Application number: 1-1713-23699 for dotgay llc
Generated on 30 May 2012
The mission of the .gay TLD is to create an environment on the Internet that addresses important and primary needs of the Gay Community; safety, visibility and support. Safety : A safe space will encourage more community members to come out and thrive in the .gay network. The Gay Community is a community centered on individuals whose gender identities and sexual orientation are outside of the norms defined for heterosexual behavior. Individuals of the Gay Community have come out of the shadows with pride and proclaimed their identity, demanding the respect and equal rights due based on international treaties such as the Universal Declaration of Human Rights, as stated by United Nations Secretary-General Ban Ki-moon at the Summit of the African Union (January 29, 2012). Yet often these identities are proclaimed at great risk to personal, family or professional safety. Visibility : To be visible is to be counted and to be counted is to be relevant to society and the economy. With the participation and endorsement from many of the largest organizations in the global Gay Community, the .gay TLD will enhance the visibility of the Gay Community so that economic and social disparities can be more easily addressed. Greater visibility will also promote greater competition and consumer choice in and amongst the Gay Community. Developing the .gay TLD as a gathering point that establishes our footstep and demonstrates our presence as one larger global community, it becomes the new banner that rallies the diverse elements of the community. As a community whose presence can be quantified and aggregated, we will all be in a better position to be understood and to create real change. Support : To support the Gay Community with access to trusted resources, as well as with funding. The Gay Community has long been a largely self-supporting community in all regions of the world. This fact has demanded action on the part of the community to assemble resources and funding in support of causes and initiatives earmarked as priorities in the community, including but not limited to social service, business and support organizations. The .gay TLD will assemble the largest pool of resources from all segments of the community to support and empower the Gay Community, while realizing tangible and sustainable financial benefits that will directly impact how the community tackles any challenge it faces. The struggles and challenges faced by the Gay Community to date reinforce the need to create the .gay TLD as a community-based TLD and as such must support both social and economic imperatives. Under dotgay LLC’s community-based model for the .gay TLD, 67% of the profits from domain name registrations will be made available to the dotgay Foundation. The dotgay Foundation will be established at the point that ICANN approves dotgay LLC’s .gay application and will have a mission to financially support initiatives in the global Gay Community. Additionally, dotgay LLC will provide a commission to organizations in the Gay Community who act as Authentication Partners, through an incentive program that rewards them for their authentication services and marketing efforts.
18(c). Describe operating rules to eliminate or minimize social costs or financial resource costs, various types of consumer vulnerabilities.
18(c)i Creating .gay as a vibrant community-based TLD requires an innovative approach to registration that ensures names are distributed in a fair and orderly manner during launch, and redistribution after expiration, in order to create the maximized benefits for the intended registrants and Internet users. This includes rights protection offered during Sunrise A and B, as well as a level of protection based on domain names that community members have built their organizations and businesses around on other IANA-recognized TLDs. In all cases described below each .gay domain name registration requires community authentication, which is manifested through a unique Community Identifier Code (CIC) per registrant and domain. The exception is the Sunrise B period, which does not require community authentication. dotgay LLC will create an extensive reserved names list consisting of potential index directory domain names, sensitive names and a wide array of common generic names in several languages. The Registry and the Internet users will later determine which words may be released as premium auction names. The Registry reserved names noted above will be excluded from all registration periods prior to General Availability. Founders The Founders period is tied to the Founders Program created by dotgay LLC, a pre-launch opportunity for members of the Gay Community to contribute financially, while reinforcing their commitment to building the .gay TLD. As is common practice in the Gay Community with new emerging organizations, Founders become stewards because of their commitment, setting the tone to build trust for future membership. Founders with and without trademarks will have the opportunity to submit requests for .gay names prior to the Sunrise Period. Requests during the Founders period are submitted directly to dotgay LLC. Resolution: Applications for domain names during the Founders Period will be distributed on a first-come⁄first serve basis and placed on the Registry reserved list of Founders Names. Sunrise The Sunrise period will consist of Sunrise A (Community Trademark) and Sunrise B (Non-Community Trademark), as described below. Both periods run simultaneously and last for a minimum of 30 days. Sunrise A applications will be submitted to approved Registrars and Sunrise B requests will be submitted directly to dotgay LLC through the provided online process, or another process outlined at a later date when details about how the Trademark Clearinghouse will operate are revealed. • Sunrise A – Community Trademark – The opportunity for authenticated community members (who have obtained a CIC) registered in the Trademark Clearinghouse to submit Registration Requests for .gay names corresponding to their registered trademarks. • Sunrise B – Non-Community Trademark – The opportunity for those who are not members of the Gay Community to submit requests for names corresponding to their trademarks, as registered in the Trademark Clearinghouse, to be added to the Registry Sunrise B Reserved names list. A nominal fee will be charged for successful Sunrise B requests, to cover the cost of the Trademark Clearinghouse inquiry (amount TBD) and Registry administration fee (TBD). Registry will publish a complete list of names from Sunrise B that have been reserved. Reserved names will not result in a Registration in the .gay TLD, and will convey no other rights to successful Sunrise B applicants. Community authentication is not required for Sunrise B. Resolution: Multiple applications for a particular domain name during Sunrise A will be resolved with an auction in the Sunrise Auction period. Sunrise A applications will trump all Sunrise B applications, meaning that if there is a viable Sunrise A and B applicant then the Sunrise A applicant will be awarded the name. Multiple Sunrise B applications do not require any prioritization. NOTE: dotgay LLC reserves the right to release Sunrise B reserved domain names for registration if an authenticated community member with a trademark (corresponding to the name) included in the Trademark Clearinghouse requests so in writing to dotgay LLC. Sunshine The Sunshine period is designed to give community members with registrations obtained before May 1, 2012 on other IANA-recognized TLDs, an opportunity to become part of the .gay domain prior to General Availability. This period follows the conclusion of the Sunrise period and is designed to provide a protection for existing community domain names. Applications received during Sunshine require a CIC and are treated as received at the same time. Resolution: Multiple applications for the same name during Sunshine will be resolved by an auction in the Sunshine Auction period. Premium Name Auction Premium Name Auction periods will take place periodically as scheduled by dotgay LLC, as early as the conclusion of the Sunshine Period. Premium Name auctions include domains reserved by dotgay LLC specifically for sale during Premium Name Auctions to those who have obtained a CIC. Resolution: All premium name auctions will be awarded to the highest bidder. Land Rush The Land Rush period opens following the conclusion of the Sunshine period and will serve as an opportunity for community members who have obtained a CIC to apply for any available name they are entitled to apply for. Applications received during Land Rush are treated as received at the same time. Resolution: Multiple applications received during Land Rush for a particular domain will be resolved by an auction in the Land Rush Auction period. General Availability The General Availability Period will follow the conclusion of the Land Rush Period and will serve as an opportunity for community members who have obtained a CIC to apply for any available name. Resolution: Applications for domain names during the General Availability will be distributed on a first-come⁄first serve basis. 18(c)ii dotgay LLC does not intend to implement any cost benefits for registrants, such as discounts or bulk rates. All pricing will stem from standardized wholesale rates. As a community-based initiative, the .gay TLD is designed to address the needs of the Gay Community by using a ‘pay it back to the community’ strategy around achieving cost benefits for its registrants. Registrations in the .gay TLD contribute to a community resource from which registrants can ultimately benefit in ways that extend beyond a financial saving on the domain name itself, including progress in the areas of social services and social change. The benefits for registrants will also be realized over the long-term. dotgay LLC views a certain monetary “entry barrier” into the second level as a healthy instrument to prevent unnecessary drain of the available namespace and in order to preserve availability for future years to come. Registrants in financial strain will be able to obtain less expensive third level registrations on index domain names. An indirect cost benefit for registrants will be realized through the incentive program designed as a commission for the essential community support organizations serving as dotgay LLC’s Authentication Partners. This is an exclusive offering to Authentication Partners as described below and based on the uniqueness of the Gay Community, and their needs. Uniqueness of the .gay TLD Unique to the .gay TLD is the challenge of identifying eligible community members and garnering their trust to participate. Because the Gay Community is not always visible and because the Gay Community is still healing (and in some cases still suffering) from prejudice and injustice, the task of outreach and engagement remains difficult, except when initiated from within the community. Understanding the landscape of the Gay Community and approaching registrants from a trusted source is mandatory to the registration process. dotgay LLC does not believe that standard practice used in marketing existing TLDs can be applied to the .gay TLD. Establishing entry points that are linked into the Gay Community and seen as trusted sources remains critical to the .gay community-based model. Through the use of established membership organizations in the Gay Community as Authentication Partners, dotgay LLC not only complies with the most restrictive community registration requirements, but also provides the best solution for connecting with potential registrants. Authentication Partners are the community membership organizations used by dotgay LLC to confirm eligibility. Authentication Partners become advocates for the .gay TLD and provide a trusted entry point for members of the community. Authentication Partners are also the advocates for their registrants within the .gay community-model. Eligibility is required of all registrants of the .gay TLD, so the first step of registration begins with the acquisition of a Community Identifier Code (CIC) through one of the Authentication Partners. As dotgay LLC will utilize a uniquely innovative and targeted marketing plan via the Authentication Partners, it will create a more strategic and cost effective approach to seeking out registrants. The majority of potential registrants will ultimately be driven by dotgay LLC and the Authentication Partners to the registrars. No pricing discounts for registrars will be offered initially. The registrars that meet dotgay LLC requirement for handling name registrations for .gay will not need to put the same necessary efforts into marketing .gay as with other TLDs, but will benefit from the Authentication Partner network created by dotgay LLC to drive registrations. Registrars will also benefit greatly from the level of trust that dotgay LLC bestows upon them as an approved registrar for the .gay TLD. Because Authentication Partners offer the direct link to eligible registrants through their membership base, dotgay LLC will focus on incentive programs that reward the Authentication Partners for each confirmed registration. Committed to an overall community-based approach to the .gay TLD, dotgay LLC feels it is essential to integrate and channel financial support back into the Gay Community wherever possible. Authentication Partner Incentive Program dotgay LLC’s Authentication Partner Incentive Program is intended to catapult growth in the early years of operation and fulfill the intended mission. Authentication Partners will be compensated for engaging their membership base with registrations in the .gay TLD while assisting in building out the index directory that will become a vital resource for the Gay Community globally. By providing an opportunity to strengthen and financially support the Authentication Partners who have served as the foundation of the Gay Community in their regions, dotgay LLC will provide a separate and distinct way of funding the Gay Community beyond the dotgay Foundation discussed in the mission outlined in 18(a) above. Registrants who are members of multiple Authentication Partners will also have the option to choose which Authentication Partner receives credit for their registration by using them to acquire their CIC, giving registrants a choice of which organizations receive the credit. 18(c)iii With the understanding that names on the .gay TLD will be sold at an initial premium wholesale price, it will be the goal of dotgay LLC to avoid any price escalation in the foreseeable future. It is dotgay LLC’s commitment that the wholesale cost of second and third level names will not increase during the five years that follow the beginning of the Sunrise period. At the conclusion of the initial five year period, dotgay LLC reserves the right to, but is not required to, introduce a wholesale price increase at both second and third level on an annual basis with prior written notice as required by ICANN. The price escalation –if ever required- will not exceed 5% per year.
20(a). Provide the name and full description of the community that the applicant is committing to serve. If this application is included in a community priority evaluation, it will be scored based on the community identified in response to this question.
Name and full description of the community dotgay LLC is committed to serving the Gay Community. The Gay Community is a community centered on individuals whose gender identities  and sexual orientation  are outside of the norms defined for heterosexual behavior of the larger society. The Gay Community includes individuals who identify themselves as male or female homosexuals, bisexual, transgender, queer, intersex, ally and many other terminology - in a variety of languages - that has been used at various points to refer most simply to those individuals who do not participate in mainstream cultural practices pertaining to gender identity, expression and adult consensual sexual relationships. The Gay Community has also been referred to using the acronym LGBT, and sometimes the more inclusive LGBTQIA . The most common and globally understood term - used both by members of the Gay Community and in the world at large - is however “Gay”. Delineation The membership criterion to join the Gay Community is the process of ‘coming out’. This process is unique for every individual, organization and ally involving a level of risk in simply becoming visible. While this is sufficient for the world at large in order to delineate more clearly, dotgay LLC is also requiring community members to have registered with one of our Authenticating Partners (process described in 20E). The Authentication Partners are the result of a century or more of community members voluntarily grouping themselves into gay civic organizations. Membership in the Gay Community is not restricted by any geographical boundaries and is united by a common interest in human rights. How the community is structured and organized While there isn’t a hierarchical structure that organizes the community, there is a cooperating loose mesh of organizations that represent the diverse segments and various interests of the Gay Community, often created to work towards ending discrimination of the Gay Community. The following examples will help to provide further understanding of representing organizations: Discrimination in the workplace; Resulted in the creation of organizations to advocate for gay employees including: Out & Equal (USA), Parks Diversity (Italy), OutServe (USA Military employee group). Discrimination in the travel industry; Resulted in the creation of organizations to identify safe space and promote gay travel including: International Gay & Lesbian Travel Association (IGLTA), Travel Gay Canada, Brazilian Gay & Lesbian Travel Association. Discrimination in the marketplace; Resulted in the creation of organizations to promote gay business including: Canadian Gay & Lesbian Chamber of Commerce, National Gay Lesbian Chamber of Commerce (USA), Argentina Gay and Lesbian Chamber of Commerce. Discrimination in sports; Resulted in the creation of gay sports teams and leagues including: Federation of Gay Games (FGG), Gay and Lesbian International Sport Association (GLISA). Discrimination in human rights; Resulted in the creation of organizations including the International Lesbian, Gay, Bisexual, Trans and Intersex Association (ILGA), Federacion Estatal de Lesbianas Gays Transexuales y Bisexuales (Spain), Lesben und Schwulenverband in Deutschland (Germany). Discrimination in social services; Resulted in the formation of Gay Community centers and service organizations including: CenterLink (community center support), Parents, Families, and Friends of Lesbians and Gays (ally support), Trans-Fuzja Foundation (transgender support), Broadway Cares Equity Fights AIDS (HIV⁄AIDS support), Lambda Legal (legal services) and the Trevor Project (teen suicide prevention). Discrimination in media; Resulted in the formation of organizations including: Gay Lesbian Alliance Against Defamation (GLAAD), National Lesbian and Gay Journalist Association (NLGJA). It is these exact organizations that form the cooperating loose mesh of organizations that serve as the foundation of the Gay Community and enable it to structure and organize efforts. When the community was established While gay individuals have always existed, visibility of these individuals only began in the 19th century. One of the first movements for the human rights of the Gay Community was initiated by Magnus Hirschfeld (Scientific Humanitarian Committee, 1897). In the 20th century a sense of community continued to emerge through the formation of the first incorporated gay rights organization (Chicago Society for Human Rights, 1924). In the ensuing years additional organizations continued to emerge, but it was a watershed event in the streets of New York City that would kick-started what would become known as the modern gay rights movement. At the Stonewall Bar in New York City’s Greenwich Village in June 1969 male and female homosexuals, bisexual, transgendered, intersexed and allied patrons fought back against routine police raids on gay bars in the Village and the events of that evening spiraled into several nights of riots in the streets. The ensuing mayhem helped not only galvanize the Gay Community and moved many individuals out of the dark bars and into the comparatively brighter streets, but resulted in global media coverage that had the unintended effect of both launching the modern gay rights movement and connecting gay individuals around the world to a larger Gay Community. For those gays living in remote parts not only of the US but of the world, knowledge of an angry mob of gays in New York City gave otherwise isolated individuals a community to finally identify with. To commemorate the anniversary of Stonewall, three American cities organized “gay pride” demonstrations one year later. At this writing hundreds of gay pride celebrations occur around the world and an international organization of Pride Organizers called InterPride has been created. Along with other global gay organizations InterPride is one of dotgay LLC’s Authentication Partners linking dotgay LLC to the origins of the modern global gay community. This is just one of the many timelines that can be drawn in Gay Community history. Each of the organizations endorsing dotgay LLC has a similar record of activities in the organization of the community. Estimated size of the community As stated above, the Gay Community is global. Since the Gay Community is self-identifying, it becomes a difficult challenge to measure accurate statistics using tradition standards. Most studies place the global gay population at 1.2% (Williams 1996), higher in countries with existing gays rights protections projected at 4-6% (eg. Australia, Canada, United Kingdom, United States). Rather than projecting the size of the community from these larger global statistical estimates, dotgay LLC has established a conservative plan with identified partners and endorsing organizations (listed in 20F) representing over 1,000 organizations and 7 million members. This constitutes our base line estimate for projecting the size of the Gay Community and the minimum pool from which potential registrants will stem.  “each person’s deeply felt internal and individual experience of gender, which may or may not correspond with the sex assigned at birth, including the personal sense of the body (which may involve, if freely chosen, modification of bodily appearance or function by medical, surgical or other means) and other expressions of gender, including dress, speech and mannerisms.” The Yogyakarta Principles www.yogyakartaprinciples.org⁄principles_en.pdf  “each person’s capacity for profound emotional, affectional and sexual attraction to, and intimate and relations with, individuals of a different gender or the same gender or more than one gender” The Yogyakarta Principles  LBGTQIA – Lesbian, Gay, Bisexual, Transgender, Queer, Intersex and Ally is the latest term used to indicate the inclusive regard for the extent of the Gay Community.
The applicant for the community-based .gay TLD is dotgay LLC, a company created to engage in the new gTLD program, by preparing an application designed for and supported by the Gay Community. dotgay LLC was founded in 2009 and is now under the guidance of CEO Scott Seitz, longtime advocate, entrepreneur and member of the Gay Community. Leadership Following an extensive career in fortune 500 companies, Scott began searching for opportunities to support and advocate for the Gay Community from within the corporate structure. Fueled by first-hand experience in the early days of HIV⁄AIDS, political action and corporate outreach, Scott formed SPI Marketing to create visibility for the Gay Community in the corporate world. Over 16 years, SPI has directed more than 30 million dollars into gay nonprofits and businesses. SPI prides itself on modest offices, nominal overhead, producing measurable results, and maintaining the highest ethical commitments and involvement with the Gay Community. Among the first agencies of its kind to launch in the gay market, SPI has a well-documented history and working relationship with corporations, nonprofits and small businesses, including numerous and frequent pro-bono efforts. SPI works with the Gay Community to communicate with corporations and government agencies, as well as with corporations to speak to the Gay Community. All of these activities are based on a fundamental principal of visibility through financial and verbal transactions, which has earned SPI the respect of consumers, corporations and institutions. This has resulted in a nearly two-decade relationship with the community that is based on respect and trust, garnering SPI and Scott Seitz numerous community service awards from various nonprofit organizations. SPI offers a unique vantage point and 360 degree approach to working with consumers, nonprofits, corporate and government agencies. With an ability to see many sides of the equation, understand the dynamics of the constituents and maintain an eye on trends and moving parts that ultimately affect the community, SPI found itself uniquely qualified to address the new gTLD program and mobilize with the community. Advocacy Through the longstanding commitment, efforts and experience of SPI, a natural step forward was taking on majority ownership in dotgay LLC to participate in the new gTLD program on behalf of the community. Most critical was the fact that no organizations were addressing Internet advocacy on behalf of the community, and restrictions in the area of resources and finances prevented organizations from taking on the responsibility. dotgay LLC provided the much needed focus, resources and advocacy to evaluate the gTLD program, communicate the implications and opportunities, and spearhead efforts to ensure the .gay application moved forward as a community-based initiative in service of the community. Both SPI and dotgay LLC have been recognized by the National Gay & Lesbian Chamber of Commerce as “Certified LGBT Business Enterprises,” an important acknowledgment confirming membership in the community as gay owned and operated businesses. Transparency While dotgay LLC will remain a for-profit business, many traditional nonprofit policies will be adapted to live up to a commitment of transparency and accountability. Trust is one of the most important elements required to engage the Gay Community and that trust begins inside the organizations that serve the community. dotgay LLC opened dialogue with the most influential and well-respected community organizations to surface expectations for best practice around transparency. Through endorsement and guidance from these organizations, dotgay LLC took steps to create a website where plans, strategies and support for the .gay TLD became visible to the community. dotgay LLC has always believed that transparency will be critical to the success of the .gay TLD, fully anticipating expectations from the community in the area of accountability. More specifically, dotgay LLC is committed to providing a minimum of 67% of profits from domain name registrations to the dotgay Foundation, a separate entity created after ICANN approval, with a Board of Directors that will guide redistribution of funds to support initiatives in the community. Upon ICANN approval, dotgay LLC will also establish a Registry Advisory Board (RAB), comprised of leaders in the community around the world committed to developing and evolving policy for the .gay TLD that reflects the true needs of the community. Outreach A deep understanding of the networking and operational aspects of the Gay Community was key to dotgay LLC’s ability to mobilize the community. Through established relationships and the trusted reputation of dotgay LLC’s leadership, organizations in the community very quickly began to listen, respond and engage in dotgay LLC’s outreach, participating at various levels within their capacity. As part of stewardship, dotgay LLC’s global outreach strategy focused on “hubs” within the community. This included United Nations accredited organizations representing the Gay Community and a cross section of the largest nonprofits, service units, commerce, media and human rights groups. Outreach included speaking engagements and panel discussions at conferences, email and social media campaigns, townhalls, teleconferences and in-person meetings in more than 17 countries on five continents. The hubs in the community also serve as trusted communication networks, helping to further move information about the pending Internet expansion and .gay TLD into the community around the globe. Participation With over 125 community endorsements, representing hundreds of organizations and 7+ million members of the community in more than 110 countries, the Gay Community has voiced their support for the .gay TLD through participation. dotgay LLC will continue to seek participation beyond the application deadline and update endorsements online at www.dotgay.com. dotgay LLC and the team of Internet consultants enlisted to guide the .gay application were complimented with participation from leadership in the community. Community perspective was provided across a variety of segments, cultures and regions of the world. The dotgay Application Advisory Group (dAAG) was formed to advise dotgay LLC during the application process. This group includes a panel of 11 community leaders from eight countries, with representation from nonprofit, human rights, commerce and equality platforms within the community. Authentication Partners (AP) will also contribute to the community participation in .gay, consisting of membership organizations that will provide service in the area of eligibility. APs will ultimately determine who is qualified to register a .gay domain name, providing the most trusted entry points into .gay and reducing risk to unqualified registrations. dotgay LLC has confirmation from several of the largest membership organizations in the community to serve as APs including; International, Lesbian, Gay, Bisexual, Trans and Intersex Assoc. (ILGA), International Gay & Lesbian Travel Assoc. (IGLTA), InterPride (global network of pride organizers), CenterLink (global network of community centers) and the gay chambers of commerce in Argentina, Canada and USA. Relations Relationships are a huge part of the collaboration to create a community-based .gay TLD and dotgay LLC is committed to those relationships with a mission of serving the needs of the community. dotgay LLC was first to take on the challenge of moving the community to create a TLD that would bring value and benefit to the community. By sharing our vision, passion and an invitation to the community to participate, the Gay Community has ultimately invited dotgay LLC to lead the initiative, evidenced through their endorsement, support and participation throughout the process.
Members of the gay community would be able to register so-called "third-level" domains that aren't based on important keywords, for a price perhaps even less than that of .com domains. Under dotgay LLC's proposal, community domains such as legal.gay, travel.gay, marriage.gay and keywest.gay would be operated as communal information hubs and thus would not be sold to third-party registrants. Second-level domains, such as visitlondon.gay, could be subject to an auction process, as there are likely to be multiple interested parties. dotgay LLC is exploring options for handling second-level domains, including possible safeguards to ensure that such domains aren't exploited to the detriment of the LGBT community.
20(d). Explain the relationship between the applied-for gTLD string and the community identified in 20(a).
Like most words in most languages, “gay” has an interesting and complicated history that moves across cultures, definitions and meanings before eventually settling on one culturally agreed upon definition, the definition that refers to the Gay Community as defined in section 20a. Etymology is an often disputed and tangled science, and “gay,” like virtually every word that originates and has been imported into the English language, has shifted meaning over time before becoming today’s word. Early uses of the word gay The Anglo-Norman gai and gaye, along with the Middle French gai was used as early as the second half of the 11th century throughout Western Europe to refer to people and incidents that ranged from happy and cheerful to those that would be described as carefree, frivolous and later even licentious, lewd and lascivious (OED). At the risk of oversimplification, the various regional variants of “gay” throughout the middle ages generally focused on “gay” as a sense relating to a variety of qualities ranging from noble and beautiful to bright, and lively (all in use in the 1300s). At a time when mass communication was non-existent, it is understandable that the same word could have so many simultaneous meanings that would vary regionally. As an example, “gay” at various moments in time would refer to “finely dressed,” simply those people who could be described as “carefree,” and to other divergent meanings ranging from the science of poetry to a description of a dog’s tail carried high and erect (OED). In the 1400s, “gay” was widely in use to refer to “Wanton, lewd, lascivious” behavior. This sense of gay as “dedicated to social pleasures” or “frivolous” and “hedonistic” behaviors helps shed light on the transition of “gay” from its earlier 12th-15th century meanings to the modern and dominant understanding of gay as both a noun and adjective referring to a specific group of individuals whose gender identities and sexual orientation are outside of the norms defined for heterosexual behavior of the larger society, and thus were judged harshly by that society. Gay used to for homosexuality As cited in the OED, “Gay by the early 20th century progressed to its current reference to a sexuality that was non-heterosexual. Writing in 1953, D.W. Cory explains: “In France as early as the sixteenth century the homosexual was called gaie; significantly enough, the feminine form was used to describe the male. The word made its way to England and America, and was used in print in some of the more pornographic literature after the First World War. Psychoanalysts recorded that homosexual patients were calling themselves gay in the nineteen-twenties, and certainly by the nineteen-thirties it was the most common word in use among homosexuals themselves” (qtd. in OED). Language is anything but stable and fixed. All words in all languages across the globe shift meaning over time and “gay” is certainly no exception to this rule. What this brief etymology of the term suggests however is that at least since the early 20th century “gay” had morphed from describing a serious of attributes ranging from lively, to happy, to sexually promiscuous that coalesced around a particular gender identity. Notably this transition of usage of “gay,” while commonly thought to be a US American invention was actually a global undertaking. The word “gay,” in fact, is used without any translation in a diverse set of world languages including French, Italian, Portuguese and many Spanish-speaking nations. In many other languages, including German, while a unique translation of gay exists officially, “Schwul,” absolutely all German-speaking individuals would understand the English translation “gay” and most are using it. Not surprisingly, the availability of global communications technologies, like the Internet, has made agreed-upon definitions of terms like “gay” possible. Whereas once regional, national and other localized variations would be able to survive, today’s instant and global communications infrastructure makes cohesion around particular meanings more inevitable. Gay as an umbrella term The term “gay” today is a term that has solidified around encompassing several sub-communities of individuals whose gender identities and sexual orientation are outside of the norms defined for heterosexual behavior of the larger society. Within these sub-communities even further classifications and distinctions can be made that further classify its members but are equally comfortable identifying as gay, particularly to those outside their own sub-communities. As an example, it has become commonplace for celebrities to acknowledge their homosexuality with the now routine declaration of “Yup, I’m gay” on the cover of newsmagazines as the comedienne Ellen Degeneres did when she “came out” on the cover of TIME magazine. Notably, “gay” is used to super-identify all these groups and circumstances. Whether homosexual, bisexual, transgender, intersex or ally, all members of the Gay Community march in the “gay pride parade” read the same “gay media” and fight for the same “gay rights.” Gay has become the prevalent term in how members of this community refer to themselves when speaking about themselves as demonstrated by the large number of organizations that use the term globally. Gay means gay While it is true that “gay” has at various points in history signified other meanings, the current definition is not only the most prominent and widely used, but also the most stable that indicates permanence and longevity. Not only are other uses of the term gay archaic (e.g. the gay nineties), they also do not name any communities. When references are made to the Gay Community, there can be not confusion for any other possible meaning of the term. At the present time the string “gay” when used as a noun is understood to indicate a member of the Gay Community (as defined in section 20a) and has no other meaning. This is not only true in the English language it is true in all other languages where the word gay is used to indicate a member of the Gay Community. As a word in the modern lexicon, the word gay has only one meaning as a noun – to be a member of the Gay Community. As an adjective, however, it still has meanings that have largely slipped into archaic or historic use. To understand other possible meetings of the term in the English language, one needs to test using substitution as is often done in language theory (eg. can the word ‘happy’ be substituted for the word ‘gay’ in the normal sentence). When one utters the phrase ‘I think he is gay’ one cannot assume the substituted ‘I think he is happy’. And if there were to be any question, it would be followed up with something such as: do you mean gay as in ‘gay’ or do you mean gay as in ‘happy’? The initial presumption is that gay refers to a member of the Gay Community. Additionally while there are a few historical references such as Gay Nineties – reference to the 1890s, there are very few remaining uses, and there is no chance of the term being misunderstood in the context of gTLD usage. In the context of new gTLD applications, the name does not have any connotation beyond the Gay Community. The idea that one would look at a domain such as lawyer.gay or health.gay and misunderstand that to mean lawyer.happy or health.happy is inconceivable. OED – Oxford English Dictionary
20(e). Provide a description of the applicant's intended registration policies in support of the community-based purpose of the applied-for gTLD. Policies and enforcement mechanisms are expected to constitute a coherent set.
.gay Registration Policies • All registrants will be required to authenticate and obtain a Community Identifier Code (CIC) through an Authentication Partner in order to register or renew .gay domain names. • One CIC will permit the registration of one domain name on the .gay TLD. • All domain names at all levels within the .gay domain name space must abide by all applicable dotgay LLC policies. • Data supplied during the authentication process will be protected, not sold and used exclusively by dotgay LLC for the purposes for which it was collected. • dotgay LLC will adhere to all name selection restrictions that flow from ICANN policies and contracts. • The registrant agreement will contain the following representations from the registrant: - They have a valid association to the name - They are not selecting a name in bad faith or for malicious use - They are not engaging in cybersquatting activity in which the goal is to obtain desirable names for the purpose of generating profit or other advantage. - They are not engaging in speculative registration activity for the purpose of reselling domains or parking the names for traffic. • Breach of registrant agreement, or representations made in that agreement, will subject the registrant to the Registry Policies Dispute Resolution Procedure (RPDRP) and may result in dotgay LLC revoking the ineligible names. • dotgay LLC will host an online process to submit recommendations for names that should be reserved prior to Sunrise including: - Community relevant key word domain names for the index directory - Domain names for premium auctions - Sensitive words or phrases that incite or promote discrimination or violent behavior, including anti-gay hate speech • Third level name registrations will be made available on select index domain names. • Registry reserves the right to review and reject any third level registration requests. • dotgay LLC will have an established policy regarding adult content. Eligibility .gay is restricted to members of the Gay Community. Eligibility is determined through formal membership with any of dotgay LLC’s Authentication Partners (AP) from the community. Early organizations of the Gay Community provided “safe places” during a period in history when community members became empowered to step out of the closet. They created a trusted network of community members sharing a common ambition; from gay rights to a response around the AIDS epidemic. Individuals who willingly associated themselves with these organizations affirmed themselves as members of the community. As the foundation of the community, membership organizations are the single most visible entry point to the Gay Community around the world. They serve as ”hubs” and are recognized as definitive qualifiers for those interested in affirming their membership in the community. The organizations range from serving health, social and economic needs to those more educational and political in nature; with each having due process around affirming status in the community. In keeping with standards currently acknowledged and used within the community, dotgay LLC will utilize membership organizations as APs to confirm eligibility. APs must meet and maintain the following requirements for approval by dotgay LLC: 1. Have an active and reputable presence in the Gay Community 2. Have a mission statement that incorporates a focus specific to the Gay Community 3. Have an established policy that affirms community status for member enrolment 4. Have a secure online member login area that requires a username & password, or other secure control mechanism. dotgay LLC will work within the community to identify and approve APs that meet the above requirements, providing as many opportunities for the community to participate as possible. A complete list of APs will be provided when .gay is placed in the root and the list will be maintained and updated as APs are added or removed. APs will be reviewed by dotgay LLC on a periodic basis (eg. every 1-3 years) to ensure they meet all requirements. dotgay LLC will provide APs with the means of allocating CICs required to register names on .gay. Name Selection Registerable names on .gay Community members that have received a CIC as per the requirements set forth in Eligibility will be permitted to register second-level names that are: 1. Not words or phrases that incite or promote discrimination or violent behavior, including anti-gay hate speech. 2. In accordance with the ICANN-related name restrictions outlined in Specification 5 of the Registry agreement (unless otherwise expressly authorized in writing by ICANN). 3. Not part of the Registry-defined reserved lists outlined below; a. Index words. Words designated for the index directory. b. Founders names. These are names that are reserved for Founders of .gay as outlined in 18(c)(i). They will remain reserved only until they are registered by the Founders, either at the beginning or the end of the Sunrise period accordingly. c. Sunrise B names. Includes names from Sunrise B as outlined on 18(c)(i). d. Registry Designated names. Includes names designated by dotgay LLC for use in operation of the Registry. e. Premium Auction names. Names reserved for auctions conducted by dotgay LLC, including generic words. f. Sensitive names. Names that the Registry Advisory Board (RAB) may recommend be reserved by dotgay LLC because they are deemed sensitive on .gay, including words or phrases that incite or promote discrimination or violent behavior. Content & Use: Content & Use Restrictions • dotgay LLC will make best efforts to prevent incitement to or promotion of real or perceived discrimination based upon race, color, gender, sexual orientation or gender expression, ethnicity, religion or national origin, or other similar types of discrimination that violate generally accepted legal norms recognized under principles of international law. • Registrants are not permitted to give non-community members access to sub-level domains. • dotgay LLC will use web metasearch technology to help determine that policies are adhered to at all levels. Enforcement: Investigation Practices & Mechanisms Registry will utilize an Ombudsman function to be the initial point of contact for reports, including complaints, disputes and matters related to abuse of policy. The Office of the Ombudsman (OTO) will be responsible for receiving and evaluating all such reports, including those from law enforcement and governmental and quasi-governmental agencies. Registry will use a Community Watch mechanism, wherein the members of the community can easily report any infraction of Registry policies. A web-based reporting system established by the Registry will be the suggested method of contact for all matters related to enforcement. The OTO will be responsible for investigating all such reports. To the extent possible, all communications between the Registry, claimants and registrants regarding enforcement matters will be conducted electronically, however at the discretion of the OTO other methods of communication may be used. The Ombudsman function will also have within its responsibility, creation and management of a statistical method of sampling adherence to the policies of the Registry. The Ombudsman function will be responsible for periodic reporting on the statistics related to complaints, enforcement and solutions. Reporting will ultimately be addressed by one of the following enforcement agents, using the appropriate dispute resolution policy. Matters that cannot be resolved by the OTO will be referred to the appropriate dispute resolution process. The Registry will be bound by the decisions made by the dispute resolution processes. Resources Allocated to Enforcement • Ombudsman ○Registry provided independent agent or agents ○Attempts to resolve issues amicably between complainant and registrant ○Acknowledges and documents all Registry related reports and resolutions ○Administers notifications and warnings related to Registry policy ○Reports to Registry when policy violations are not corrected in the required time ○As required by due process and ICANN rules, cooperates with law enforcement, privacy protection regulations and other regulatory frameworks ○Redirect complaints that cannot be resolved by the OTO, to the appropriate dispute resolution process. -Uniform Dispute Resolution Policy (UDRP) as defined by ICANN -Uniform Rapid Suspension (URS) as defined by ICANN -Registry Restrictions Dispute Resolution Procedures (RRDRP) as defined by ICANN -Trademark Post Delegation Dispute Resolution Procedure (Trademark PDDRP) as defined by ICANN -Registry Policies Dispute Resolution Procedure (RPDRP) as defined below. • Registry Policies Dispute Resolution Procedure (RPDRP) ○The RPDRP is similar to the RRDRP except that it is responsible for resolving all disputes concerning Registry established policies, such as naming policy. Appeals Mechanism Registrants who have not been successful in Registry policy dispute resolution will have the one-time opportunity to make a reconsideration appeal around the policy decision. The reconsideration appeal will be through an online appeal mechanism provided by the Registry. Reconsideration appeals must include a stated reason for request of reconsideration. Any Registrant taken down or suspended for a Registry related violation will also have the option to submit an appeal for reinstatement. Registrants will submit appeals directly with the RPDRP appointed dispute resolution provider. All claimants must follow the online appeal process provided by the appointed dispute resolution provider.
20(f). Attach any written endorsements from institutions/groups representative of the community identified in 20(a). An applicant may submit endorsements by multiple institutions/groups, if relevant to the community.
See LGBT Endorsements
21(b). If a geographic name, attach documentation of support or non-objection from all relevant governments or public authorities.
Does not apply.
Protection of Geographic Names
22. Describe proposed measures for protection of geographic names at the second and other levels in the applied-for gTLD. This should include any applicable rules and procedures for reservation and/or release of such names.
Geographical names predetermined to require protection will initially be reserved at the second level and at all other levels within the .gay TLD at which the Registry provides for registrations. This includes all two-character labels, country and territory names included in Specification 5 of the Registry agreement with ICANN. According to the Applicant Guidebook “the rules for release can be developed or agreed to by governments, the GAC, and⁄or approved ICANN after a community discussion.” Registry initially proposes the following procedure but reserves the right to later introduce additional procedures in case agreement can be reached with governments, the GAC, and⁄or ICANN. Rules for release of Geographical Names The following rules are suggested for requests pertaining to the release of reserved geographic names: 1. Requesting registrants must meet eligibility requirements for the .gay TLD. 2. Requesting registrants must specify whether they are seeking a second or third level registrations, or any combination thereof. 3. Reserved geographical names will only be eligible for release and delegation to the government agency to which the geographical name represents. 4. Reserved geographical names in the form of two-character labels that are not currently assigned may only be released through an agreement between ICANN and Registry. 5. Requests for the release of restricted geographical names must followed the appropriate procedure outlined below. Procedures for release of Geographical Names The suggested procedure for releasing and registering an unassigned two-character label from the reserved geographical names on the .gay TLD will be as follows: 1. Confirm eligibility requirements of the .gay TLD as outlined in 20(e), which will result in the generation of a CIC. 2. The requesting registrant informs dotgay LLC of their interest to register an unassigned two-character label geographical name and provides a CIC in the request. 3. The requesting registrant will then provide the Registry with a detailed explanation of the intended purpose for the name and how it relates to the Gay Community, as well as if it is a second and⁄or third level request. 4. The Registry will consider the proposal and offer an approval or denial of the request. 5. If the two-character label geographical name request is denied, the Registry will continue to hold the requested geographical name on the reserved list. 6. If approved, the Registry will submit a request to ICANN to verify the availability of the name and seek approval for the release of the two-character label. 7. If denied by ICANN, the two-character label will remain on the reserved list. 8. If approved by ICANN, the designated beneficiary (the Registrant) will be provide with a unique Authentication code provided by the Registry to register the exact two-label character, with a Registry approved and accredited Registrar, using the Authorization code as their authority. The suggested procedures for releasing and registering all other reserved geographical names on the .gay TLD will be as follows: 1. Confirm eligibility requirements of the .gay TLD as outlined in 20(e), which will result in the generation of a CIC. 2. The Government or relevant public authority related to a geographical name informs the GAC Secretariat of their request to register the geographical name, and the designated beneficiary. 3. The GAC Secretariat authenticates the request and transfers it to ICANN and to the Registry to verify the CIC and availability of the name. 4. The Government or public authority will then provide the Registry with a detailed explanation of the intended purpose for the name and how it relates to the gay community, as well as if it is a second and⁄or third level request. 5. The Registry will consider the proposal and offer an approval or denial of the request. 6. If the geographical name request is denied, the Registry will continue to hold the requested geographical name on the reserved list. 7. If approved, the Registry will issue a unique Authentication code to register the exact geographical name, with a Registry approved and accredited Registrar, using the Authorization code as their authority.
23. Provide name and full description of all the Registry Services to be provided. Descriptions should include both technical and business components of each proposed service, and address any potential security or stability concerns. The following registry services are customary services offered by a registry operator: A. Receipt of data from registrars concerning registration of domain names and name servers. B. Dissemination of TLD zone files. C. Dissemination of contact or other information concerning domain name registrations (Whois service). D. Internationalized Domain Names, where offered. E. DNS Security Extensions (DNSSEC). The applicant must describe whether any of these registry services are intended to be offered in a manner unique to the TLD. Additional proposed registry services that are unique to the registry must also be described.
23.1 Introduction dotgay LLC has elected to partner with NeuStar, Inc (Neustar) to provide back-end services for the .gay registry. In making this decision, dotgay LLC recognized that Neustar already possesses a production-proven registry system that can be quickly deployed and smoothly operated over its robust, flexible, and scalable world-class infrastructure. The existing registry services will be leveraged for the .gay registry. The following section describes the registry services to be provided. 23.2 Standard Technical and Business Components Neustar will provide the highest level of service while delivering a secure, stable and comprehensive registry platform. dotgay LLC will use Neustarʹs Registry Services platform to deploy the .gay registry, by providing the following Registry Services (none of these services are offered in a manner that is unique to .gay): -Registry-Registrar Shared Registration Service (SRS) -Extensible Provisioning Protocol (EPP) -Domain Name System (DNS) -WHOIS -DNSSEC -Data Escrow -Dissemination of Zone Files using Dynamic Updates -Access to Bulk Zone Files -Dynamic WHOIS Updates -IPv6 Support -Rights Protection Mechanisms -Internationalized Domain Names (IDN). The following is a description of each of the services. 23.2.1 SRS Neustarʹs secure and stable SRS is a production-proven, standards-based, highly reliable, and high-performance domain name registration and management system. The SRS includes an EPP interface for receiving data from registrars for the purpose of provisioning and managing domain names and name servers. The response to Question 24 provides specific SRS information. 23.2.2 EPP The .gay registry will use the Extensible Provisioning Protocol (EPP) for the provisioning of domain names. The EPP implementation will be fully compliant with all RFCs. Registrars are provided with access via an EPP API and an EPP based Web GUI. With more than 10 gTLD, ccTLD, and private TLDs implementations, Neustar has extensive experience building EPP-based registries. Additional discussion on the EPP approach is presented in the response to Question 25. 23.2.3 DNS dotgay LLC will leverage Neustarʹs world-class DNS network of geographically distributed nameserver sites to provide the highest level of DNS service. The service utilizes Anycast routing technology, and supports both IPv4 and IPv6. The DNS network is highly proven, and currently provides service to over 20 TLDs and thousands of enterprise companies. Additional information on the DNS solution is presented in the response to Questions 35. 23.2.4 WHOIS Neustarʹs existing standard WHOIS solution will be used for the .gay. The service provides supports for near real-time dynamic updates. The design and construction is agnostic with regard to data display policy is flexible enough to accommodate any data model. In addition, a searchable WHOIS service that complies with all ICANN requirements will be provided. The following WHOIS options will be provided: Standard WHOIS (Port 43) Standard WHOIS (Web) Searchable WHOIS (Web) 23.2.5 DNSSEC An RFC compliant DNSSEC implementation will be provided using existing DNSSEC capabilities. Neustar is an experienced provider of DNSSEC services, and currently manages signed zones for three large top level domains: .biz, .us, and .co. Registrars are provided with the ability to submit and manage DS records using EPP, or through a web GUI. Additional information on DNSSEC, including the management of security extensions is found in the response to Question 43. 23.2.6 Data Escrow Data escrow will be performed in compliance with all ICANN requirements in conjunction with an approved data escrow provider. The data escrow service will: -Protect against data loss -Follow industry best practices -Ensure easy, accurate, and timely retrieval and restore capability in the event of a hardware failure -Minimizes the impact of software or business failure. Additional information on the Data Escrow service is provided in the response to Question 38. 23.2.7 Dissemination of Zone Files using Dynamic Updates Dissemination of zone files will be provided through a dynamic, near real-time process. Updates will be performed within the specified performance levels. The proven technology ensures that updates pushed to all nodes within a few minutes of the changes being received by the SRS. Additional information on the DNS updates may be found in the response to Question 35. 23.2.8 Access to Bulk Zone Files dotgay LLC will provide third party access to the bulk zone file in accordance with specification 4, Section 2 of the Registry Agreement. Credentialing and dissemination of the zone files will be facilitated through the Central Zone Data Access Provider. 23.2.9 Dynamic WHOIS Updates Updates to records in the WHOIS database will be provided via dynamic, near real-time updates. Guaranteed delivery message oriented middleware is used to ensure each individual WHOIS server is refreshed with dynamic updates. This component ensures that all WHOIS servers are kept current as changes occur in the SRS, while also decoupling WHOIS from the SRS. Additional information on WHOIS updates is presented in response to Question 26. 23.2.10 IPv6 Support The .gay registry will provide IPv6 support in the following registry services: SRS, WHOIS, and DNS⁄DNSSEC. In addition, the registry supports the provisioning of IPv6 AAAA records. A detailed description on IPv6 is presented in the response to Question 36. 23.2.11 Required Rights Protection Mechanisms dotgay LLC, will provide all ICANN required Rights Mechanisms, including: -Trademark Claims Service -Trademark Post-Delegation Dispute Resolution Procedure (PDDRP) -Registration Restriction Dispute Resolution Procedure (RRDRP) -UDRP -URS -Sunrise service. More information is presented in the response to Question 29. 23.2.12 Internationalized Domain Names (IDN) IDN registrations are provided in full compliance with the IDNA protocol. Neustar possesses extensive experience offering IDN registrations in numerous TLDs, and its IDN implementation uses advanced technology to accommodate the unique bundling needs of certain languages. Character mappings are easily constructed to block out characters that may be deemed as confusing to users. A detailed description of the IDN implementation is presented in response to Question 44. 23.3 Unique Services The .gay Registry will initially reserve an extensive list of domain names as part of the Registry-defined reserved list. It will contain –but is not limited to– potential premium auction domains, registration prohibited domains, potential index directory domains, Sunrise B domains, and recently expired domains. The .gay Registry will route a subset of the Registry-defined reserved list to an automated, but not monetized landing page which will enable the community to: • Engage in the identification of the index directory • Identify prohibited domains and • Request to be notified about the upcoming event of the availability of a certain domain that registrants are interested in registering. 23.4 Security or Stability Concerns All services offered are standard registry services that have no known security or stability concerns. Neustar has demonstrated a strong track record of security and stability within the industry.
DEMONSTRATION OF TECHNICAL & OPERATIONAL CAPABILITY (EXTERNAL)
24. Shared Regisration System (SRS) Performance: describe the plan for operation of a robust and reliable Shared Registration System. SRS is a critical registry function for enabling multiple registrars to provide domain name registration services in the TLD.
24.1 Introduction dotgay LLC has partnered with NeuStar, Inc (ʺNeustarʺ), an experienced TLD registry operator, for the operation of the .gay Registry. The applicant is confident that the plan in place for the operation of a robust and reliable Shared Registration System (SRS) as currently provided by Neustar will satisfy the criterion established by ICANN. Neustar built its SRS from the ground up as an EPP based platform and has been operating it reliably and at scale since 2001. The software currently provides registry services to five TLDs (.BIZ, .US, TEL, .CO and .TRAVEL) and is used to provide gateway services to the .CN and .TW registries. Neustarʹs state of the art registry has a proven track record of being secure, stable, and robust. It manages more than 6 million domains, and has over 300 registrars connected today. The following describes a detailed plan for a robust and reliable SRS that meets all ICANN requirements including compliance with Specifications 6 and 10. 24.2 The Plan for Operation of a Robust and Reliable SRS 24.2.1 High-level SRS System Description The SRS to be used for .gay will leverage a production-proven, standards-based, highly reliable and high-performance domain name registration and management system that fully meets or exceeds the requirements as identified in the new gTLD Application Guidebook. The SRS is the central component of any registry implementation and its quality, reliability and capabilities are essential to the overall stability of the TLD. Neustar has a documented history of deploying SRS implementations with proven and verifiable performance, reliability and availability. The SRS adheres to all industry standards and protocols. By leveraging an existing SRS platform, dotgay LLC is mitigating the significant risks and costs associated with the development of a new system. Highlights of the SRS include: -State-of-the-art, production proven multi-layer design -Ability to rapidly and easily scale from low to high volume as a TLD grows -Fully redundant architecture at two sites -Support for IDN registrations in compliance with all standards -Use by over 300 Registrars -EPP connectivity over IPv6 -Performance being measured using 100% of all production transactions (not sampling). 24.2.2 SRS Systems, Software, Hardware, and Interoperability The systems and software that the registry operates on are a critical element to providing a high quality of service. If the systems are of poor quality, if they are difficult to maintain and operate, or if the registry personnel are unfamiliar with them, the registry will be prone to outages. Neustar has a decade of experience operating registry infrastructure to extremely high service level requirements. The infrastructure is designed using best of breed systems and software. Much of the application software that performs registry-specific operations was developed by the current engineering team and a result the team is intimately familiar with its operations. The architecture is highly scalable and provides the same high level of availability and performance as volumes increase. It combines load balancing technology with scalable server technology to provide a cost effective and efficient method for scaling. The Registry is able to limit the ability of any one registrar from adversely impacting other registrars by consuming too many resources due to excessive EPP transactions. The system uses network layer 2 level packet shaping to limit the number of simultaneous connections registrars can open to the protocol layer. All interaction with the Registry is recorded in log files. Log files are generated at each layer of the system. These log files record at a minimum: -The IP address of the client -Timestamp -Transaction Details -Processing Time. In addition to logging of each and every transaction with the SRS Neustar maintains audit records, in the database, of all transformational transactions. These audit records allow the Registry, in support of the applicant, to produce a complete history of changes for any domain name. 24.2.3 SRS Design The SRS incorporates a multi-layer architecture that is designed to mitigate risks and easily scale as volumes increase. The three layers of the SRS are: -Protocol Layer -Business Policy Layer -Database. Each of the layers is described below. 24.2.4 Protocol Layer The first layer is the protocol layer, which includes the EPP interface to registrars. It consists of a high availability farm of load-balanced EPP servers. The servers are designed to be fast processors of transactions. The servers perform basic validations and then feed information to the business policy engines as described below. The protocol layer is horizontally scalable as dictated by volume. The EPP servers authenticate against a series of security controls before granting service, as follows: -The registrarʹs host exchanges keys to initiates a TLS handshake session with the EPP server. -The registrarʹs host must provide credentials to determine proper access levels. -The registrarʹs IP address must be preregistered in the network firewalls and traffic-shapers. 24.2.5 Business Policy Layer The Business Policy Layer is the brain of the registry system. Within this layer, the policy engine servers perform rules-based processing as defined through configurable attributes. This process takes individual transactions, applies various validation and policy rules, persists data and dispatches notification through the central database in order to publish to various external systems. External systems fed by the Business Policy Layer include backend processes such as dynamic update of DNS, WHOIS and Billing. Similar to the EPP protocol farm, the SRS consists of a farm of application servers within this layer. This design ensures that there is sufficient capacity to process every transaction in a manner that meets or exceeds all service level requirements. Some registries couple the business logic layer directly in the protocol layer or within the database. This architecture limits the ability to scale the registry. Using a decoupled architecture enables the load to be distributed among farms of inexpensive servers that can be scaled up or down as demand changes. The SRS today processes over 30 million EPP transactions daily. 24.2.6 Database The database is the third core components of the SRS. The primary function of the SRS database is to provide highly reliable, persistent storage for all registry information required for domain registration services. The database is highly secure, with access limited to transactions from authenticated registrars, trusted application-server processes, and highly restricted access by the registry database administrators. A full description of the database can be found in response to Question 33. Figure 24-1 attached depicts the overall SRS architecture including network components. 24.2.7 Number of Servers As depicted in the SRS architecture diagram above Neustar operates a high availability architecture where at each level of the stack there are no single points of failures. Each of the network level devices run with dual pairs as do the databases. For the .gay registry, the SRS will operate with 8 protocol servers and 6 policy engine servers. These expand horizontally as volume increases due to additional TLDs, increased load, and through organic growth. In addition to the SRS servers described above, there are multiple backend servers for services such as DNS and WHOIS. These are discussed in detail within those respective response sections. 24.2.8 Description of Interconnectivity with Other Registry Systems The core SRS service interfaces with other external systems via Neustarʹs external systems layer. The services that the SRS interfaces with include: -WHOIS -DNS -Billing -Data Warehouse (Reporting and Data Escrow). Other external interfaces may be deployed to meet the unique needs of a TLD. At this time there are no additional interfaces planned for .gay. The SRS includes an external notifier concept in its business policy engine as a message dispatcher. This design allows time-consuming backend processing to be decoupled from critical online registrar transactions. Using an external notifier solution, the registry can utilize control levers that allow it to tune or to disable processes to ensure optimal performance at all times. For example, during the early minutes of a TLD launch, when unusually high volumes of transactions are expected, the registry can elect to suspend processing of one or more back end systems in order to ensure that greater processing power is available to handle the increased load requirements. This proven architecture has been used with numerous TLD launches, some of which have involved the processing of over tens of millions of transactions in the opening hours. The following are the standard three external notifiers used the SRS: 24.2.9 WHOIS External Notifier The WHOIS external notifier dispatches a work item for any EPP transaction that may potentially have an impact on WHOIS. It is important to note that, while the WHOIS external notifier feeds the WHOIS system, it intentionally does not have visibility into the actual contents of the WHOIS system. The WHOIS external notifier serves just as a tool to send a signal to the WHOIS system that a change is ready to occur. The WHOIS system possesses the intelligence and data visibility to know exactly what needs to change in WHOIS. See response to Question 26 for greater detail. 24.2.10 DNS External Notifier The DNS external notifier dispatches a work item for any EPP transaction that may potentially have an impact on DNS. Like the WHOIS external notifier, the DNS external notifier does not have visibility into the actual contents of the DNS zones. The work items that are generated by the notifier indicate to the dynamic DNS update sub-system that a change occurred that may impact DNS. That DNS system has the ability to decide what actual changes must be propagated out to the DNS constellation. See response to Question 35 for greater detail. 24.2.11 Billing External Notifier The billing external notifier is responsible for sending all billable transactions to the downstream financial systems for billing and collection. This external notifier contains the necessary logic to determine what types of transactions are billable. The financial systems use this information to apply appropriate debits and credits based on registrar. 24.2.12 Data Warehouse The data warehouse is responsible for managing reporting services, including registrar reports, business intelligence dashboards, and the processing of data escrow files. The Reporting Database is used to create both internal and external reports, primarily to support registrar billing and contractual reporting requirement. The data warehouse databases are updated on a daily basis with full copies of the production SRS data. 24.2.13 Frequency of Synchronization between Servers The external notifiers discussed above perform updates in near real-time, well within the prescribed service level requirements. As transactions from registrars update the core SRS, update notifications are pushed to the external systems such as DNS and WHOIS. These updates are typically live in the external system within 2-3 minutes. 24.2.14 Synchronization Scheme (e.g., hot standby, cold standby) Neustar operates two hot databases within the data center that is operating in primary mode. These two databases are kept in sync via synchronous replication. Additionally, there are two databases in the secondary data center. These databases are updated real time through asynchronous replication. This model allows for high performance while also ensuring protection of data. See response to Question 33 for greater detail. 24.2.15 Compliance with Specification 6 Section 1.2 The SRS implementation for .gay is fully compliant with Specification 6, including section 1.2. EPP Standards are described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. Extensible Provisioning Protocol or EPP is defined by a core set of RFCs that standardize the interface that make up the registry-registrar model. The SRS interface supports EPP 1.0 as defined in the following RFCs shown in Table 24-1 attached. Additional information on the EPP implementation and compliance with RFCs can be found in the response to Question 25. 24.2.16 Compliance with Specification 10 Specification 10 of the New TLD Agreement defines the performance specifications of the TLD, including service level requirements related to DNS, RDDS (WHOIS), and EPP. The requirements include both availability and transaction response time measurements. As an experienced registry operator, Neustar has a long and verifiable track record of providing registry services that consistently exceed the performance specifications stipulated in ICANN agreements. This same high level of service will be provided for the .gay Registry. The following section describes Neustarʹs experience and its capabilities to meet the requirements in the new agreement. To properly measure the technical performance and progress of TLDs, Neustar collects data on key essential operating metrics. These measurements are key indicators of the performance and health of the registry. Neustarʹs current .biz SLA commitments are among the most stringent in the industry today, and exceed the requirements for new TLDs. Table 24-2 compares the current SRS performance levels compared to the requirements for new TLDs, and clearly demonstrates the ability of the SRS to exceed those requirements. Their ability to commit and meet such high performance standards is a direct result of their philosophy towards operational excellence. See response to Question 31 for a full description of their philosophy for building and managing for performance. 24.3 Resourcing Plans The development, customization, and on-going support of the SRS are the responsibility of a combination of technical and operational teams, including: -Development⁄Engineering -Database Administration -Systems Administration -Network Engineering. Additionally, if customization or modifications are required, the Product Management and Quality Assurance teams will be involved in the design and testing. Finally, the Network Operations and Information Security play an important role in ensuring the systems involved are operating securely and reliably. The necessary resources will be pulled from the pool of operational resources described in detail in the response to Question 31. Neustarʹs SRS implementation is very mature, and has been in production for over 10 years. As such, very little new development related to the SRS will be required for the implementation of the .gay registry. The following resources are available from those teams: -Development⁄Engineering 19 employees -Database Administration 10 employees -Systems Administration 24 employees -Network Engineering 5 employees The resources are more than adequate to support the SRS needs of all the TLDs operated by Neustar, including the .gay registry.
25. Extensible Provisioning Protocol (EPP): provide a detailed description of the interface with registrars, including how the applicant will comply with Extensible Provisioning Protocol in the relevant RFCs, including but not limited to: RFCs 3735, and 5730-5734. Provide the EPP templates and schemas that will be used. Include resourcing plans (number and description of personnel roles allocated to this area).
25.1 Introduction dotgay LLC’s back-end registry operator, Neustar, has over 10 years of experience operating EPP based registries. They deployed one of the first EPP registries in 2001 with the launch of .biz. In 2004, they were the first gTLD to implement EPP 1.0. Over the last ten years Neustar has implemented numerous extensions to meet various unique TLD requirements. Neustar will leverage its extensive experience to ensure dotgay LLC is provided with an unparalleled EPP based registry. The following discussion explains the EPP interface which will be used for the .gay registry. This interface exists within the protocol farm layer as described in Question 24 and is depicted in Figure 25-1. 25.2 EPP Interface Registrars are provided with two different interfaces for interacting with the registry. Both are EPP based, and both contain all the functionality necessary to provision and manage domain names. The primary mechanism is an EPP interface to connect directly with the registry. This is the interface registrars will use for most of their interactions with the registry. However, an alternative web GUI (Registry Administration Tool) that can also be used to perform EPP transactions will be provided. The primary use of the Registry Administration Tool is for performing administrative or customer support tasks. The main features of the EPP implementation are: -Standards Compliance: The EPP XML interface is compliant to the EPP RFCs. As future EPP RFCs are published or existing RFCs are updated, Neustar makes changes to the implementation keeping in mind of any backward compatibility issues. -Scalability: The system is deployed keeping in mind that it may be required to grow and shrink the footprint of the Registry system for a particular TLD. -Fault-tolerance: The EPP servers are deployed in two geographically separate data centers to provide for quick failover capability in case of a major outage in a particular data center. The EPP servers adhere to strict availability requirements defined in the SLAs. -Configurability: The EPP extensions are built in a way that they can be easily configured to turn on or off for a particular TLD. -Extensibility: The software is built ground up using object oriented design. This allows for easy extensibility of the software without risking the possibility of the change rippling through the whole application. -Auditable: The system stores detailed information about EPP transactions from provisioning to DNS and WHOIS publishing. In case of a dispute regarding a name registration, the Registry can provide comprehensive audit information on EPP transactions. -Security: The system provides IP address based access control, client credential-based authorization test, digital certificate exchange, and connection limiting to the protocol layer. 25.3 Compliance with RFCs and Specifications The registry-registrar model is described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. As shown in Table 25-1, EPP is defined by the core set of RFCs that standardize the interface that registrars use to provision domains with the SRS. As a core component of the SRS architecture, the implementation is fully compliant with all EPP RFCs. Neustar ensures compliance with all RFCs through a variety of processes and procedures. Members from the engineering and standards teams actively monitor and participate in the development of RFCs that impact the registry services, including those related to EPP. When new RFCs are introduced or existing ones are updated, the team performs a full compliance review of each system impacted by the change. Furthermore, all code releases include a full regression test that includes specific test cases to verify RFC compliance. Neustar has a long history of providing exceptional service that exceeds all performance specifications. The SRS and EPP interface have been designed to exceed the EPP specifications defined in Specification 10 of the Registry Agreement and profiled in Table 25-2. Evidence of Neustar’s ability to perform at these levels can be found in the .biz monthly progress reports found on the ICANN website. EPP Toolkits Toolkits, under open source licensing, are freely provided to registrars for interfacing with the SRS. Both Java and C++ toolkits will be provided, along with the accompanying documentation. The Registrar Tool Kit (RTK) is a software development kit (SDK) that supports the development of a registrar software system for registering domain names in the registry using EPP. The SDK consists of software and documentation as described below. The software consists of working Java and C++ EPP common APIs and samples that implement the EPP core functions and EPP extensions used to communicate between the registry and registrar. The RTK illustrates how XML requests (registration events) can be assembled and forwarded to the registry for processing. The software provides the registrar with the basis for a reference implementation that conforms to the EPP registry-registrar protocol. The software component of the SDK also includes XML schema definition files for all Registry EPP objects and EPP object extensions. The RTK also includes a “dummy” server to aid in the testing of EPP clients. The accompanying documentation describes the EPP software package hierarchy, the object data model, and the defined objects and methods (including calling parameter lists and expected response behavior). New versions of the RTK are made available from time to time to provide support for additional features as they become available and support for other platforms and languages. 25.4 Proprietary EPP Extensions dotgay LLC will be implementing a pre-authentication model that requires registrants to be pre-validated and obtain a Unique Identification Number (UIN) (planned to be referred to as the Community Identifier Code or CIC) token from a verification agent which is then provided to the registry to permit a domain name registration to occur. Using an extension to the EPP create domain transaction, this token will be submitted at the time of registration. The registry will validate the token and if valid, permit the registration to proceed. Attached is the schema of the EPP extension to be used for the UIN. Neustar has implemented various EPP extensions for both internal and external use in other TLD registries. These extensions use the standard EPP extension framework described in RFC 5730. Table 25-3 provides a list of extensions developed for other TLDs. Should the .gay registry require additional EPP extensions at some point in the future, those extensions will be implemented in compliance with all RFC specifications including RFC 3735. The full EPP schema to be used in the .gay registry is attached in the document titled “EPP Schema Files.” For the .gay TLD there will be authentication of registrations via a UIN token as described above. The EPP extension required to execute this authentication is attached in the document titled “EPP Extension - Unique Identification Number.” 25.5 Resourcing Plans The development and support of EPP is largely the responsibility of the Development⁄Engineering and Quality Assurance teams. As an experience registry operator with a fully developed EPP solution, on-going support is largely limited to periodic updates to the standard and the implementation of TLD specific extensions. The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams: Development⁄Engineering – 19 employees Quality Assurance - 7 employees. These resources are more than adequate to support any EPP modification needs of the .gay registry.
26. Whois: describe how the applicant will comply with ICANN's Registry Publicly Available Registration Data (Whois) specifications for data objects, bulk access, and lookups as defined in Specifications 4 and 6 to the registry agreement. Describe how the Applicant's Registry Publicly Available Registration Data (Whois) service will comply with RFC 3912. Describe resourcing plans (number and description of personnel roles allocated to this area).
26.1 Introduction dotgay LLC recognizes the importance of an accurate, reliable, and up-to-date WHOIS database to governments, law enforcement, intellectual property holders and the public as a whole and is firmly committed to complying with all of the applicable WHOIS specifications for data objects, bulk access, and lookups as defined in Specifications 4 and 10 to the Registry Agreement. dotgay LLC’s back-end registry services provider, Neustar, has extensive experience providing ICANN and RFC-compliant WHOIS services for each of the TLDs that it operates both as a Registry Operator for gTLDs, ccTLDs and back-end registry services provider. As one of the first “thick” registry operators in the gTLD space, Neustar’s WHOIS service has been designed from the ground up to display as much information as required by a TLD and respond to a very stringent availability and performance requirement. Some of the key features of dotgay LLC’s solution include: • Fully compliant with all relevant RFCs including 3912 • Production proven, highly flexible, and scalable with a track record of 100% availability over the past 10 years • Exceeds current and proposed performance specifications • Supports dynamic updates with the capability of doing bulk updates • Geographically distributed sites to provide greater stability and performance • In addition, dotgay LLC’s thick-WHOIS solution also provides for additional search capabilities and mechanisms to mitigate potential forms of abuse as discussed below. (e.g., IDN, registrant data). 26.2 Software Components The WHOIS architecture comprises the following components: • An in-memory database local to each WHOIS node: To provide for the performance needs, the WHOIS data is served from an in-memory database indexed by searchable keys. • Redundant servers: To provide for redundancy, the WHOIS updates are propagated to a cluster of WHOIS servers that maintain an independent copy of the database. • Attack resistant: To ensure that the WHOIS system cannot be abused using malicious queries or DOS attacks, the WHOIS server is only allowed to query the local database and rate limits on queries based on IPs and IP ranges can be readily applied. • Accuracy auditor: To ensure the accuracy of the information served by the WHOIS servers, a daily audit is done between the SRS information and the WHOIS responses for the domain names which are updated during the last 24-hour period. Any discrepancies are resolved proactively. • Modular design: The WHOIS system allows for filtering and translation of data elements between the SRS and the WHOIS database to allow for customizations. • Scalable architecture: The WHOIS system is scalable and has a very small footprint. Depending on the query volume, the deployment size can grow and shrink quickly. • Flexible: It is flexible enough to accommodate thin, thick, or modified thick models and can accommodate any future ICANN policy, such as different information display levels based on user categorization. • SRS master database: The SRS database is the main persistent store of the Registry information. The Update Agent computes what WHOIS updates need to be pushed out. A publish-subscribe mechanism then takes these incremental updates and pushes to all the WHOIS slaves that answer queries. 26.3 Compliance with RFC and Specifications 4 and 10 Neustar has been running thick-WHOIS Services for over 10+ years in full compliance with RFC 3912 and with Specifications 4 and 10 of the Registry Agreement.RFC 3912 is a simple text based protocol over TCP that describes the interaction between the server and client on port 43. Neustar built a home-grown solution for this service. It processes millions of WHOIS queries per day. Table 26-1 describes Neustar’s compliance with Specifications 4 and 10. 26.4 High-level WHOIS System Description 26.4.1 WHOIS Service (port 43) The WHOIS service is responsible for handling port 43 queries. Our WHOIS is optimized for speed using an in-memory database and a master-slave architecture between the SRS and WHOIS slaves. The WHOIS service also has built-in support for IDN. If the domain name being queried is an IDN, the returned results include the language of the domain name, the domain name’s UTF-8 encoded representation along with the Unicode code page. 26.4.2 Web Page for WHOIS queries In addition to the WHOIS Service on port 43, Neustar provides a web based WHOIS application (www.whois.gay). It is an intuitive and easy to use application for the general public to use. WHOIS web application provides all of the features available in the port 43 WHOIS. This includes full and partial search on: • Domain names • Nameservers • Registrant, Technical and Administrative Contacts • Registrars. It also provides features not available on the port 43 service. These include: 1. Redemption Grace Period calculation: Based on the registry’s policy, domains in pendingDelete can be restorable or scheduled for release depending on the date⁄time the domain went into pendingDelete. For these domains, the web based WHOIS displays “Restorable” or “Scheduled for Release” to clearly show this additional status to the user. 2. Extensive support for international domain names (IDN) 3. Ability to perform WHOIS lookups on the actual Unicode IDN 4.Display of the actual Unicode IDN in addition to the ACE-encoded name 5.A Unicode to Punycode and Punycode to Unicode translator 6.An extensive FAQ 7. A list of upcoming domain deletions 26.5 IT and Infrastructure Resources As described above the WHOIS architecture uses a workflow that decouples the update process from the SRS. This ensures SRS performance is not adversely affected by the load requirements of dynamic updates. It is also decoupled from the WHOIS lookup agent to ensure the WHOIS service is always available and performing well for users. Each of Neustar’s geographically diverse WHOIS sites use: • Firewalls, to protect this sensitive data • Dedicated servers for MQ Series, to ensure guaranteed delivery of WHOIS updates • Packetshaper for source IP address-based bandwidth limiting • Load balancers to distribute query load • Multiple WHOIS servers for maximizing the performance of WHOIS service. Additional hardware details can be found in the response to Question 32. Figure 26-1 depicts the different components of the WHOIS architecture. 26.6 Interconnectivity with Other Registry System As described in Question 24 about the SRS and further in response to Question 31, “Technical Overview”, when an update is made by a registrar that impacts WHOIS data, a trigger is sent to the WHOIS system by the external notifier layer. The update agent processes these updates, transforms the data if necessary and then uses messaging oriented middleware to publish all updates to each WHOIS slave. The local update agent accepts the update and applies it to the local in-memory database. A separate auditor compares the data in WHOIS and the SRS daily and monthly to ensure accuracy of the published data. 26.7 Frequency of Synchronization between Servers Updates from the SRS, through the external notifiers, to the constellation of independent WHOIS slaves happens in real-time via an asynchronous publish⁄subscribe messaging architecture. The updates are guaranteed to be updated in each slave within the required SLA of 95% ≤ 60 minutes. Please note that Neustar’s current architecture is built towards the stricter SLAs (95% ≤ 15 minutes) of .BIZ. The vast majority of updates tend to happen within 2-3 minutes. 26.8 Provision for Searchable WHOIS Capabilities Neustar will create a new web-based service to address the new search features based on requirements specified in Specification 4 Section 1.8. The application will enable users to search the WHOIS directory using any one or more of the following fields: • Domain name • Contacts and registrant’s name • Contact and registrant’s postal address, including all the sub-fields described in EPP (e.g., street, city, state or province, etc.) • Name server name and name server IP address • The system will also allow search using non-Latin character sets which are compliant with IDNA specification. The user will choose one or more search criteria, combine them by Boolean operators (AND, OR, NOT) and provide partial or exact match regular expressions for each of the criterion name-value pairs. The domain names matching the search criteria will be returned to the user. Figure 26-2 shows an architectural depiction of the new service. To mitigate the risk of this powerful search service being abused by unscrupulous data miners, a layer of security will be built around the query engine which will allow the registry to identify rogue activities and then take appropriate measures. Potential abuses include, but are not limited to: • Data Mining • Unauthorized Access • Excessive Querying • Denial of Service Attacks To mitigate the abuses noted above, Neustar will implement any or all of these mechanisms as appropriate: • Username-password based authentication • Certificate based authentication • Data encryption • CAPTCHA mechanism to prevent robo invocation of Web query • Fee-based advanced query capabilities for premium customers. The searchable WHOIS application will adhere to all privacy rules and policies of the .gay registry. 26.9 Resourcing Plans As with the SRS, the development, customization, and on-going support of the WHOIS service is the responsibility of a combination of technical and operational teams. The primary groups responsible for managing the service include: • Development⁄Engineering – 19 employees • Database Administration – 10 employees • Systems Administration – 24 employees • Network Engineering – 5 employees Additionally, if customization or modifications are required, the Product Management and Quality Assurance teams will also be involved. Finally, the Network Operations and Information Security play an important role in ensuring the systems involved are operating securely and reliably. The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. Neustar’s WHOIS implementation is very mature, and has been in production for over 10 years. As such, very little new development will be required to support the implementation of the .gay registry. The resources are more than adequate to support the WHOIS needs of all the TLDs operated by Neustar, including the .gay registry.
27. Registration Life Cycle: provide a detailed description of the proposed registration lifecycle for domain names in the proposed gTLD. The description must explain the various registration states as well as the criteria and procedures that are used to change state. It must describe the typical registration lifecycle of create/update/delete and all intervening steps such as pending, locked, expired, and transferred that may apply. Any time elements that are involved - for instance details of add-grace or redemption grace periods, or notice periods for renewals or transfers - must also be clearly explained. Describe resourcing plans (number and description of personnel roles allocated to this area).
27.1 Registration Life Cycle Introduction .gay will follow the lifecycle and business rules found in the majority of gTLDs today. Our back-end operator, Neustar, has over ten years of experience managing numerous TLDs that utilize standard and unique business rules and lifecycles. Domain Lifecycle - Description The registry will use the EPP 1.0 standard for provisioning domain names, contacts and hosts. Each domain record is comprised of three registry object types: domain, contacts, and hosts. Domains, contacts and hosts may be assigned various EPP defined statuses indicating either a particular state or restriction placed on the object. Statuses are an integral part of the domain lifecycle and serve the dual purpose of indicating the particular state of the domain and indicating any restrictions placed on the domain. The EPP standard defines 17 statuses, however only 14 of these statuses will be used in the .gay registry per the defined .gay business rules. The following is a brief description of each of the statuses. Server statuses may only be applied by the Registry, and client statuses may be applied by the Registrar. OK – Default status applied by the Registry. Inactive – Default status applied by the Registry if the domain has less than 2 nameservers. PendingCreate – Status applied by the Registry upon processing a successful Create command, and indicates further action is pending. This status will not be used in the .gay registry. PendingTransfer – Status applied by the Registry upon processing a successful Transfer request command, and indicates further action is pending. PendingDelete – Status applied by the Registry upon processing a successful Delete command that does not result in the immediate deletion of the domain, and indicates further action is pending. PendingRenew – Status applied by the Registry upon processing a successful Renew command that does not result in the immediate renewal of the domain, and indicates further action is pending. This status will not be used in the .gay registry. PendingUpdate – Status applied by the Registry if an additional action is expected to complete the update, and indicates further action is pending. This status will not be used in the .gay registry. Hold – Removes the domain from the DNS zone. UpdateProhibted – Prevents the object from being modified by an Update command. TransferProhibted – Prevents the object from being transferred to another Registrar by the Transfer command. RenewProhibted – Prevents a domain from being renewed by a Renew command. DeleteProhibted – Prevents the object from being deleted by a Delete command. The lifecycle of a domain begins with the registration of the domain. All registrations must follow the EPP standard, as well as the specific business rules described in the response to Question 18 above. Upon registration a domain will either be in an active or inactive state. Domains in an active state are delegated and have their delegation information published to the zone. Inactive domains either have no delegation information or their delegation information in not published in the zone. Following the initial registration of a domain, one of five actions may occur during its lifecycle: Domain may be updated Domain may be deleted, either within or after the add-grace period Domain may be renewed at anytime during the term Domain may be auto-renewed by the Registry Domain may be transferred to another registrar. Every domain must eventually be renewed, auto-renewed, transferred, or deleted. A registrar may apply EPP statuses described above to prevent specific actions such as updates, renewals, transfers, or deletions; however none of these statuses, including the renewprohibited status will prevent the Registry from auto-renewing the domain. 27.1.1 Registration States Domain Lifecycle – Registration States As described above the .gay registry will implement a standard domain lifecycle found in most gTLD registries today. Active Inactive Locked Pending Transfer Pending Delete. All domains are always in either an Active or Inactive state, and throughout the course of the lifecycle may also be in a Locked, Pending Transfer, and Pending Delete state. Specific conditions such as applied EPP policies and registry business rules will determine whether a domain can be transitioned between states. Additionally, within each state, domains may be subject to various timed events such as grace periods, and notification periods. Active State The active state is the normal state of a domain and indicates that delegation data has been provided and the delegation information is published in the zone. A domain in an Active state may also be in the Locked or Pending Transfer states. Inactive State Indicates that a domain has not been delegated or that the delegation data has not been published to the zone. A domain in an Inactive state may also be in the Locked or Pending Transfer states. By default all domain in the Pending Delete state are also in the Inactive state. Locked State Indicates that certain specified EPP transactions may not be performed to the domain. A domain is considered to be in a Locked state if at least one restriction has been placed on the domain; however up to eight restrictions may be applied simultaneously. Domains in the Locked state will also be in the Active or Inactive, and under certain conditions may also be in the Pending Transfer or Pending Delete states. Pending Transfer State Indicates a condition in which there has been a request to transfer the domain from one registrar to another. The domain is placed in the Pending Transfer state for a period of time to allow the current (losing) registrar to approve (ack) or reject (nack) the transfer request. Registrars may only nack requests for reasons specified in the Inter-Registrar Transfer Policy. Pending Delete State Occurs when a Delete command has been sent to the Registry after the first 5 days (120 hours) of registration. The Pending Delete period is 35-days during which the first 30-days the name enters the Redemption Grace Period (RGP) and the last 5-days guarantee that the domain will be purged from the Registry Database. 27.1.2 Typical Registration Lifecycle Activities Domain Creation Process The creation (registration) of domain names is the fundamental registry operation. All other operations are designed to support or compliment a domain creation. The following steps occur when a domain is created. 1. Contact objects are created in the SRS database. The same contact object may be used for each contact type, or they may all be different. If the contacts already exist in the database this step may be skipped. 2. Nameservers are created in the SRS database. Nameservers are not required to complete the registration process; however any domain with less than 2 name servers will not be resolvable. 3. The domain is created using the each of the objects created in the previous steps. In addition, the term and any client statuses may be assigned at the time of creation. The actual number of EPP transactions needed to complete the registration of a domain name can be as few as one and as many as 40. Update Process Registry objects may be updated (modified) using the EPP Modify operation. The Update transaction updates the attributes of the object. For example, the Update operation on a domain name will only allow the following attributes to be updated: Domain statuses Registrant ID Administrative Contact ID Billing Contact ID Technical Contact ID Nameservers AuthInfo Additional Registrar provided fields. The Update operation will not modify the details of the contacts. Rather it may be used to associate a different contact object (using the Contact ID) to the domain name. Renew Process The term of a domain may be extended using the EPP Renew operation. ICANN policy general establishes the maximum term of a domain name to be 10 years, and Neustar recommends not deviating from this policy. A domain may be renewed⁄extended at any point time, even immediately following the initial registration. The only stipulation is that the overall term of the domain name may not exceed 10 years. If a Renew operation is performed with a term value will extend the domain beyond the 10 year limit, the Registry will reject the transaction entirely. Transfer Process The EPP Transfer command is used for several domain transfer related operations: Initiate a domain transfer Cancel a domain transfer Approve a domain transfer Reject a domain transfer. To transfer a domain from one Registrar to another the following process is followed: 1. The gaining (new) Registrar submits a Transfer command, which includes the AuthInfo code of the domain name. 2. If the AuthInfo code is valid and the domain is not in a status that does not allow transfers the domain is placed into pendingTransfer status 3. A poll message notifying the losing Registrar of the pending transfer is sent to the Registrar’s message queue 4. The domain remains in pendingTransfer status for up to 120 hours, or until the losing (current) Registrar Acks (approves) or Nack (rejects) the transfer request 5. If the losing Registrar has not Acked or Nacked the transfer request within the 120 hour timeframe, the Registry auto-approves the transfer 6. The requesting Registrar may cancel the original request up until the transfer has been completed. A transfer adds an additional year to the term of the domain. In the event that a transfer will cause the domain to exceed the 10 year maximum term, the Registry will add a partial term up to the 10 year limit. Unlike with the Renew operation, the Registry will not reject a transfer operation. Deletion Process A domain may be deleted from the SRS using the EPP Delete operation. The Delete operation will result in either the domain being immediately removed from the database or the domain being placed in pendingDelete status. The outcome is dependent on when the domain is deleted. If the domain is deleted within the first five days (120 hours) of registration, the domain is immediately removed from the database. A deletion at any other time will result in the domain being placed in pendingDelete status and entering the Redemption Grace Period (RGP). Additionally, domains that are deleted within five days (120) hours of any billable (add, renew, transfer) transaction may be deleted for credit. 27.1.3 Applicable Time Elements The following section explains the time elements that are involved. Grace Periods There are six grace periods: Add-Delete Grace Period (AGP) Renew-Delete Grace Period Transfer-Delete Grace Period Auto-Renew-Delete Grace Period Auto-Renew Grace Period Redemption Grace Period (RGP). The first four grace periods listed above are designed to provide the Registrar with the ability to cancel a revenue transaction (add, renew, or transfer) within a certain period of time and receive a credit for the original transaction. The following describes each of these grace periods in detail. Add-Delete Grace Period The APG is associated with the date the Domain was registered. Domains may be deleted for credit during the initial 120 hours of a registration, and the Registrar will receive a billing credit for the original registration. If the domain is deleted during the Add Grace Period, the domain is dropped from the database immediately and a credit is applied to the Registrar’s billing account. Renew-Delete Grace Period The Renew-Delete Grace Period is associated with the date the Domain was renewed. Domains may be deleted for credit during the 120 hours after a renewal. The grace period is intended to allow Registrars to correct domains that were mistakenly renewed. It should be noted that domains that are deleted during the renew grace period will be placed into pendingDelete and will enter the RGP (see below). Transfer-Delete Grace Period The Transfer-Delete Grace Period is associated with the date the Domain was transferred to another Registrar. Domains may be deleted for credit during the 120 hours after a transfer. It should be noted that domains that are deleted during the renew grace period will be placed into pendingDelete and will enter the RGP. A deletion of domain after a transfer is not the method used to correct a transfer mistake. Domains that have been erroneously transferred or hijacked by another party can be transferred back to the original registrar through various means including contacting the Registry. Auto-Renew-Delete Grace Period The Auto-Renew-Delete Grace Period is associated with the date the Domain was auto-renewed. Domains may be deleted for credit during the 120 hours after an auto-renewal. The grace period is intended to allow Registrars to correct domains that were mistakenly auto-renewed. It should be noted that domains that are deleted during the auto-renew delete grace period will be placed into pendingDelete and will enter the RGP. Auto-Renew Grace Period The Auto-Renew Grace Period is a special grace period intended to provide registrants with an extra amount of time, beyond the expiration date, to renew their domain name. The grace period lasts for 45 days from the expiration date of the domain name. Registrars are required to provide registrants with at least 30 days of the period. The registrar is obliged to delete the domain within the Auto-Renew Grace Period in order to initiate the RGP. It is also not permitted to transfer the domain to a third entity (eg. the registrar itself or a redistribution partner) instead of deleting the domain name. If the registrar does not delete the domain within the RGP it automatically authorizes the registry operator to do so on its (the registrar’s) behalf. During the Auto-Renew Grace Period, the registrar is not permitted to transfer ownership of domains. Redemption Grace Period The RGP is a special grace period that enables Registrars to restore domains that have been inadvertently deleted but are still in pendingDelete status within the Redemption Grace Period. All domains enter the RGP except those deleted during the AGP. The RGP period is 60 days, during which time the domain may be restored using the EPP RenewDomain command as described below. Following the 30day RGP period the domain will remain in pendingDelete status for an additional five days, during which time the domain may NOT be restored. The domain is released from the SRS, at the end of the 5 day non-restore period. A restore fee applies and is detailed in the Billing Section. A renewal fee will be automatically applied for any domain past expiration. Neustar has created a unique restoration process that uses the EPP Renew transaction to restore the domain and fulfill all the reporting obligations required under ICANN policy. The following describes the restoration process. Cool Down Period For a period between 1 - 12 months, and at the sole discretion of the registry operator, the domain will not be available for re-registration. The Cool Down Period shall enable for all interested potential registrants to become aware of the ability to register domains in order to minimize the risk that those speculating on domains trump regular registrants. During the Cool Down Period, the registry will have the domain in a reserved names list and reserves the right to route the domain to an automated, non-monetized landing page. This will allow input from the community in the following ways: “Shall this domain be part of the index directory? Shall this domain name be exempted from registration because it causes potential harm to the community? Are you interested in registering this domain and want to be informed in a timely manner once it comes up for re-delegation?”. This way the intended registrants (end users from the community wanting to utilize domain names to publish content and in this way maximizing the awareness of the TLD brand) have a chance to become aware of the availability of the domain. Redelegation Expired domains will be made available for registration in the same manner as described in the landrush period. That enables a fair process of delegation if more than one potential registrant is interested in registering the domain name. 27.2 State Diagram Figure 27-1 provides a description of the registration lifecycle. The details of each trigger are described below: Create: Registry receives a create domain EPP command. WithNS: The domain has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone. WithOutNS: The domain has not met the minimum number of nameservers required by registry policy. The domain will not be in the DNS zone. Remove Nameservers (NS): Domainʹs NS(s) is removed as part of an update domain EPP command. The total NS is below the minimum number of NS required by registry policy in order to be published in the DNS zone. Add Nameservers: NS(s) has been added to domain as part of an update domain EPP command. The total number of NS has met the minimum number of NS required by registry policy in order to be published in the DNS zone. Delete: Registry receives a delete domain EPP command. DeleteAfterGrace: Domain deletion does not fall within the add grace period. DeleteWithinAddGrace: Domain deletion falls within add grace period. Restore: Domain is restored. Domain goes back to its original state prior to the delete command. Transfer: Transfer request EPP command is received. Not possible during the Auto-Renew Grace Period Transfer Approve⁄Cancel⁄Reject: Transfer requested is approved or cancel or rejected. TransferProhibited: The domain is in clientTransferProhibited and⁄or serverTranferProhibited status. This will cause the transfer request to fail. The domain goes back to its original state. DeleteProhibited: The domain is in clientDeleteProhibited and⁄or serverDeleteProhibited status. This will cause the delete command to fail. The domain goes back to its original state. Note: the locked state is not represented as a distinct state on the diagram as a domain may be in a locked state in combination with any of the other states: inactive, active, pending transfer, or pending delete. 27.2.1 EPP RFC Consistency As described above, the domain lifecycle is determined by ICANN policy and the EPP RFCs. Neustar has been operating ICANN TLDs for the past 10 years consistent and compliant with all the ICANN policies and related EPP RFCs. 27.3 Resources The registration lifecycle and associated business rules are largely determined by policy and business requirements; as such the Product Management and Policy teams will play a critical role in working Applicant to determine the precise rules that meet the requirements of the TLD. Implementation of the lifecycle rules will be the responsibility of Development⁄Engineering team, with testing performed by the Quality Assurance team. Neustar’s SRS implementation is very flexible and configurable, and in many case development is not required to support business rule changes. The .gay registry will be using standard lifecycle rules, and as such no customization is anticipated. However should modifications be required in the future, the necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams: Development⁄Engineering – 19 employees Registry Product Management – 4 employees These resources are more than adequate to support the development needs of all the TLDs operated by Neustar, including the .gay registry.
28. Abuse Prevention and Mitigation: Applicants should describe the proposed policies and procedures to minimize abusive registrations and other activities that have a negative impact on Internet users. Answers should include:
- safeguards the applicant will implement at the time of registration, policies to reduce opportunities for abusive behaviors using registered domain names in the TLD, and policies for handling complaints regarding abuse. Each registry operator will be required to establish and publish on its website a single abuse point of contact responsible for addressing matters requiring expedited attention and providing a timely response to abuse complaints concerning all names registered in the TLD through all registrars of record, including those involving a reseller.
- a description of rapid takedown or suspension systems that will be implemented.
- proposed measures for management and removal of orphan glue records for names removed from the zone.
- resourcing plans (number and description of personnel roles allocated to this area).
28.1 Abuse Prevention and Mitigation Strong abuse prevention of a new gTLD is an important benefit to the internet community and .gay registrants. dotgay LLC and its registry operator and back-end registry services provider, Neustar, agree that a registry must not only aim for the highest standards of technical and operational competence, but also needs to act as a steward of the space on behalf of the Internet community and ICANN in promoting the public interest. Neustar brings extensive experience establishing and implementing registration policies. This experience will be leveraged to help dotgay LLC combat abusive and malicious domain activity within the new gTLD space. One of those public interest functions for a responsible domain name registry includes working towards the eradication of abusive domain name registrations, including, but not limited to, those resulting from: Illegal or fraudulent actions Spam Phishing Pharming Distribution of malware Fast flux hosting Botnets Distribution of child pornography Online sale or distribution of illegal pharmaceuticals Incitement to violence or promotion of hatred to the Gay Community. More specifically, although traditionally botnets have used Internet Relay Chat (IRC) servers to control registry and the compromised PCs, or bots, for DDoS attacks and the theft of personal information, an increasingly popular technique, known as fast-flux DNS, allows botnets to use a multitude of servers to hide a key host or to create a highly-available control network. This ability to shift the attacker’s infrastructure over a multitude of servers in various countries creates an obstacle for law enforcement and security researchers to mitigate the effects of these botnets. But a point of weakness in this scheme is its dependence on DNS for its translation services. By taking an active role in researching and monitoring these sorts of botnets, Applicant’s partner, Neustar, has developed the ability to efficiently work with various law enforcement and security communities to begin a new phase of mitigation of these types of threats. Policies and Procedures to Minimize Abusive Registrations A Registry must have the policies, resources, personnel, and expertise in place to combat such abusive DNS practices. As dotgay LLC’s registry provider, Neustar is at the forefront of the prevention of such abusive practices and is one of the few registry operators to have actually developed and implemented an active “domain takedown” policy. We also believe that a strong program is essential given that registrants have a reasonable expectation that they are in control of the data associated with their domains, especially its presence in the DNS zone. Because domain names are sometimes used as a mechanism to enable various illegitimate activities on the Internet sometimes the best preventative measure to thwart these attacks is to remove the names completely from the DNS before they can impart harm, not only to the domain name registrant, but also to millions of unsuspecting Internet users. Removing the domain name from the zone has the effect of shutting down all activity associated with the domain name, including the use of all websites and e-mail. The use of this technique should not be entered into lightly. dotgay LLC has an extensive, defined, and documented process for taking the necessary action of removing a domain from the zone when its presence in the zone poses a threat to the security and stability of the infrastructure of the Internet or the registry. Abuse Point of Contact As required by the Registry Agreement, dotgay LLC will establish and publish on its website a single abuse point of contact responsible for addressing inquiries from law enforcement and the public related to malicious and abusive conduct. dotgay LLC will also provide such information to ICANN prior to the delegation of any domain names in the TLD. This information shall consist of, at a minimum, a valid e-mail address dedicated solely to the handling of malicious conduct complaints, and a telephone number and mailing address for the primary contact. We will ensure that this information will be kept accurate and up to date and will be provided to ICANN if and when changes are made. In addition, with respect to inquiries from ICANN-Accredited registrars, our registry services provider, Neustar, shall have an additional point of contact, as it does today, handling requests by registrars related to abusive domain name practices. 28.2 Policies Regarding Abuse Complaints One of the key policies each new gTLD registry will need to have is an Acceptable Use Policy that clearly delineates the types of activities that constitute “abuse” and the repercussions associated with an abusive domain name registration. In addition, the policy will be incorporated into the applicable Registry-Registrar Agreement and reserve the right for the registry to take the appropriate actions based on the type of abuse. This may include locking down the domain name preventing any changes to the contact and nameserver information associated with the domain name, placing the domain name “on hold” rendering the domain name non-resolvable, transferring to the domain name to another registrar, and⁄or in cases in which the domain name is associated with an existing law enforcement investigation, substituting name servers to collect information about the DNS queries to assist the investigation. dotgay LLC will adopt an Acceptable Use Policy that clearly defines the types of activities that will not be permitted in the TLD and types of activities that are only permitted under specific conditions (eg. labeling of adult content) and reserves the right of the Applicant to lock, cancel, transfer or otherwise suspend or take down domain names violating the Acceptable Use Policy and allow the Registry where and when appropriate to share information with law enforcement. Each ICANN-Accredited Registrar must agree to pass through the Acceptable Use Policy to its Resellers (if applicable) and ultimately to the TLD registrants. Below is the Registry’s initial Acceptable Use Policy that we will use in connection with the .gay TLD. .gay Acceptable Use Policy This Acceptable Use Policy gives the Registry the ability to quickly lock, cancel, transfer or take ownership of any .gay domain name, either temporarily or permanently, if the domain name is being used in a manner that appears to threaten the stability, integrity or security of the Registry, or any of its registrar partners – and⁄or that may put the safety and security of any registrant or user at risk. The process also allows the Registry to take preventive measures to avoid any such criminal or security threats. The Acceptable Use Policy may be triggered through a variety of channels, including, among other things, private complaint, public alert, government or enforcement agency outreach, and the on-going monitoring by the Registry or its partners. In all cases, the Registry or its designees will alert Registry’s registrar partners about any identified threats, and will work closely with them to bring offending sites into compliance. The following are some (but not all) activities that may be subject to rapid domain compliance: Phishing: the attempt to acquire personally identifiable information by masquerading as a website other than you own. Pharming: the redirection of Internet users to websites other than those the user intends to visit, usually through unauthorized changes to the Hosts file on a victim’s computer or DNS records in DNS servers. Dissemination of Malware: the intentional creation and distribution of ʺmaliciousʺ software designed to infiltrate a computer system without the owner’s consent, including, without limitation, computer viruses, worms, key loggers, and Trojans. Fast Flux Hosting: a technique used to shelter Phishing, Pharming and Malware sites and networks from detection and to frustrate methods employed to defend against such practices, whereby the IP address associated with fraudulent websites are changed rapidly so as to make the true location of the sites difficult to find. Botnetting: the development and use of a command, agent, motor, service, or software which is implemented: (1) to remotely control the computer or computer system of an Internet user without their knowledge or consent, (2) to generate direct denial of service (DDOS) attacks. Malicious Hacking: the attempt to gain unauthorized access (or exceed the level of authorized access) to a computer, information system, user account or profile, database, or security system. Child Pornography: the storage, publication, display and⁄or dissemination of pornographic materials depicting individuals under the age of majority in the relevant jurisdiction. Incitement to violence or promotion of hatred of the Gay Community: The Registry reserves the right, in its sole discretion, to take any administrative and operational actions necessary, including the use of computer forensics and information security technological services, among other things, in order to implement the Acceptable Use Policy. In addition, the Registry reserves the right to deny, cancel or transfer any registration or transaction, or place any domain name(s) on registry lock, hold or similar status, that it deems necessary, in its discretion; (1) to protect the integrity and stability of the registry; (2) to comply with any applicable laws, government rules or requirements, due process backed requests from law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of Registry as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement or (5) to correct mistakes made by the Registry or any Registrar in connection with a domain name registration. Registry also reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a dispute. Monitoring for Malicious Activity dotgay LLC’s partner, Neustar is at the forefront of the prevention of abusive DNS practices. Neustar is one of only a few registry operators to have actually developed and implemented an active “domain takedown” policy in which the registry itself takes down abusive domain names. Neustar’s approach is quite different from a number of other gTLD Registries and the results have been unmatched. Neustar targets verified abusive domain names and removes them within 12 hours regardless of whether or not there is cooperation from the domain name registrar. This is because Neustar has determined that the interest in removing such threats from the consumer outweighs any potential damage to the registrar⁄registrant relationship. Neustar’s active prevention policies stem from the notion that registrants in the TLD have a reasonable expectation that they are in control of the data associated with their domains, especially its presence in the DNS zone. Because domain names are sometimes used as a mechanism to enable various illegitimate activities on the Internet, including malware, bot command and control, pharming, and phishing, the best preventative measure to thwart these attacks is sometimes to remove the names completely from the DNS before they can impart harm, not only to the domain name registrant, but also to millions of unsuspecting Internet users. Rapid Takedown Process Since implementing the program, Neustar has developed two basic variations of the process. The more common process variation is a light-weight process that is triggered by “typical” notices. The less-common variation is the full process that is triggered by unusual notices. These notices tend to involve the need for accelerated action by the registry in the event that a complaint is received by Neustar which alleges that a domain name is being used to threaten the stability and security of the TLD, or is part of a real-time investigation by law enforcement or security researchers. These processes are described below: Lightweight Process In addition to having an active Information Security group that, on its own initiatives, seeks out abusive practices in the TLD, Neustar is an active member in a number of security organizations that have the expertise and experience in receiving and investigating reports of abusive DNS practices, including but not limited to, the Anti-Phishing Working Group, Castle Cops, NSP-SEC, the Registration Infrastucture Safety Group and others. Each of these sources are well-known security organizations that have developed a reputation for the prevention of harmful agents affecting the Internet. Aside from these organizations, Neustar also actively participates in privately run security associations whose basis of trust and anonymity makes it much easier to obtain information regarding abusive DNS activity. Once a complaint is received from a trusted source, third-party, detected by the dotgay LLC’s periodic reviews, or detected by Neustar’s internal security group, information about the abusive practice is forwarded to an internal mail distribution list that includes members of the operations, legal, support, engineering, and security teams for immediate response as well as representatives of dotgay LLC (“CERT Team”). Although the impacted URL is included in the notification e-mail, the CERT Team is trained not to investigate the URLs themselves since often times the URLs in Question have scripts, bugs, etc. that can compromise the individual’s own computer and the network safety. Rather, the investigation is done by a few members of the CERT team that are able to access the URLs in a laboratory environment so as to not compromise the Neustar network. The lab environment is designed specifically for these types of tests and is scrubbed on a regular basis to ensure that none of Neustar’s internal or external network elements are harmed in any fashion. Once the complaint has been reviewed and the alleged abusive domain name activity is verified to the best of the ability of the CERT Team, the sponsoring registrar is given 12 hours to investigate the activity and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hNeustar’s period (i.e., is unresponsive to the request or refuses to take action), Neustar places the domain on “ServerHold”. Although this action removes the domain name from the TLD zone, the domain name record still appears in the TLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved. Full Process. In the event that Neustar receives a complaint which claims that a domain name is being used to threaten the stability and security of the TLD or is a part of a real-time investigation by law enforcement or security researchers, Neustar follows a slightly different course of action. Upon initiation of this process, members of the CERT Team are paged and a teleconference bridge is immediately opened up for the CERT Team to assess whether the activity warrants immediate action. If the CERT Team determines the incident is not an immediate threat to the security and the stability of critical internet infrastructure, they provide documentation to the Neustar Network Operations Center to clearly capture the rationale for the decision and either refers the incident to the Lightweight process set forth above. If no abusive practice is discovered, the incident is closed. However, if the CERT TEAM determines there is a reasonable likelihood that the incident warrants immediate action as described above, a determination is made to immediately remove the domain from the zone. As such, Customer Support contacts the responsible registrar immediately to communicate that there is a domain involved in a security and stability issue. The registrar is provided only the domain name in Question and the broadly stated type of incident. Given the sensitivity of the associated security concerns, it may be important that the registrar not be given explicit or descriptive information in regards to data that has been collected (evidence) or the source of the complaint. The need for security is to fully protect the chain of custody for evidence and the source of the data that originated the complaint. Coordination with Law Enforcement & Industry Groups One of the reasons for which Neustar was selected to serve as the back-end registry services provider for dotgay LLC is Neustar’s extensive experience with its industry-leading abusive domain name and malicious monitoring program and its close working relationship with a number of law enforcement agencies, both in the United States and internationally. For example, in the United States, Neustar is in constant communication with the Federal Bureau of Investigation, US CERT, Homeland Security, the Food and Drug Administration, and the National Center for Missing and Exploited Children. Neustar is also a participant in a number of industry groups aimed at sharing information amongst key industry players about the abusive registration and use of domain names. These groups include the Anti-Phishing Working Group and the Registration Infrastructure Safety Group (where Neustar served for several years as on the Board of Directors). Through these organizations and others, Neustar shares information with other registries, registrars, ccTLDs, law enforcement, security professionals, etc. not only on abusive domain name registrations within its own TLDs, but also provides information uncovered with respect to domain names in other registries’ TLDs. Neustar has often found that rarely are abuses found only in the TLDs for which it manages, but also within other TLDs, such as .com and .info. Neustar routinely provides this information to the other registries so that it can take the appropriate action. With the assistance of Neustar as its back-end registry services provider, dotgay LLC can meet its obligations under Section 2.8 of the Registry Agreement where required to take reasonable steps to investigate and respond to reports from law enforcement and governmental and quasi-governmental agencies of illegal conduct in connection with the use of its TLD. dotgay LLC and⁄or Neustar will respond to legitimate law enforcement inquiries within one business day from receiving the request. Such response shall include, at a minimum, an acknowledgement of receipt of the request, Questions or comments concerning the request, and an outline of the next steps to be taken by dotgay LLC and⁄or Neustar for rapid resolution of the request. In the event such request involves any of the activities which can be validated by dotgay LLC and⁄or Neustar and involves the type of activity set forth in the Acceptable Use Policy, the sponsoring registrar is then given 12 hours to investigate the activity further and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), Neustar places the domain on “serverHold”. 28.3 Measures for Removal of Orphan Glue Records As the Security and Stability Advisory Committee of ICANN (SSAC) rightly acknowledges, although orphaned glue records may be used for abusive or malicious purposes, the “dominant use of orphaned glue supports the correct and ordinary operation of the DNS.” See http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf. While orphan glue often support correct and ordinary operation of the DNS, we understand that such glue records can be used maliciously to point to name servers that host domains used in illegal phishing, bot-nets, malware, and other abusive behaviors. Problems occur when the parent domain of the glue record is deleted but its children glue records still remain in DNS. Therefore, when the Registry has written evidence of actual abuse of orphaned glue, the Registry will take action to remove those records from the zone to mitigate such malicious conduct. Neustar run a daily audit of entries in its DNS systems and compares those with its provisioning system. This serves as an umbrella protection to make sure that items in the DNS zone are valid. Any DNS record that shows up in the DNS zone but not in the provisioning system will be flagged for investigation and removed if necessary. This daily DNS audit serves to not only prevent orphaned hosts but also other records that should not be in the zone. In addition, if either dotgay LLC or Neustar become aware of actual abuse on orphaned glue after receiving written notification by a third party through its Abuse Contact or through its customer support, such glue records will be removed from the zone. 28.4 Measures to Promote WHOIS Accuracy dotgay LLC acknowledges that ICANN has developed a number of mechanisms over the past decade that are intended to address the issue of inaccurate WHOIS information. Such measures alone have not proven to be sufficient and dotgay LLC will offer a mechanism whereby third parties can submit complaints directly to the Applicant (as opposed to ICANN or the sponsoring Registrar) about inaccurate or incomplete WHOIS data. Such information shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Thirty days after forwarding the complaint to the registrar, dotgay LLC will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, Applicant reserves the right to suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies. In addition, dotgay LLC shall on its own initiative, no less than twice per year, perform a manual review of a random sampling of .gay domain names to test the accuracy of the WHOIS information. Although this will not include verifying the actual information in the WHOIS record, dotgay LLC will be examining the WHOIS data for prima facie evidence of inaccuracies. In the event that such evidence exists, it shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Thirty days after forwarding the complaint to the registrar, the Applicant will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, dotgay LLC reserves the right to suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies. 28.4.1 Authentication of Registrant Information Authentication of registrant information as complete and accurate at time of registration. Measures to accomplish this could include performing background checks, verifying all contact information of principals mentioned in registration data, reviewing proof of establishment documentation, and other means. 28.4.2 Monitoring of Registration Data Regular monitoring of registration data for accuracy and completeness, employing authentication methods, and establishing policies and procedures to address domain names with inaccurate or incomplete WHOIS data. 28.4.3 Policies and Procedures Ensuring Compliance If relying on registrars to enforce measures, establishing policies and procedures to ensure compliance, which may include audits, financial incentives, penalties, or other means. Note that the requirements of the RAA will continue to apply to all ICANN-accredited registrars. 28.5 Resourcing Plans Responsibility for abuse mitigation rests with a variety of functional groups. The Abuse Monitoring team is primarily responsible for providing analysis and conducting investigations of reports of abuse. The customer service team also plays an important role in assisting with the investigations, responded to customers, and notifying registrars of abusive domains. Finally, the Policy⁄Legal team is responsible for developing the relevant policies and procedures. The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams: Customer Support – 12 employees Policy⁄Legal – 2 employees Ombudsman function – 1 full time equivalent The resources are more than adequate to support the abuse mitigation procedures of the .gay registry.
29. Rights Protection Mechanisms: Applicants should describe how their proposal will comply with policies and practices that minimize abusive registrations and other activities that affect the legal rights of others. Describe how the registry operator will implement safeguards against allowing unqualified registrations, and reduce opportunities for behaviors such as phishing or pharming. At a minimum, the registry operator must offer either a Sunrise period or a Trademark Claims service, and implement decisions rendered under the URS. Answers may also include additional measures such as abusive use policies, takedown procedures, registrant pre-verification, or authentication procedures, or other covenants. Describe resourcing plans (number and description of personnel roles allocated to this area).
29.1. Rights Protection Mechanisms dotgay LLC is firmly committed to the protection of Intellectual Property rights and to implementing the mandatory rights protection mechanisms contained in the Applicant Guidebook. dotgay LLC recognizes that although the New gTLD program includes significant protections beyond those that were mandatory for a number of the current TLDs, a key motivator for dotgay LLC’s selection of Neustar as its registry services provider is Neustar’s experience in successfully launching a number of TLDs with diverse rights protection mechanisms, including many the ones required in the Applicant Guidebook. More specifically, dotgay LLC will implement the following rights protection mechanisms in accordance with the Applicant Guidebook as further described below: • Trademark Clearinghouse: a one-stop shop so that trademark holders can protect their trademarks with a single registration. • Sunrise and Trademark Claims processes for the TLD. • Implementation of the Uniform Dispute Resolution Policy to address domain names that have been registered and used in bad faith in the TLD. • Uniform Rapid Suspension: A quicker, more efficient and cheaper alternative to the Uniform Dispute Resolution Policy to deal with clear cut cases of cybersquatting. • Implementation of a Thick WHOIS making it easier for rights holders to identify and locate infringing parties A. Trademark Clearinghouse Including Sunrise and Trademark Claims The first mandatory rights protection mechanism (“RPM”) required to be implemented by each new gTLD Registry is support for, and interaction with, the trademark clearinghouse. The trademark clearinghouse is intended to serve as a central repository for information to be authenticated, stored and disseminated pertaining to the rights of trademark holders. The data maintained in the clearinghouse will support and facilitate other RPMs, including the mandatory Sunrise Period and Trademark Claims service. Although many of the details of how the trademark clearinghouse will interact with each registry operator and registrars, dotgay LLC is actively monitoring the developments of the Implementation Assistance Group (“IAG”) designed to assist ICANN staff in firming up the rules and procedures associated with the policies and technical requirements for the trademark clearinghouse. In addition, dotgay LLC’s back-end registry services provider is actively participating in the IAG to ensure that the protections afforded by the clearinghouse and associated RPMs are feasible and implementable. Utilizing the trademark clearinghouse, all operators of new gTLDs must offer: (i) a sunrise registration service for at least 30 days during the pre-launch phase giving eligible trademark owners an early opportunity to register second-level domains in new gTLDs; and (ii) a trademark claims service for at least the first 60 days that second-level registrations are open. The trademark claim service is intended to provide clear noticeʺ to a potential registrant of the rights of a trademark owner whose trademark is registered in the clearinghouse. dotgay LLC’s registry service provider, Neustar, has already implemented Sunrise and⁄or Trademark Claims programs for numerous TLDs including .biz, .us, .travel, .tel and .co and will implement the both of these services on behalf of dotgay LLC. Neustar’s Experience in Implementing Sunrise and Trademark Claims Processes In early 2002, Neustar became the first registry operator to launch a successful authenticated Sunrise process. This process permitted qualified trademark owners to pre-register their trademarks as domain names in the .us TLD space prior to the opening of the space to the general public. Unlike any other “Sunrise” plans implemented (or proposed before that time), Neustar validated the authenticity of Trademark applications and registrations with the United States Patent and Trademark Office (USPTO). Subsequently, as the back-end registry operator for the .tel gTLD and the .co ccTLD, Neustar launched validated Sunrise programs employing processes. These programs are very similar to those that are to be employed by the Trademark Clearinghouse for new gTLDs. Below is a high level overview of the implementation of the .co Sunrise period that demonstrates Neustar’s experience and ability to provide a Sunrise service and an overview of Neustar’s experience in implementing a Trademark Claims program to trademark owners for the launch of .BIZ. Neustar’s experience in each of these rights protection mechanisms will enable it to seamlessly provide these services on behalf of dotgay LLC as required by ICANN. a) Sunrise and .co The Sunrise process for .co was divided into two sub-phases: • Local Sunrise giving holders of eligible trademarks that have obtained registered status from the Colombian trademark office the opportunity apply for the .CO domain names corresponding with their marks • Global Sunrise program giving holders of eligible registered trademarks of national effect, that have obtained a registered status in any country of the world the opportunity apply for the .CO domain names corresponding with their marks for a period of time before registration is open to the public at large. Like the new gTLD process set forth in the Applicant Guidebook, trademark owners had to have their rights validated by a Clearinghouse provider prior to the registration being accepted by the Registry. The Clearinghouse used a defined process for checking the eligibility of the legal rights claimed as the basis of each Sunrise application using official national trademark databases and submitted documentary evidence. Applicants and⁄or their designated agents had the option of interacting directly with the Clearinghouse to ensure their applications were accurate and complete prior to submitting them to the Registry pursuant to an optional “Pre-validation Process”. Whether or not an applicant was “pre-validated”, the applicant had to submit its corresponding domain name application through an accredited registrar. When the Applicant was pre-validated through the Clearinghouse, each was given an associated approval number that it had to supply the registry. If they were not pre-validated, applicants were required to submit the required trademark information through their registrar to the Registry. As the registry level, Neustar, subsequently either delivered the: • Approval number and domain name registration information to the Clearinghouse • When there was no approval number, trademark information and the domain name registration information was provided to the Clearinghouse through EPP (as is currently required under the Applicant Guidebook). Information was then used by the Clearinghouse as either further validation of those pre-validated applications, or initial validation of those that did not go through pre-validation. If the applicant was validated and their trademark matched the domain name applied-for, the Clearinghouse communicated that fact to the Registry via EPP. When there was only one validated sunrise application, the application proceeded to registration when the .co launched. If there were multiple validated applications (recognizing that there could be multiple trademark owners sharing the same trademark), those were included in the .co Sunrise auction process. Neustar tracked all of the information it received and the status of each application and posted that status on a secure Website to enable trademark owners to view the status of its Sunrise application. Although the exact process for the Sunrise program and its interaction between the trademark owner, Registry, Registrar, and IP Clearinghouse is not completely defined in the Applicant Guidebook and is dependent on the current RFI issued by ICANN in its selection of a Trademark Clearinghouse provider, Neustar’s expertise in launching multiple Sunrise processes and its established software will implement a smooth and compliant Sunrise process for the new gTLDs. b) Trademark Claims Service Experience With Neustar’s biz TLD launched in 2001, Neustar became the first TLD with a Trademark Claims service. Neustar developed the Trademark Claim Service by enabling companies to stake claims to domain names prior to the commencement of live .biz domain registrations. During the Trademark Claim process, Neustar received over 80,000 Trademark Claims from entities around the world. Recognizing that multiple intellectual property owners could have trademark rights in a particular mark, multiple Trademark Claims for the same string were accepted. All applications were logged into a Trademark Claims database managed by Neustar. The Trademark Claimant was required to provide various information about their trademark rights, including the: • Particular trademark or service mark relied on for the trademark Claim • Date a trademark application on the mark was filed, if any, on the string of the domain name • Country where the mark was filed, if applicable • Registration date, if applicable • Class or classes of goods and services for which the trademark or service mark was registered • Name of a contact person with whom to discuss the claimed trademark rights. Once all Trademark Claims and domain name applications were collected, Neustar then compared the claims contained within the Trademark Claims database with its database of collected domain name applications (DNAs). In the event of a match between a Trademark Claim and a domain name application, an e-mail message was sent to the domain name applicant notifying the applicant of the existing Trademark Claim. The e-mail also stressed that if the applicant chose to continue the application process and was ultimately selected as the registrant, the applicant would be subject to Neustar’s dispute proceedings if challenged by the Trademark Claimant for that particular domain name. The domain name applicant had the option to proceed with the application or cancel the application. Proceeding on an application meant that the applicant wanted to go forward and have the application proceed to registration despite having been notified of an existing Trademark Claim. By choosing to “cancel,” the applicant made a decision in light of an existing Trademark Claim notification to not proceed. If the applicant did not respond to the e-mail notification from Neustar, or elected to cancel the application, the application was not processed. This resulted in making the applicant ineligible to register the actual domain name. If the applicant affirmatively elected to continue the application process after being notified of the claimants’ alleged trademark rights to the desired domain name, Neustar processed the application. This process is very similar to the one ultimately adopted by ICANN and incorporated in the latest version of the Applicant Guidebook. Although the collection of Trademark Claims for new gTLDs will be by the Trademark Clearinghouse, many of the aspects of Neustar’s Trademark Claims process in 2001 are similar to those in the Applicant Guidebook. This makes Neustar uniquely qualified to implement the new gTLD Trademark Claims process. . B. Uniform Dispute Resolution Policy (UDRP) and Uniform Rapid Suspension (URS) 1. UDRP Prior to joining Neustar, Mr. Neuman was a key contributor to the development of the Uniform Dispute Resolution Policy (“UDRP”) in 1998. This became the first “Consensus Policy” of ICANN and has been required to be implemented by all domain name registries since that time. The UDRP is intended as an alternative dispute resolution process to transfer domain names from those that have registered and used domain names in bad faith. Although there is not much of an active role that the domain name registry plays in the implementation of the UDRP, Neustar has closely monitored UDRP decisions that have involved the TLDs for which it supports and ensures that the decisions are implemented by the registrars supporting its TLDs. When alerted by trademark owners of failures to implement UDRP decisions by its registrars, Neustar either proactively implements the decisions itself or reminds the offending registrar of its obligations to implement the decision. 1. URS In response to complaints by trademark owners that the UDRP was too cost prohibitive and slow, and the fact that more than 70 percent of UDRP cases were “clear cut” cases of cybersquatting, ICANN adopted the IRT’s recommendation that all new gTLD registries be required, pursuant to their contracts with ICANN, to take part in a Uniform Rapid Suspension System (“URS”). The purpose of the URS is to provide a more cost effective and timely mechanism for brand owners than the UDRP to protect their trademarks and to promote consumer protection on the Internet. The URS is not meant to address Questionable cases of alleged infringement (e.g., use of terms in a generic sense) or for anti-competitive purposes or denial of free speech, but rather for those cases in which there is no genuine contestable issue as to the infringement and abuse that is taking place. Unlike the UDRP which requires little involvement of gTLD registries, the URS envisages much more of an active role at the registry-level. For example, rather than requiring the registrar to lock down a domain name subject to a UDRP dispute, it is the registry under the URS that must lock the domain within 24hours of receipt of the complaint from the URS Provider to restrict all changes to the registration data, including transfer and deletion of the domain names. In addition, in the event of a determination in favor of the complainant, the registry is required to suspend the domain name. This suspension remains for the balance of the registration period and would not resolve the original website. Rather, the nameservers would be redirected to an informational web page provided by the URS Provider about the URS. Additionally, the WHOIS reflects that the domain name will not be able to be transferred, deleted, or modified for the life of the registration. Finally, there is an option for a successful complainant to extend the registration period for one additional year at commercial rates. dotgay LLC is fully aware of each of these requirements and will have the capability to implement these requirements for new gTLDs. In fact, during the IRT’s development of f the URS, Neustar began examining the implications of the URS on its registry operations and provided the IRT with feedback on whether the recommendations from the IRT would be feasible for registries to implement. Although there have been a few changes to the URS since the IRT recommendations, Neustar continued to participate in the development of the URS by providing comments to ICANN, many of which were adopted. As a result, Neustar is committed to supporting the URS for all of the registries that it provides back-end registry services. C. Implementation of Thick WHOIS The .gay registry will include a thick WHOIS database as required in Specification 4 of the Registry agreement. A thick WHOIS provides the ability to more easily manage and control the accuracy of data, and a consistent user experience. D. Policies Handling Complaints Regarding Abuse In addition the Rights Protection mechanisms addressed above, dotgay LLC will implement a number of measures to handle complaints regarding the abusive registration of domain names in its TLD as described in dotgay LLC’s response to Question 28. Registry Acceptable Use Policy One of the key policies each new gTLD registry is the need to have is an Acceptable Use Policy that clearly delineates the types of activities that constitute “abuse” and the repercussions associated with an abusive domain name registration. The policy must be incorporated into the applicable Registry-Registrar Agreement and reserve the right for the registry to take the appropriate actions based on the type of abuse. This may include locking down the domain name preventing any changes to the contact and nameserver information associated with the domain name, placing the domain name “on hold” rendering the domain name non-resolvable, transferring to the domain name to another registrar, and⁄or in cases in which the domain name is associated with an existing law enforcement investigation, substituting name servers to collect information about the DNS queries to assist the investigation. dotgay LLC’s Acceptable Use Policy, set forth in our response to Question 28, will include prohibitions on phishing, pharming, dissemination of malware, fast flux hosting, hacking, and child pornography. In addition, the policy will include the right of the registry to take action necessary to deny, cancel, suspend, lock, or transfer any registration in violation of the policy. Monitoring for Malicious Activity dotgay LLC is committed to ensuring that those domain names associated with abuse or malicious conduct in violation of the Acceptable Use Policy are dealt with in a timely and decisive manner. These include taking action against those domain names that are being used to threaten the stability and security of the TLD, or are part of a real-time investigation by law enforcement as required by due process. Once a complaint is received from a trusted source, third-party, or detected by the Registry, the Registry will use commercially reasonable efforts to verify the information in the complaint. If that information can be verified to the best of the ability of the Registry and can be shown to be in accordance with due process requirements, the sponsoring registrar will be notified and be given 12 hours to investigate the activity and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the Registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), the Registry will place the domain on “ServerHold”. Although this action removes the domain name from the TLD zone, the domain name record still appears in the TLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved. 29.2 Safeguards against Unqualified Registrations As a community-based TLD, dotgay LLC is firmly committed to safeguarding against unqualified registrations on .gay, a responsibility directly linked to fulfilling the community-based mission outlined in 18(a). Building a trusted TLD for the gay community requires a strategic and well planned approach and through the participation, input and use of established membership protocol from organizations in the gay community, dotgay LLC has identified several mechanisms to assist with admitting and maintaining qualified registrations, as well as identifying and removing unqualified registrations. More specifically, dotgay LLC will implement the following safeguarding mechanisms as further described below: • Community Authentication: requirement with a Community Identifier Code (CIC), a unique code used to validate eligibility during name registration • Authentication Update: periodic requirement for existing registrations • Community Watch: online reporting • Audit: periodic scanning and reviews 1. Community Authentication In order to “qualify to register” a name on the .gay TLD, all registrants will be required to authenticate that they are members of the gay community. The qualifier used by dotgay LLC will draw on the existing practices from the network of membership organizations in the gay community around the world, making membership with these organizations the threshold requirement for admission into the .gay TLD. Membership organizations in the gay community serve as the foundation of the community in all regions of the world, implementing internal policies to identify and admit members of the gay community, while preventing non-community members from taking up membership for reasons primarily focused on misrepresentation and safety. The systems currently employed for admission to the gay community will serve the community-based .gay TLD well since it takes a community approach to who qualifies to register a .gay name. dotgay LLC refers to these organizations as Authentication Partners and they will be comprised of a wide variety of membership organizations in the gay community that focus on human rights, equality, commerce, culture and others designed to serve the gay community (as defined in Question 20e). Authentication Partners will be the entry point for members of the gay community to begin the process of registering a name on the .gay TLD. Community members will follow an online process with their Authentication Partners to acquire a Community Identifier Code (CIC). The CIC will simultaneously be shared with dotgay LLC and Neustar for future validation during name registration. Each CIC will be good for a one name registration on the .gay TLD and must be provided to the registrar during name registration so that it can be validated with Neustar. If the CIC is confirmed as valid by Neustar, it will permit the name registration to proceed. If the CIC fails validation with Neustar then the name registration will not proceed. By design this process will be the first line of defense for unqualified registrations. Any transfer of a .gay name, from one registrant to another, will also require that a valid CIC be provided by the registrant taking possession of the name. This is to avoid .gay names from being transferred to non-community members at any point during the registration period. 2. Authentication Update dotgay LLC will also require authentication updates for all registrations as an ongoing safeguard against unqualified registrations. The authentication updates are intended to provide a double check and ongoing confirmation that registrations are from members of the gay community. To complete an authentication update, registrants will simply return to their chosen Authentication Partner and acquire a new CIC. This CIC will be transmitted directly to dotgay LLC to complete the update. Registrants will be able to update their CIC at any point, or at minimum within the time period required for the authentication update as detailed in the registrant agreement. 3. Community Watch dotgay LLC will implement an online reporting mechanism to assist in surfacing unqualified registrations that may have fraudulently passed through Community Authentication, or which no longer meet eligibility requirements of the .gay TLD. The community watch approach enables members of the gay community to engage when they have knowledge pertaining to an unqualified registration, by bringing it to the attention of the Registry. The reporting mechanism will require an explanation as to why the registration is believed to not be qualified for the .gay TLD and reports received will be reviewed by the Registry’s Office of the Ombudsman. 4. Audits dotgay LLC will also reserve the right to conduct an audit on .gay registrations when it becomes aware of CIC abuse or misconduct of Authentication Partners. 29.3 Resourcing Plans The rights protection mechanisms described in the response above involve a wide range of tasks, procedures, and systems. The responsibility for each mechanism varies based on the specific requirements. In general the development of applications such as sunrise and IP claims is the responsibility of the Engineering team, with guidance from the Product Management team. Customer Support and Legal play a critical role in enforcing certain policies such as the rapid suspension process. These teams have years of experience implementing these or similar processes. The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams: Development⁄Engineering – 19 employees Product Management- 4 employees Customer Support – 12 employees Ombudsman function – 1 full time equivalent The resources are more than adequate to support the rights protection mechanisms of the .gay registry.
Demonstration of Technical & Operational Capability (Internal)
30(a). Security Policy: provide summary of the security policy for the proposed registry, including but not limited to:
- indication of any independent assessment reports demonstrating secuirty capabilities; description of any augemented secuirty levels or capabilities commensurate with the
- nature of the applied for gTLD string;
- lists of commitments made to registrants concerning security levels;