential. Such data and log information will only be available to staff with actual operational requirements to access those files, and b) will include a respective provision in the gTLD’s registrar accreditation agreement that such data is to be kept confidential and may to be used to contact the respective potential costumer. 

4.4 Gripe Sites; Deceptive and Offensive Domain Names

In line with the RAP WG recommendation, the proposed gTLD registry will not develop best practices to restrict the registration of offensive strings. It is believed that the existing UDRP, in addition to court decisions (which the registry will obviously be bound by) provides sufficient,independent action against such potentially abusive names.

Please refer to the answer to Question 29 for more detailed information on these measures.

4.5 Fake Renewal Notices

The registry will not, in line with the RAPs recommendations, implement any specific countermeasure withinits registry systems and services. As the registry is required to provide accurate and complete WHOIS information for all domain names (which is believed to be the information source for such notices) it is not feasible to implement such measures at this level. It is understood that ICANN continually monitors this issueand will take necessary countermeasures against registrars associated with such practices.

The registry will, however, post warnings on their website about any clearly fraudulent (and clearly illegal) renewal and expiration notices of which its staff becomes aware and will take legal measures against registrars performing such illegal, fraudulent acts.

4.6 Name Spinning

This is considered to be a practice employed mainly by registrars in a legitimate way to offer users more choice and⁄or alternatives should their desired name already be taken. As such, it is believed that it is within the registrar’s responsibility to use those techniques in a considered manner. In reality it is not possible for the registry to differentiate between a legitimate domain namerequest, say one manually entered by a user, and a domain name request that was “spun” by the registrar.

In the event that such name spinning practices could lead to trademark infringements on a domain name, the UDRP allows for appropriate action to be taken against the holder of such a name.This follows the RAP’s recommendation.

4.7 Pay-Per-Click

In agreement with the RAP position, this is considered to be an indirect and purelyweb related issue that does not have a directrelationship to the registration of domain names. In most cases, pay-per-click is a legitimate revenue source for domain name owners and web site operators. Any potential misuse of such practices must be out of scope for the Registry and again any trademark cases are expected to be brought forwardusing the UDRP or URS.

4.8 Traffic Diversion

In accordance with the RAP position, this is again a web related issue and no specific countermeasures have been implemented within the registry’s operations.

4.9 Domain Kiting ⁄ Tasting

In order to prevent mass domain kiting ⁄ tasting (as it was observable in gTLD and ccTLD registries), the Registry will implement the “Add Grace Period Limits Policy” (http:⁄⁄www.icann.org⁄en⁄tlds⁄agp-policy-17dec08-en.htm), which efficiently removes the financial advantage of domain kiting ⁄ tasting and hence significantly reduces the volume of such registrations. All registrars will obviously be treated identically in this respect with no exemptions from that policy.

5. Abusive Use of a Domain Name

Corresponding to the second bullet in the list above (“Abusive Use”), the RAP WG has also provided an analysis in their Final Report. Valuetainment will implement strong safeguards and countermeasures to prevent the abusive usage of .VOTING domain names.

Abusive Use of a Domain Name is defined in the DNP as:
• Violation of applicable laws or regulation; in particular the provisions of the German Criminal Code, the German Youth Protection Act and the German Interstate Treaty on the Protection of Minors in the Media (JMStV).;
• Use of a domain to publish content and to conduct votingswhich incite to hatred against parts of the population or against a national, racial, religious or ethnic group, content which glorifies violence, content which violates
 the human dignity, content which denies or plays down acts committed under the National Socialist regime;
• Distribution of child abusive material; 
• Use of a domain name for the dissemination of spam, i.e. unsolicited bulk electronic communication (e-mail, instant messaging, on websites, in forums or mobile messaging) or advertising a domain name by means of spam;
• Use of a domain name for Distributed Denial-of-service attacks (“DDoS attacks”);
• Use of domain names in phishing activities, tricking Internet users into divulging personal data such as names, addresses, usernames, passwords, or financial data;
• Use of domain names in pharming , such as DNS hijacking and DNS cache poisoning;
• Use of domain names for the intentional distribution of malicious code such as spyware, botware, keylogger bots, viruses, worms or trojans;
• Use of domain names to command and control botnets , i.e. a network of compromised computers or “zombies,”
• Use of domain names in activities intended to gain illegal access to other computers or networks (“hacking”), as well as any activity to prepare for such a system penetration; or
• Use of a domain name fast flux hosting, disguising the location of internet addresses or Internet services.

Additionally, as detailed in the answer to Question 29 (Rights Protection Mechanisms), Valuetainment takes extensive measures to protect third party rights with regard to .VOTING domain names. This includes

• conducting a Sunrise phase to allow trademark holders to secure names related to their trademarks prior to general availability;
• accessing the Trademark Clearinghouse to validate trademarks presented by registrants;
• offering the Trademark Claims Service, not only during the first 60 days of general availability, but on a continuous basis;
• taking precautions against phishing and pharming and
• committing to full compliance with established Dispute Resolution and Suspension Procedures, including the Uniform Rapid Suspension (URS), the Trademark Post-Delegation Dispute Resolution 
 Procedure (Trademark PDDRP) and the Uniform Domain Name Dispute Resolution Policy (URDP) 

Please refer to the answer to question 29 for more detailed information on these measures.

6. Registry Interfaces Abuse

The registry will employ the following countermeasures to protect against abuses of the registry systems and the DNS network itself:
6.1 WHOIS data harvesting

WHOIS access is a critical and vital serviceprovided by any gTLD registry and the Registry will obviously comply with ICANN’s requirements for WHOIS access.

However, as indicated in the SSAC’s document “Is the WHOIS Service a Source for email Addresses for Spammers?”, WHOIS abuse can be considered to be one of the primary meansto generate email address lists for the purposes of sending unsolicited email, in particular the practice of mass harvesting information from the WHOIS. It is also believed that the WHOIS is the main source of data for generating fake renewal notices. To protect against harvesting of registration data (and particularly, email addresses), the registry will employ the following countermeasures:

• WHOIS query rate limits: All access to whois data will be query rate limited on a per-IP-address basis (for IPv4) and a per-prefix basis (for IPv6), with a daily limit of 25 WHOIS queries per IP address⁄prefix. Once this limit is reached, 
 the WHOIS server responds with a relevant notification message instead of the standardWHOIS answer (The query limits may be reviewed and adapted by the Registry operator from time to time). IP-Ranges of accredited registrars 
 (and other IP-ranges, eg. ICANN itself, UDRP and URS service providers etc) will be excluded from thoserate limiting measures. This will allow legitimate usage of the service while at the same time make it very difficult to harvest data 
 on a large scale.
• Email⁄Phone⁄Fax privacy: The EPP implementation of the “contact” object provides a mechanism that allows a registrar to define whether or not the “email”, “phone”, and “fax” fields of the contact object shall be publicly disclosed
 (i.e. “contact:disclose” element). The registry will set these fields to “do not disclose” by default, however, registrars can modify this setting via the normal EPP command stream. When a flag for a certain field is set to “do not disclose”, 
 the respective field will be omitted from anonymous WHOIS outputs, providing a minimum level of privacy to registrants. To allow for various business processes, IP Ranges of accredited registrars (and other IP-ranges as needed, eg. 
 ICANN itself, UDRP and URS service providers) will still need to see the full data set, including those fields marked as “do not disclose”.
• WHOIS monitoring: The WHOIS service will be monitored in order to identify unusual activity on the interface

The countermeasures above provide a well-balanced compromise between the requirements to provide access to WHOIS data and the basic data protection rights of registrants. More information about the WHOIS service provided by the registry is contained in response to Question 26.
6.2 EPP Interface Abuse

As described in the answers to the SRS, EPP and security questions (Question 24, 25 and 30, respectively), the EPP interfaces of the Registry are heavily firewalled, are only accessible from IP-ranges of accredited registrars and are protected by EPP authenticationmechanisms. As such, abuse of those interfaces (such as DDoS, brute-force attacks against username⁄password combinations etc) can only be performed from networks of parties with which the Registry Operator has a legal agreement. Additionally, EPP interfaces are rate-limited at the network layer.

Registars are obliged by the RRA to represent and to warrant that they are technically able to deliver and to perform its obligations under the RRA which means, that each registrar is contractual obliged to 

• not abuse the EPP Interface;
• employ all necessary and current technology and all needed restrictions to ensure safe and secure connections;
• informValuetainment immediately in the event of a data security breach on his side (e.g leaked passwords).
• 
Should a registrar fail to comply with such provisions he’s obliged to indemnify Valuetainment. Depending on the breach of its obligations, Valuetainment has the right to cancel the respective RRA resulting in the obligation of the affected registrar to immediately transfer its sponsorship of registered .VOTING domain names to another registrar. 
6.3 DNS Interface Abuse
Public nameservers, hidden masters and the signing infrastructure is configured and firewalled so that they allow NOTIFYs and UPDATEs from the required addresses only. In order to prevent zone walking and load peaks, zone transfers from the DNS infrastructure are disabled. 

7. Management and removal of orphan glue records

It is understood, that inline with the SSAC’s comments in http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf, glue records have a vital function in the correct and normal operation of the DNS but that they can also be used for malicious purposes. 
In order to prevent such malicious usage, the registry performs glue record management in accordance with the following policy:

• Provisioning of host objects with glue: In line with the EPP RFCs, glue record (“internal”) host objects can only be provisioned when the superordinate (parent) domain name exists in the registry. Host objects that are not under the TLD managed by the registry (“external hosts”) can never have A or AAAA records
• Deletion of domain with subordinate glue record hosts: When a domain name transitions from a “REGISTERED” to a “REDEMPTION” status (for example, via the EPP “delete domain” command, or via expiration), the domain name itself is removed from the DNS, however any glue records under the deleted domain are kept in the zone temporarily. Other registrars who are affected by a potential impact on DNS service due to the upcoming removal of the host from their domains are notified via the EPP message queue. 
• Subsequently, when the domain name transitions from a “REDEMPTION” to a “PENDING DELETE” status, the glue records under the affected domain name are revoked from the DNS, but still exist in the SRS database.
• In the last step of the deletion process (transition from “PENDING DELETE” to “AVAILABLE”), the glue record host objects are deleted together with the domain and are also removed from any other domain name in the registry that still uses those hosts.
This policy effectively prevents misuse of orphan glue records in the registry since the status of a host object always follows the status of the superordinate domain. As a result glue records can never exist for domains that are not in the registry database. Additionally, keeping the glue records in the zone during the redemption period together with notification to Registrars significantly reduces the risk of other domainsbeing impacted and reduces the effort required by a registrar in the event that the domain is subsequently restored. 

However, in addition to this procedural policy outlined above, the registry operator will also act on documented evidence that glue records are present and used inconnection with malicious activity by subsequently removing such glue records manually.

8. Ressourcing Plan

The abuse management is outsourced to Schollmeyer&RickertRechtsanwaltsgesellschaftmbH, a law firm that has seven attorneys plus additional support staff so that an efficient abuse management can be granted even if the volume of complaints should be high at times. The abuse management will be rendered on the basis of a fix fee as already included in the financial projections. There will be no additional costs for Valuetainment.

8.1 CERT.atis a department of the backend provider

It is important to note that the Austrian CERT (Computer Security Emergency Response Team - http:⁄⁄www.cert.at⁄), staffed with 5 full-time-equivalents is a department within nic.atand shares offices with theregistry operations team. Hence, world class security and anti-abuse expertise is committed to beavailable literally „next door“ to the registry operations centre.

Also note that ICANN’s “Trademark Clearing House” policy is still subject to change, hence final descriptions of the registry services required to support that functionality are not possible.
1 Overview

As required by specification 7 of the new gTLD Agreement, the Registry Operator will implement and adhere to any rights protection mechanisms („RPMs“) that are mandated by ICANN. 
Furthermore, Valuetainment will implement a “.VOTINGphased roll-out policy”, which will address the different availability phases (Sunrise and Landrush) of the new .VOTING gTLD. This policy will contain several mechanisms designed to protect third party rights. 
All mandated and independently developed rights protection mechanisms will be included in the registry-registrar agreement for the TLD. The Registry Operator will implement all required RPMs described in the Trademark Clearinghouse function (once adopted by ICANN) and understands that ICANN may revise such requirements from time to time.
The Registry Operator will not mandate that owners of applicable intellectual property rights have to use any other trademark information aggregation, notification or validation service in addition to or instead of the ICANN-designated Trademark Clearing House.
The Registry Operator will comply with PDDRP, RRDRP (which is not applicable in the present case) and URS procedures, and will implement and adhere to the remedies ICANN imposes via those processes.
The Registry Operator will also take reasonable steps, as detailed in the answer to question 28, to investigate and respond to any reports from law enforcement, governmental and quasi-governmental agencies of illegal conduct under the .VOTINGgTLD, and understands that the Registry Operator will not be required to take any action that contradicts applicable law.
Details about the implementation of the various rights protection mechanisms are included below.

1.1 UDRP Support

It is understood that ICANN’s Uniform Dispute Resolution Process (UDRP) is largely concerned with registrars. Hence, the Registry Operator does not need to implement any specific process in order to support the UDRP specifically. However, the Registry Operator will support registrars in UDRP cases involving domain names under the TLD and will cooperate with approved Dispute Resolution Service Providers in order to assist in their work.
1.2 URS Support

The Registry Operator will comply with ICANN’s requirements regarding the Uniform Rapid Suspension (URS) process and understands that the following services are required (and will be provided) during the operation of the TLD:
• Contact information: the Registry Operator will provide email and other contact information to accredited URS-DPRs so that notices and other communication regarding URS cases can be communicated efficiently.
• Notice and locking of a domain: Upon receipt of a respective Notice from an accredited URS provider, the Registry Operator will “lock” the affected domain name within 24 hours by means of putting it into the LOCKED status. This means that modifications (including transfers) on the domain name and registration data will be rejected but the name will still resolve in the DNS. The Registry Operator will immediately notify the URS provider upon locking the domain.
• Remedies: In order for the URS-DRP to implement the Remedy, the Registry Operator will subsequently modify the registration (for example, by changing nameservers to the URS-DRP’s own hosts) or remove the LOCKED status on the domain or implement other such measures as instructed by the URS Provider.
• Extend Registration: the Registry Operator will support successful Complainants if they wish to extend the registration period for one year at commercial rates. 
The Registry Operator wishes to note that authentication of URS providers is a critical issue since Notices and other instructions may be sent via email to the Registry Operator and email itself does not provide any means of authentication. Hence, additional measures such as cryptographically signing such emails will be deemed necessary in order to identify a Notice as authentic and subsequently authorize requests to the Registry Operator.


1.3 PDDRP

The Registry Operator agrees to participate in the procedures required by the Post-Delegation Dispute Resolution Procedure (PDDRP) and be bound to all determinations that are the result of said procedures. The process implemented by the Registry Operator for actual complaints will be as follows:
• Once a Complaint is received electronically or in paper notice form from the Provider, Registry Operator will verify the content requirements of the Complaint, according to section 7.2 of the current PDDRP specification (dated Sep 19 2011). The Complaint will be reviewed by the legal team at Schollmeyer&RickertRechtsanwaltsgesellschaftmbH.
• The Registry Operator will notify the Provider about the receipt of a complaint.
• If deemed necessary, the Registry Operator will submit papers within 10 days of receipt of the Complaint.
• Registry Operator will subsequently follow the process regarding implementation of the remedies, as described in the PDDRP specification.
1.4 RRDRP

The Registry Operator agrees to participate in the procedures required by the Registration Restriction Dispute Resolution Policy (RRDRP) and be bound to the determinations that are the result of said procedures, in accordance to Section 2a of Specification 7 of the New gTLD Agreement. The actual administrative steps for handling Complaints based on the RRDRP will be identical, process-wise, to the PDDRP process described above.
1.5 Trademark Claims (Clearinghouse)

It is understood that – according to the Trademark Clearing House definition dated Jan 12 2012 – ICANN is going to define a Trademark Clearinghouse provider who will in turn supply two primary functions (see Section 1.2 of the document), of which function (ii) (“serving as a database to provide information to new gTLDs”) will be directly relevant to the operation of this TLD.
It is also understood that ICANN’s work towards the establishment of such a Trademark Clearinghouse is still in progress. Therefore, it is not yet possible to describe the actual process and technical interfaces by which the Registry will support the Trademark Clearinghouse requirements.
The Registry Operator will, however, implement any reasonable measures and processes that are required by the Trademark Clearinghouse function.

1.6 Sunrise Services

During the Sunrise period, holders of marks that have been previously validated by the Trademark Clearinghouse (1.6 above) will receive notice of domain names that are an identical match (as defined in the ICANN Applicant Guidebook) to their mark(s). Such notice will be provided in accordance with ICANN’s requirements either by Valuetainmentdirectly or through a registrar. 
Valuetainmentrequires all registrants, either directly or through registrars, to i) affirm that said registrants meet the Sunrise Eligibility Requirements (SER) and ii) submit to the Sunrise Dispute Resolution Policy (SDRP) consistent with Section 6 of the Trademark Clearinghouse model. 
During the Sunrise period, Valuetainment and⁄or registrars, as applicable, are responsible for determining whether each domain name is eligible to be registered (including in accordance with the SERs).
1.7.1 Sunrise Eligibility Requirements
The SER will include the following:
A. The registrant meets, where applicable, the requirements of the .VOTING Eligibility Policy;
B1. The registrant is the owner of a word mark: (i) that is nationally or regionally registered for which proof of use – which can be a declaration and a single specimen of current use – was submitted to, and validated by, the Trademark Clearinghouse; or (ii) that has been court-validated; or (iii) that is specifically protected by a statute or treaty currently in effect and that was in effect on or before 26 June 2008; or
B2. The registrant is the owner, licensee or legal successor of a registered and existing trademark right (word mark and⁄or figurative mark), for which the claimed legal position on which the registration of the domain name is based was in effect on or before 26 June 2008 and the domain name is identical to the textual element of the mark (for which the parameters will be further defined);
C. The requirement of a representation that all provided information is true and correct;
D. The requirement that the provision of data sufficient to document rights in the trademark; and
E. The requirement that the application has been successfully validated by Valuetainment’s Validation Agent.
Applications submitted to Valuetainmentor through an accredited registrar during the Sunrise Period are validated for completeness and accuracy in accordance with the roll-out policy on behalf of Valuetainmentby a specialized Validation Agent, who will be tasked to 
o validate trademarks against the Trademark Clearinghouse or against the respective database of the competent trademark office; and
o determine whether the trademark matches the string applied for according to the SER.
The Validation Agent can request supplementary records from the registrant at any time in the course of the validation process. Registrants are obliged to pay a fee for the application and for the respective validation. Rejected and⁄or unsuccessful applications will not be refunded.
Applications shall be rejected if,
o the application does not contain complete and accurate information as described in the Sunrise Policy, or is not in compliance with other provisions of the Sunrise Policy and⁄or other applicable .VOTING policies;
o the domain name applied for obviously violates existing law, court or official orders, and is accordingly likely to endanger the operations of .VOTING; or
o the Registrant fails to pay the validation fee and⁄or fails to deliver supplementary records as requested by the Validation Agent.
Domain names applied for shall be registered after the end of the Sunrise Period if,
• Valeutainmenthas received only one application for a given domain name which was successfully validated, this domain name will be registered to the Applicant, if it meets the other requirements of the Sunrise policy and the other applicable .VOTING policies; or
• an Applicant whose application has been validated was the highest bidder in an auction.
Should Valuetainmentreceive two or more valid applications for the same domain name, it will be offered to the applicants at auction. The highest bidder will be awarded the domain.
1.7.2 Sunrise Dispute Resolution Policy (SDRP)
After any Sunrise name is awarded to an applicant, it will remain under a “Sunrise Lock” status for at least 60 days so that parties will have an opportunity to file Sunrise Challenges. During this Sunrise Lock period the domain name will not resolve and cannot be modified, transferred, or deleted by the registrar. The domain name will be unlocked at the end of that lock period only if it is not the subject of a Sunrise Challenge.
The Sunrise Dispute Resolution Policy (SDRP) will allow Sunrise challenges based on the following four grounds: 
(i) at time the challenged domain name was registered, the registrant did 
not hold a trademark registration of national effect (or regional effect) or the 
trademark had not been court-validated or protected by statute or treaty; 
(ii) the domain name is not identical to the mark on which the registrant based its Sunrise registration; 
(iii) the trademark registration on which the registrant based its Sunrise 
registration is not of national effect (or regional effect) or the trademark had not 
been court-validated or protected by statute or treaty; or 
(iv) the trademark registration on which the domain name registrant based its Sunrise registration did not issue on or before the effective date of the Registry Agreement and was not applied for on or before ICANN announced the applications received.
1.7 Other Reports

As detailed in the answer to question 28, reports and requests from competent authorities, law enforcement and⁄or courts will receive top priority. These parties will receive priority contact options to ensure quick and proper reactions. Such requests will be handled and resolved by Valuetainment’s abuse team – the legal team at Schollmeyer&RickertRechtsanwaltsgesellschaftmbH- without delay, the latest within 24 hrs.
1.8 Contractual Measurements

The answer to Question 28 (“Abuse Prevention and Mitigation”) described Valuetainment’sdifferent contractual approaches to identify and address abusive usage of .VOTINGgTLDS. Valuetainmentwill establish upon the launch of the new .VOTINGgTLD the “.VOTINGEligibility Policy”, the “.VOTING Domain Name Policy” and the “.VOTING Abuse Reporting and Takedown Policy”. 
These policies will all be part of the Registry-Registrar Agreement (RRA), which needs to be signed by all registrars interested in offering registrations under the .VOTINGgTLD giving Valuetainmentthe possibility to impose certain sanctions against Registrants directly should this be necessary. Those contractual rights, procedures and measurements are designed as following:
By applying for and registering .VOTINGdomain name(s) the registrant enters into a direct agreement with Valuetainment. Furthermore Valuetainmentshall be entitled (but not obliged) to reject an application or to delete, revoke, cancel or transfer a Domain Name Registration should the respective domain name infringe upon third party rights. 
If Valuetainmentor any other party involved in the registration of the .VOTING domain name is directly contacted by a third party because of alleged violations of law, Valuetainment’s abuse team will notify the registrant by e-mail, either directly or through the respective registrar. The registrant will process and reply to all correspondence forwarded by Valuetainmentwithout delay, and at least within 48 hours, unless a third party has set a shorter period or there is other specific need for speed. 
Should the registrant fail to reply within this time limit, Valuetainmentis entitled to stop the domain name from resolving via the DNS, have it deleted and⁄or to terminate the respective agreement.
 In urgent cases, Valuetainmentis entitled to stop the domain name from resolving via the DNS, have it deleted and⁄or to terminate the respective agreement without prior notification or warning. This applies specifically to violations of criminal law and⁄or violations of youth protection law. 
1.9 Dispute-related Technical Functionality in the Registry System

In order to handle any disputes concerning a domain in the “.VOTING” zone according to the RPMs defined, the Registry Administration Panel (a web-based interface to the SRS to query and manipulate registry data) includes functionality to manually put domains into the “LOCKED” status (see Answer to question 27 – Registration Lifecycle). The dispute related functions are based on more than 12 years of experience in managing disputes under the “.at” TLD and provide the following functionality:
• Search for domain names and display WHOIS as well as registrar data
• For each domain, the following tasks can be performed:
** Delete the domain immediately (domain immediately enters PENDINGDELETE state and thus cannot be restored by a registrar)
** Put the domain into the LOCKED state (which prevents modifications and transfers on the domain name, and also prohibits modifications on the associated registrant contact)
** Add the “serverHold” status to domain names under LOCKED(so that the name is excluded from the DNS, and hence technically disabled)
** Remove the “serverHold” status from a LOCKED domain
** Put domain names in LOCKED state back to their previous state (most commonly, REGISTERED).
** For each action, the system allows users to select one of several “reasons” to be recorded with the action.
** An additional free-form text box allows users to record additional information, such as pointers to external documents, or case numbers.
• List all domain names in LOCKEDstatus
• Display data, reasons, and additional information of domains in LOCKED state
• Display historical data about such cases

1.10 Resourcing Plan for Implementation and Ongoing Maintenance

Valuetainment staff will implement the measures described above with the support of subcontractors as described in the financial section.
Basic functionality regarding rights protections mechanisms (domain locking, tracking of requests) is already implemented in the registry core system, hence no further resources are needed for this initial implementation. 
However, it is understood that resources are necessary to implement further measures that require technical interaction with the registry system, as soon as they are clearly defined (especially the trademark clearing house process and sunrise). The implementation effort cannot be foreseen at the time of writing,hence the concrete resourcing plan for the technical part of the implementation and ongoing maintenance cannot be provided. However, the Registry Operator is aware of the fact that during landrush and sunrise more resources will be allocated to handle the increased load on the day to day operations as well performing necessary changes on the system after completion of sunrise and landrush if instructed by ICANN rules to do so. 
Still, the Registry Operator will implement any reasonable measures and processes that are required by ICANN in respect to rights protection and resources will be allocated accordingly to have the functionality available for the operation of the registry.

Registry Policy Framework

The Information Security Management System was developed in accordance with the international standard ISO 27001 and the registry backend operator is currently on the ISO 27001 certification path for theInformation Security Management System(ISMS)to be completed before launching the registry. For the secondary datacenter in Salzburg the certification will be completed in 2012 and the primary datacenter in Vienna is already certified – please find ISO 27001 certification document in attachment 30a-06.

Valuetainment’s business is governed by Swiss law. However, Valuetainment also undertakes to be fully compliant with German law in the area of data protection to make it easier for registrants from the EU to understand the legal system within which the applicant operates. The German Federal Data Protection Act provides for a high level of both data protection as well as data security. These requirements are particularly enshrined in Art. 9 of the Federal Data Protection Act and its appendix as attached (Appendix 30a-07):
 
Registry Back-end Operator Security Organization

The role of the Chief Information Security Officer (CISO) is definedin the organization operating the registry back-end, and is staffed with an FTE. This person is responsible for the setup, operation and continuous improvement of the Information Security Management System and Business Continuity Management System.

In the organization chart the CISO is located directly below senior management. This role is independent of operational management and directly reports to the upper management of the registry backend operator who in turn reports to the registry operator’s management. The CISO advises the management on all security related issues.

Information Security Management System (ISMS):

The ISO 27001 based ISMS supports and facilitates management in achieving the goals defined in the Corporate Security Policy and Security Standard. The ISMS as shown in diagram Q30a-1 provides the Deming - cycle (plan-do-check-act) in security concerns as referred to in ISO 27001.

The Security Policy Framework and Security Standard have a review cycle of a maximum of 1 year. The CISO is responsible for adhering to this review cycle.

Business Continuity Management System (BCMS)

Please find further details on BCMS in response to question 39.

1 Corporate Security Policy

The Corporate Security Policy is understood as the commitment by upper management to support and maintain information and IT security.

The main items are:

• The overall goal of these activities is to prevent security incidents and to minimize their impact.
• Prevention before damage reduction; personal responsibility and awareness before surveillance of employees.
• Information security and IT security are important quality metrics for the registry.
• Information security and IT security are core competences of the registry.
• Safeguarding the integrity and availability of the gTLDs Domain Name System
• In the event of a Security incident to minimize any potential damage. 

2 Corporate Security Standard

The Corporate Security Standard, based on ISO 27001, defines the areas of responsibility for information – and IT security:

• IT Risk Management
• Continuous Improvement Process
• Audit Management
• IT Asset Management
• Information Classification and Processing
• IT Change Management
• Identity and Access Management
• Personal Management
• Security Incident Management
• IT Project Management
• IT Patch and Update Management
• Backup and Recovery
• Logging and Monitoring
• Spam and Antivirus
• Mobile Devices
• Media Disposal
• Network Security
• Physical Security
• External Suppliers

These areas will be discussed in more detail in the following sections. 
2.1 IT Risk Management

Diagram Q30a-2 describes the risk management process in use at the registry.

The evaluation of risks is performed according to 4 different category types: 

• Finance:assesses any potential financial impact on the registry.
• Operating Tasks:assessesthe influence on the main business processes or tasks of the registry.
• Corporate Image:assesses the effects of reputational damage or loss of trust in the registry.
• Compliance:assessesimpact of contractual or legal damages.

The risks are evaluated and categorized into the following severity levels:

• Critical
• High
• Medium
• Low

The risks are further measured by their estimated frequency of occurrence:

• Very high probability: 1 per month or more frequently
• High probability: 1 per year
• Possible: every 10 years
• Highly unlikely: every 100 years
• Impossible: risk is not relevant (for example avalanches in Vienna)

The risk assessment is performed using the Delphi technique and involves management, the CISO and the head of IT. Within each category the worst cases are rated as the most important ones.

Aspects of risk management are also used for the vulnerability management.

ISO27001
Domain Name
6 Organization of information security
6.1 Internal organization
6.2 External parties
12 Information systems acquisition, development and maintenance
12.6 Technical vulnerabilitymanagement

2.2 Continuous Improvement Process

The continuous improvement process is risk-management oriented, and shown in Figure Q30a - 2: Continuous Improvement process.

Regularorganizational meetings are set up to trigger the process:

• IT security update: 
** Participants: Head of IT, CISO
** Topics: Operational tasks
** Frequency: At least every 2 weeks
• Security jour fixe: 
** Participants: CTO, CISO, optional head of IT
** Topics: Planning, monitoring of projects, tasks, countermeasures
** Frequency: At least every month
• Management security jour fixe: 
** Participants: CEO, CTO, CISO, optional head of IT
** Topics: Risk management, large scale management decisions

The management review has to take place at least once per year or as needed in the event that a potential risk arises.

2.3 Audit Management

The planning of all audit work including technical audits such as penetration tests and vulnerability scans is managed by the CISO.

Different kinds of technical security audits are accomplished:

• Regular basis
** Vulnerability scans on systems at operating system level to identify problems in patch management or configuration processes
** Penetration tests are executed by third party security consultants to identify design issues, organizational deficits or other security issues. The focus of the penetration tests is varied every year.
** Web vulnerability scans (OWASP Top 10) are performed against all internal and external websites
• Prior to the launch of a new system:
** Penetration testing of all business critical system elements
** Vulnerability scans on the system at an operating system level
** Web vulnerability scan (if the system is web-based)

ISO27001
Domain Name
6 Organization of information security
6.1 Internal organization
6.2 External parties
15 Compliance
15.1 Compliance with legal requirements
15.2 Compliance with security policies and standards, and technical compliance
15.3 Information systemsauditconsiderations

 
2.4 IT Asset Management

All assets and their lifecycles are fully documented. Assets are categorized as follows:

• Physical assets
• Software assets
• Information assets

ISO27001
Domain Name
7 Asset Management 
7.1 Responsibility for assets
7.2 Information classification
8 Human resourcesecurity
8.3 Termination orchangeofemployment

2.5 Information Classification

All information is classified into the following categories:

• Public: For example data on public websites
• Internal: For example general company information
• Confidential: For example annual business reports before publication
• Highly confidential: For example person specific data, penetration testing reports

The data classification policy defines how to store, transmit and share these different kinds of information.

ISO27001
Domain Name
7 Asset management
7.1 Responsibility of assets
7.2 Information classification 
10 Communications and operations management
10.7 Media handling
10.8 Exchange of information
12 Information systems acquisition, development and maintenance
12.3 Cryptographic controls
15 Compliance
15.1 Compliance with legal requirements

 
2.6 IT Change Management

IT change management ensures that all modifications to IT systems can be reproduced, fulfill the organizational needs and are documented. Changes are categorized into following groups:

• Changes without approval
** Below low risk
** Implemented within 1 week
• Standard change
** Low risk
** Implemented within 1 month
• Emergency change
** If availability of a service is dependent on a specific change
** Has to be done as soon as possible
** Can’t be scheduled any more
** Escalation to management is required

ISO27001
Domain Name
10 Communications and operations management
10.1 Operational procedures and responsibilities
12 Information systems acquisition, development and maintenance
12.6 Security in development and support processes

 
2.7 Identity and Access Management

All user rights are based on the “least privilege” and “need to know” principle. Roles are used to group the relevant user permissions where appropriate.

User accounts are personal accounts meaning that they identify one specific person. Group or role accounts are non-standard and have to be approved in writing by the CISO.

Administrative accounts have to be approved by the head of IT in writing. There are stronger policies, for example password policies.

External accounts (for third parties) also need written approval by the CISO. These types of accounts are deactivated after 30 days.

External administrative accounts need written approval by the head of IT and the CISO. Such accounts are subject to increased monitoring and logging. These types of accounts are also deactivated after 30 days by default.

If an employee leaves the company, his⁄her account is deactivated immediately. 

Inactive accounts are deleted after 60 days.

At least once a year there is a review of the accounts structure and user rights permissions performed by analyzing a sample of accounts.

ISO27001
Domain Name
11 Access controls
11.1 Business requirement for access control
11.2 User access management
11.3 User responsibility
11.5 Operating system access control
11.6 Applicationandinformationaccesscontrol

2.8 Personnel Management

Checklists exist for employee entry and exit activities. Every new employee is added to these lists and registered. All new employees have to prove that they have not been previously prosecuted and do not have a criminal record which means that there are no relevant records in the police records (Strafregisterauszug). Every employee must attend a security awareness course.

Background checks for security personnel

All Computer Emergency Response Team (CERT) members and the CISO are background security checked by the Federal Ministry of Interior (§55 Sicherheitspolizeigesetz).

ISO27001
Domain Name
8 Human resource security
8.1 Prior to employment
8.2 During employment
8.3 Termination or change of employment

2.9 Security Incident Management

A sister company of the registry backend operator also operates a CERT. This team consists of one Junior Security Analyst and a minimum of five Senior Security Analysts with at least 5 years and up to 15 yearsexperience in IT Security. 

This team also operates the national CERT for the Republic of Austria (CERT.at) and together with the Federal Chancellery of the Republic of Austria, the Austrian Government CERT (GovCERT Austria). It is internationally accredited as a Forum of Incident Response Member (FIRST) and a Trusted Introducer. By achieving these memberships the registry has built an excellent formal and informal information network. As a result the registry is well prepared for the prevention of and response to security incidents.

Figure Q30a –4 the Security Incident Management Process is described.

Classification for the triage of security incidents

Urgency:

• Immediate: Reaction within 1h, invoke crisis organization if necessary
• Soon: Reaction within 8h or on the next business day
• Normal: Equivalent to a systems change, defined by change management procedures

Impacts:

• Critical
• High
• Middle
• Low

ISO27001
Domain Name
13 Information security incident management
13.1 Reporting information security events and weaknesses
13.2 Management of information security incidents and improvements

 
2.10 IT Project Management

A specific project management methodology has been defined.

ISO27001
Domain Name
6 Organization of information security
6.2 Internal organization
10 Communications and operations management
10.1 Operational procedures and responsibilities
10.3 System planning and acceptance
12 Information systems acquisition, development and maintenance
12.1 Security requirements of information systems
12.5 Security in development and support processes

2.11 IT Patch and Update Management

A formalvulnerability and patch management process has been defined (shown in Figure Q30a -5: Vulnerability Management).

Patches are classified as: 

• Critical (remediation within hours)
• Non critical (remediation by the next patch day)

All patches are fully tested prior to being deployed. 

The effectiveness of the patching process is audited by vulnerability scans and by matching the actual software inventory with vulnerability databases.

Reports are discussed on a regular basis by management in order to guarantee continuous improvement.

ISO27001
Domain Name
10 Communications and operations management
10.1 Operational procedures and responsibilities
12 Information systems acquisition, development and maintenance
12.5 Security in development and support processes
12.6 Technical Vulnerability Management

2.12 Backup and Recovery

A full backup and recovery framework is in place. For details see the answer to question 37.

ISO27001
Domain Name
10 Communications and operations management
10.5 Back Up 
15 Compliance
15.1 Compliance with legal requirements

2.13 Logging and Monitoring

A logging and monitoring solution is in operation to identify malicious activities and unauthorized access. All authorized access is also logged.

All servers and systems are time synced using the Network Time Protocol (NTP).

The level of detail of logging:

• Varies with expected risks
• Requirements of business processes
• Requirements of data integrity and confidentiality

Minimum details are

• User ID
• Date and time
• Type of access
• Software
• Non authorized access
** Not working action
• Administrator actions
** System start and stop
** Change of system configuration
** Activation and de-activation of security components
• Security components alarms
• Error protocol
• Security protocol, for example anti virus software

All relevant systems of the gTLD registry are controlled by a host-based intrusion detections system (HIDS). All events are logged on a central device.

The HIDS allows to: 

• Check of host integrity.
• Check of file integrity.
• Port monitoring
• Programs using specific ports
• Process checks
• Login⁄logoff

The HIDS and the other log sources are integrated into a central monitoring tool. This tool can trigger certain events.

Analysis of logging and monitoring information is performed continuously to detect security incidents and performed as needed in the event of a security incident.

ISO27001
Domain Name
10 Communications and operations management
10.2 Third party service delivery management
10.10 Monitoring 
15 Compliance
15.1 Compliance with legal requirements

2.14 Spam and Antivirus

All office systems are protected by anti malware software. Servers are checked on a regular basis, if real time protection is not possible.

ISO27001
Domain Name
10 Communications and operations management
10.4 Protection against malicious and mobile code
10.6 Network security management
13 Information security incident management
13.1 Reporting information security events and weaknesses

2.15 Mobile Devices

All smartphones and mobile devices (for example notebooks) must use full hard disk encryption if technically possible. If possible it should be combined with remote wipe functionality.

The actual standard for smartphones are to use Blackberry devices with a corporate policy.

Every loss of a device has to be reported to the IT department as soon as possible.

ISO27001
Domain Name
7 Asset management
7.1 Responsibility for assets
11 Access control
11.7 Mobile computing and teleworking

2.16 Media Disposal

Information in paper form must be shredded if it is classified as confidential or higher. 

Hard disk drives (HDD) and other storage media are deleted or destroyed in conformance with policy requirements.

For example:

• Overwrite HDDs multiple times with random data
• Shredder CDs

Media disposal policies apply to all relevant devices, e.g. also HDDs in printer or other media devices.

ISO27001
Domain Name
9 Physical and environmental security
9.2 Equipment security
10 Communications and operations management
10.7 Media handling

2.17 Network Security

The aspects of integrity, confidentiality and availability are considered as essential aspects in our network design.

Integrity, confidentiality:

• Encryption on network layers between:
** Data centers
** Offices and data centers

Availability

• Redundant physical paths via multiple carriers

Access to the network itself is restricted by means of security zone definitions, for example no direct connection is available to the corporate network from visitor meeting rooms etc.

All controls are audited on a regular basis, for example by penetration tests.

ISO27001
Domain Name
10 Communications and operations management
10.6 Network security management
11 Access control
11.4 Network Access Control 
12 Information systems acquisition, development and maintenance
12.3 Cryptographiccontrols

2.18 Physical Security

The physical security risks are again evaluated on an annual basis.

The gTLD systems themselves are operated in two different data centers with state-of the art security provisions in place, e.g. heavily restricted access to data center and locked racks.

For details see answer to question 39.

ISO27001
Domain Name
9 Physical and environmental security 
9.1 Secure areas
9.2 Equipment security

2.19 External Suppliers

For external suppliers either the same restrictions as those for internal personnel or further restrictions are applied.

Domain Name
6 Organization of information security
6.2 External parties
10 Communications and operations management
10.2 Third party service delivery management