29 Rights Protection Mechanisms

Prototypical answer:

1 MECHANISMS DESIGNED TO PREVENT ABUSIVE REGISTRATIONS

Rights protection is a core objective of fTLD Registry Services, LLC (FRS).

Members of the .bank gTLD community are all too familiar with the problems of abusive registrations, and many times, find themselves victims of such activity. The mission of the .bank gTLD is to serve as a trusted, hierarchical and intuitive namespace for the banking community and the consumers it serves. FRS will implement and adhere to all Rights Protection Mechanisms (RPMs) that may be mandated periodically by ICANN, including each mandatory RPM set forth in the Trademark Clearinghouse model contained in the template Registry Agreement, Specification 7. FRS acknowledges that, at a minimum, ICANN requires a Sunrise period, a Trademark Claims period, and interaction with the Trademark Clearinghouse with respect to the registration of domain names for the .bank gTLD.

In addition to ICANN’s baseline requirements, FRS plans to introduce enhanced measures to ensure that abusive registrations do not occur in the .bank gTLD. It should be noted that because ICANN, as of the time of this application submission, has not issued final guidance with respect to the Trademark Clearinghouse, FRS cannot fully detail the specific implementation of the Trademark Clearinghouse within this application. FRS will adhere to all processes and procedures to comply with ICANN once this final guidance has been issued.

As described in this response, FRS will implement a multi-tier approach to rights protection that seeks to minimize the potential for abusive registrations and to expeditiously address them should they occur. Measures will be deployed at the registry, registrar and registrant levels to ensure a comprehensive approach to these critical objectives. Policies and processes designed to prevent and mitigate abusive registrations include:
- Registrant Eligibility Criteria
- Stringent Name Selection Policy
- Acceptable Use Policy
- Deployment of Enhanced Security Standards
- Trademark Claims Service
- Sunrise Service
- Rapid Takedown or Suspension
- Anti-Abuse Process
- Enhanced Authentication
- Malware Code Identification
- DNSSEC Signing Service
- Semi-Annual WHOIS Verification
- Active Participation in Anti-Abuse Community Activities

Certain aspects of the Sunrise Period and⁄or Trademark Claims Service will be administered on behalf of FRS by its FRS-accredited registrars or by contracted third parties of FRS, such as its selected backend registry services provider, Verisign.


Registrant Eligibility Criteria

As the operator of the .bank gTLD, FRS has undertaken responsibilities based upon experience and concerns expressed by the banking community. It is essential that only registrations of verified members of the banking community be permitted. In addition to validating the eligibility of the registrant, the domain name to be registered must comply with appropriate name selection and use requirement policies.

To ensure strict compliance with these policies, FRS will develop and implement a Registrant Eligibility Evaluation Process. This process requires .bank accredited registrars to collect registrant information that will be used by FRS or an independent third-party service provider to authenticate that the registrant is a member of the banking community. These requirements will be hard coded into FRS’ Registry-Registrar Agreement (RRA).

Registrations within the community may initially be made by the following for-profit and not-for-profit businesses, individuals or organizations:
- State or regionally chartered and regulated banks
- Nationally chartered and regulated banks
- Associations whose members are comprised of chartered and regulated banking entities (if approved by the FRS Board)
- Organizations that are majority controlled by chartered and regulated banks or financial holding companies (if approved by the FRS Board)
- Entities whose operations are principally dedicated to serving banks (if approved by the FRS Board)
- Specialized organizations (e.g., research or risk coordination) (if approved by the FRS Board)

As part of the registration process, potential applicants must provide the registrar with the following information:
- Full legal name
- Business address
- Professional title of representative of the administrative contact of potential registrant
- Business name
- Point of contact within the business who can verify their representation of the business
- Phone
- Email
- Another proof of identity necessary to establish that the registrant is an eligible member of the .bank gTLD community
- For organizations that are majority controlled by chartered and regulated banks or financial holding companies (if approved by the FRS Board)
- For entities whose operations are principally dedicated to serving banks (if approved by the FRS Board), corporate operating agreement or like document(s) as determined necessary to validate alignment with the goals of the community
- For specialized organizations (e.g., research or risk coordination) (if approved by the FRS Board), a copy of its corporate operating agreement if for-profit or its mission statement if non-profit (or like document(s) as determined necessary to validate alignment with the goals of the community)

The Registrant Eligibility Evaluation Process serves several purposes which will reduce the incidents of abusive registrations that impact the rights of others, as well as impact the security of the gTLD including:
- Ensuring the registrant information is complete, true and accurate, thereby contributing to accurate Whois information for all domains in the gTLD.
- Verifying, where necessary, supplemental documentation submitted to establish eligibility within the banking community.

Applicants who pass these eligibility tests will then be permitted to register their domain name. Applicants who do not pass the eligibility test will have the opportunity to appeal to the registry, but determination of eligibility rests solely with FRS. In the case of a dispute, an adjunct ombudsman will be used.


Stringent Name Selection Policy

Domains registered in the .bank gTLD must correspond to a trademark, trade name or other service mark owned by the registrant. All other registrations (e.g., geographic, generic, etc.) will be reserved by the registry for its use or to be allocated in the future under an equitable allocation plan. The registry will develop a list of reserved names that are intended to be released in the future and the procedures governing their release will be developed in an open and transparent manner. In addition, FRS will ensure that all domain names meet the technical requirements set forth in applicable Requests for Comments (RFCs) (e.g., max character length), as well as domain name reservations as set forth in Specification 5 of the template Registry Agreement.


Acceptable Use Policy

FRS will have an Acceptable Use Policy (AUP) that will govern how a registrant may use its registered name. A DRAFT version of the policy follows (which may be amended from time to time):

All .bank domains must be used to serve the needs of the banking community. By registering a name in a gTLD operated by FRS, you agree to be bound by the terms of this Acceptable Use Policy (AUP). You may not:
1. Use your domain for any purposes prohibited by the laws of the jurisdiction(s) in which you do business or any other applicable law. For banks, use of your domain name for any purposes prohibited by the banking regulations of the regulator or government agency that issues your charter or license is strictly prohibited.
2. Use your domain for any purposes or in any manner that violates a statute, rule or law governing use of the Internet and⁄or electronic commerce (specifically including phishing, pharming, distributing Internet viruses and other destructive activities).
3. Use your domain for the following types of activity:

- Violating the privacy or publicity rights of another member of the banking community or any other person or entity, or breaching any duty of confidentiality that you owe to another member of the .bank gTLD community or any other person or entity;
- Promoting or engaging in hate speech, hate crime, terrorism, violence against people, animals, or property, or intolerance of or against any protected class;
- Promoting or engaging in defamatory, harassing, abusive or otherwise objectionable behavior;
- Promoting or engaging in pornography;
- Promoting or engaging in any spam or other unsolicited bulk email, or computer or network hacking or cracking;
- Promoting or engaging in any money laundering or terrorist financing activity;
- Infringing on the intellectual property rights of another member of the .bank gTLD community or any other person or entity;
- Engaging in activities designed to impersonate any third party or create a likelihood of confusion in sponsorship;
- Interfering with the operation of the .bank gTLD or services offered by FRS;
- Distributing or Installing any viruses, worms, bugs, Trojan horses or other code, files or programs designed to, or capable of, disrupting, damaging or limiting the functionality of any software or hardware, or distributing false or deceptive language, or unsubstantiated or comparative claims, regarding FRS;
- Disseminating content which contains false or deceptive language or unsubstantiated comparative claims, regarding FRS;
- Licensing your domain to any third party during the period of your registration; or,
- Engaging in behavior that is anti-competitive, boycotts or otherwise violates anti-trust laws.

You are responsible for the usage of your domain at all times during the period of your registration.

Proxy registrations are prohibited for all gTLDs operated by FRS.

By “use,” “usage” or “using” your domain name, we mean any use involving the Internet including, but not limited to, website(s) and⁄or any pages thereof resolving at your domain, either directly or indirectly (including redirection, framing, pop-up windows⁄browsers, linking, etc.), and email distribution and⁄or reception.

As part of the AUP, FRS will have complete enforcement rights over registrant’s use of domain names.

If Registrant violates this AUP, Registrant will be subject to a rapid domain name compliance action, be in material breach of this Agreement, and along with all other rights and remedies under this Agreement with respect to such a breach, FRS reserves the right to revoke, suspend, terminate, cancel or otherwise modify Registrant’s rights to the domain name.

On a regular basis, FRS will audit domain names, or require an attestation by second-level domain holders, registered in the .bank gTLD space to ensure compliance with all eligibility and use criteria. If a violation is discovered, an investigation will begin immediately to rectify the violation.

If an applicant chooses to appeal, FRS will review the appeal to determine if there are any material changes to the action or activity. FRS will retain the right to assign the dispute to an ombudsman if necessary. This appeal or referral process will operate on a cost-recovery basis.


Deployment of Enhanced Security Standards

In January 2010, ABA and the Roundtable (through its BITS division) - founding organizations of FRS - committed to forming a global, industry-wide working group whose goal was to develop enhanced security standards that should be implemented in financial Top Level Domains or any domain that requires increased security. The Security Standards Working Group (SSWG) was comprised of representatives from the financial services and domain name industries, as well as security and technical experts. For a complete list of organizations that endorsed the SSWG’s standards, see Attachment 29-1.

The SSWG developed a list of 31 Enhanced Security Standards that should be implemented in any financial gTLD. See Attachment 29-2 for the full list of Enhanced Security Standards. Included in the most recent version of the Applicant Guidebook, ICANN has cited these security standards as an example of what an independent standard could look like so that other financial services gTLD applicants could use it for guidance. FRS, as the steward of the .bank gTLD, is implementing all 31 of these Enhanced Security Standards to ensure that the gTLD meets the necessary security requirements designed to provide security for the financial services community.

It is important to note that the proposed standards are consistent with the recommendations and concerns put forth by international law enforcement that are “designed to aid in the prevention and disruption of efforts to exploit domain registration procedures by criminal groups for criminal purposes.” The law enforcement proposals have the support of ICANN’s Governmental Advisory Committee (GAC), the U.K. Serious Organized Crimes Agency, and the U.S. Federal Bureau of Investigation. Further, the GAC noted in its Nairobi Communiqué that law enforcement proposals were favorably viewed by the high tech crime experts in the G8 and Interpol.

A more thorough description of the Enhanced Security Standards can be found in the response to question 30.


Sunrise Period. As provided by the Trademark Clearinghouse model set forth in the ICANN Applicant Guidebook, the Sunrise service pre-registration procedure for domain names continues for at least 30 days prior to the launch of the general registration of domain names in the gTLD (unless FRS decides to offer a longer Sunrise period).

During the Sunrise period, holders of marks that have been previously validated by the Trademark Clearinghouse receive notice of domain names that are an identical match (as defined in the ICANN Applicant Guidebook) to their mark(s). Such notice is in accordance with ICANN’s requirements and is provided by FRS either directly or through FRS-accredited registrars.

FRS requires all registrants, either directly or through FRS-accredited registrars, to 1) affirm that said registrants meet the Sunrise Eligibility Requirements (SER) and 2) submit to the Sunrise Dispute Resolution Policy (SDRP), consistent with Section 6 of the Trademark Clearinghouse model. At a minimum, FRS will recognize and honor all word marks for which a proof of use was submitted and validated by the Trademark Clearinghouse, in addition to any additional eligibility requirements as specified earlier in this question.

During the Sunrise period, FRS and⁄or FRS-accredited registrars, as applicable, are responsible for determining whether each domain name is eligible to be registered (including in accordance with the SER).

To execute a successful Sunrise Period that meets all of ICANN’s necessary requirements, as well as ensures appropriate protection for rights holders, FRS will seek to engage an external third-party service provider with prior experience in the design and administration of sunrise periods. Once ICANN finalizes the implementation details and scope of the Trademark Clearinghouse, FRS plans to incorporate such details into its Sunrise efforts. The current proposed model anticipates that FRS will run two different Sunrise periods followed by a Real Time Registration Period for the entire banking community. The current proposal is set forth below:

Founder’s Sunrise - This Sunrise will be offered to those participants in the FRS Founder’s Program. They will have the first opportunity to secure .bank second-level domains that represent their trademarks, trade names or service marks and will operate on a first come, first served basis. As the universe of founding members is quite small, we do not anticipate many registration conflicts.

General Sunrise for the larger .bank gTLD community - Following the Founder’s Sunrise, this Sunrise period will allow eligible members of the .bank gTLD community to register domains that represent their trademarks, trade names or service marks. This Sunrise will run for a period of time, but will not operate on a first come, first served basis. Due to the limited and restrictive nature of the .bank namespace, FRS does not envision many significant issues regarding multiple financial service community members vying for the same domain name. However, in the event there are multiple registrations a domain name during General Sunrise, a two-step process will determine which registrant receives the domain. Within the guidelines set forth by ICANN for protecting trademark⁄registered name rights, first preference will be given to the applicant with proven (registered) rights to a name. If all contending registrants have an equal right, all will be asked to submit a proposed use plan and application fee to demonstrate to FRS how the TLD will be used. Emphasis will be placed on developing and deploying the domain. FRS will employ an independent arbiter to review and make the initial recommendation regarding awarding the domain to FRS Board of Directors. In the event that there is not a clear cut winner after these steps are undertaken, the parties may opt to proceed to a mechanism of last resort: auction.


Trademark Claims Service. As provided by the Trademark Clearinghouse model set forth in the ICANN Applicant Guidebook, all new gTLDs will have to provide a Trademark Claims Service for a minimum of 60 days after the launch of the general registration of domain names in the gTLD (Trademark Claims Period).

During the Trademark Claims Period, in accordance with ICANN’s requirements, FRS or the FRS-accredited registrar will send a Trademark Claims Notice to any prospective registrant of a domain name that is an identical match (as defined in the ICANN Applicant Guidebook) to any mark validated in the Trademark Clearinghouse. The Trademark Claims Notice will include links to the Trademark Claims as listed in the Trademark Clearinghouse and will be provided at no cost.

Prior to registration of said domain name, FRS, or the FRS-accredited registrar, will require each prospective registrant to provide the warranties dictated in the Trademark Clearinghouse model set forth in the ICANN Applicant Guidebook. Those warranties will include receipt and understanding of the Trademark Claims Notice and confirmation that registration and use of said domain name will not infringe on the trademark rights of the mark holders listed. Without receipt of said warranties, FRS, or the FRS-accredited registrar, will not process the domain name registration.

Following the registration of a domain name, the FRS-accredited registrar will provide a notice of domain name registration to the holders of marks that have been previously validated by the Trademark Clearinghouse and are an identical match. This notice will be as dictated by ICANN. At a minimum, FRS will recognize and honor all word marks validated by the Trademark Clearinghouse.

Reserve Name Challenge Process. As noted in the response to Question 18, FRS will reserve a set of domain names prior to launch. These domain names will either be used by FRS in its capacity as Registry Operator for the management, operation, and purpose of the gTLD as set forth in Specification 9 of the template Registry Agreement, or they will be equitably allocated to members of the .bank gTLD community. The subset of domain names reserved for use by the FRS is necessary to create a trusted, hierarchical, and intuitive framework for the banking namespace to facilitate the ease by which consumers can navigate the gTLD.

Although these reserved words will be commonly used words and phrases and⁄or geographic terms, FRS wants to provide an enhanced RPM that will provide trademark owners with the option to challenge the reservation⁄potential use of these domain names. This challenge process will be modeled after the highly successful dotAsia Pioneering Program.


2 MECHANISMS DESIGNED TO IDENTIFY AND ADDRESS THE ABUSIVE USE OF REGISTERED NAMES ON AN ONGOING BASIS

In addition to the Sunrise and Trademark Claims services described in Section 1 of this response, FRS will implement and adhere to RPMs post-launch as mandated by ICANN, and confirm that registrars accredited for the .bank gTLD are in compliance with these mechanisms. Certain aspects of these post-launch RPMs may be administered on behalf of FRS by FRS-accredited registrars or by contracted third parties of FRS, such as its selected backend registry services provider, Verisign. Where applicable, these measures will be incorporated into the Registry-Registrar Agreement (RRA), which governs the legal relationship between FRS and its accredited registrars.

These post-launch RPMs include the established Uniform Domain-Name Dispute-Resolution Policy (UDRP), as well as the newer Uniform Rapid Suspension System (URS) and Trademark Post-Delegation Dispute Resolution Procedure (PDDRP). Where applicable, FRS will implement all determinations and decisions issued under the corresponding RPM.

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

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

- UDRP: The UDRP provides a mechanism for complainants to object to domain name registrations. The complainant files its objection with a UDRP provider and the domain name registrant has an opportunity to respond. The UDRP provider makes a decision based on the papers filed. If the complainant is successful, ownership of the domain name registration is transferred to the complainant. If the complainant is unsuccessful, ownership of the domain name remains with the domain name registrant. FRS and entities operating on its behalf adhere to all decisions rendered by UDRP providers. The UDRP must be incorporated by reference into the Registration Agreement developed by .bank accredited registrars. Prospective registrants must agree to be bound by the terms and conditions in connection with the UDRP in order to successfully register a name. These requirements will also be included in the RRA to ensure register compliance.

- URS: As provided in the Applicant Guidebook, all registries are required to implement the URS. Similar to the UDRP, a complainant files its objection with a URS provider. The URS provider conducts an administrative review for compliance with filing requirements. If the complaint passes review, the URS provider notifies the registry operator and locks the domain. A lock means that the registry restricts all changes to the registration data, but the name will continue to resolve. After the domain is locked, the complaint is served to the domain name registrant, who has an opportunity to respond. If the complainant is successful, the registry operator is informed and the domain name is suspended for the balance of the registration period; the domain name will not resolve to the original website, but to an informational webpage provided by the URS provider. If the complainant is unsuccessful, the URS is terminated and full control of the domain name registration is returned to the domain name registrant. Similar to the existing UDRP, FRS and entities operating on its behalf will comply with decisions rendered by the URS providers. In addition, the URS must be incorporated by reference into the Registration Agreement developed by .bank accredited registrars. Prospective registrants must agree to be bound by the terms and conditions in connection with the URS in order to successfully register a name. These requirements will also be included in the RRA to ensure register compliance.

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

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

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


Semi-annual Whois Verification
As part of their RRA all .bank registrars will be required to revalidate Whois data for each record they have registered in the gTLD. The registry will leave the ultimate determination of how to implement this procedure to each registrar, but it must include one of the following approved methods:

1) Email with a verification link that must be acted upon within a set time frame.
2) If the email verification is not acted upon in the proscribed timeframe, an outbound telemarketing effort to the individual listed as the administrative contact for the domain must be initiated to manually confirm the information contained in the Whois record.

Each method will require the use of two factor authentication to ensure the respondent is the original registrant.

Verification process for each registered domain name must take place twice a year within the following schedule:
1) Mid-registration Verification: No sooner than 120 days after initial registration or subsequent renewal, and no later than 200 days after initial registration or subsequent renewal.
2) Renewal Verification: No later than 30 days prior to expiration and no sooner than 90 days prior to expiration.

FRS, as operator of the registry, will perform audits of verified Whois information to ensure compliance and accuracy. In addition, the registry will allow interested parties to report cases of inaccurate Whois information via an inbound reporting mechanism on the .bank gTLD webpage.


Active Participation in Anti-abuse Community Activities

FRS and its founding member organizations are, and will continue to be, active participants in the anti-abuse community. As this is a perpetual process, we take participation in various organizations, seminars and conferences very seriously and look to learn from the experience of others as well as share our experiences with said others to promote a safer online space. As the ABA and Roundtable led the development of the enhanced security standards for financial gTLDs, FRS and its member organizations will continue to take leadership roles to ensure that all financial related gTLDs are operated in a safe and secure manner that reflects the unique nature of their offering.



3 RESOURCING PLANS

Resource Planning

FRS is committed to operating the .bank gTLD in a manner that benefits the financial services community, specifically the banking industry, while demonstrating the highest levels of security, stability and resiliency. FRS strategically chose Verisign as its registry services provider because of their excellent track record in operating some of the worldʹs most complex and critical gTLDs. Verisignʹs support for the .bank gTLD will help ensure its success.

FRS will employ three full-time professionals to coordinate the operation of the .bank gTLD. In addition to its full-time staff, FRS will be supported by professionals at its founding organizations including, but not limited to, the American Banking Association and The Financial Services Roundtable. This support will include, but not be limited to, legal, finance and other services necessary to ensure the successful operation of the .bank gTLD.

As the .bank gTLD is a community supported effort, it is also expected that members of the banking and financial services communities will advise and support FRS in implementing the policies and procedures developed to govern the gTLD. This type of community effort has already taken place with the Security Standards Working Group and their development of Enhanced Security Standards for financial services gTLDs.

The following FRS professionals will be used to support Rights Protection Mechanisms:

- Managing Director
- Director of Operations
- Manager, Community Relations


Resource Planning Specific to Backend Registry Activities

Verisign, FRS’ selected backend registry services provider, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a gTLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements, as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for the .bank gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to FRS fully accounts for cost related to this infrastructure, which is provided as Line IIb.G, Total Critical Registry Function Cash Outflows, within the Question 46 financial projections response.

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

Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support the implementation of RPMs:
- Customer Affairs Organization: 9
- Customer Support Personnel: 36
- Information Security Engineers: 11

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

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

Similar gTLD applications: (1)