29 Rights Protection Mechanisms

Prototypical answer:

Rights protection is a core responsibility of the Top-Level Domain (“TLD”) operator, and is supported by a well-developed plan for rights protection that includes:

- Establishing mechanisms to prevent unqualified registrations (e.g., registrations made in violation of the registry’s eligibility restrictions or policies);
- Implementing a robust Sunrise program, utilizing the Trademark Clearinghouse, the services of one of ICANN’s approved dispute resolution providers, a trademark validation agent, and drawing upon sunrise policies and rules used successfully in previous gTLD launches;
- Implementing a professional trademark claims program that utilizes the Trademark Clearinghouse, and drawing upon models of similar programs used successfully in previous TLD launches;
- Complying with the requirements of the Uniform Rapid Suspension System (“URS”);
- Complying with the Uniform Domain Name Dispute Resolution Policy (“UDRP”);
- Complying with the Registry Restrictions Dispute Resolution Procedure (“RRDRP”);
- Complying with the Trademark Post-Delegation Dispute Resolution Policy (“PDDRP”); and,
- Including all ICANN-mandated and independently developed rights protection mechanisms (“RPMs”) in the registry-registrar agreement entered into by ICANN-accredited registrars authorized to register names in the TLD

The response below details the rights protection mechanisms at the launch of the TLD (Sunrise and Trademark Claims Service) which comply with rights protection policies (URS, UDRP, RRDRP, PDDRP, and other ICANN RPMs), outlines additional provisions made for rights protection, and provides the resourcing plans.


A. Safeguards for rights protection at the launch of the TLD

This TLD will satisfy the rights protection mechanisms described in the New gTLD Registry Agreement.

Merck KGaA will implement a Sunrise period of 30 days for the purpose of complying with ICANN requirements. Because the Registry Operator and the other community members will be the sole registrants within this space, there will be no other registrants eligible to reserve or register domain names during this period.

Notice will be provided to all relevant trademark holders in the Clearinghouse if someone is seeking a Sunrise registration. This notice will be provided to holders of marks in the Clearinghouse that are an Identical Match to the name to be registered during Sunrise.

The Registry Operator will develop and implement an appropriate Sunrise Dispute Resolution Policy (SDRP), containing the elements specified by ICANN, for the resolution of any disputes which might in theory arise during this period. The proposed Sunrise Eligibility Requirements (SERs) will include: (i) ownership of a mark (that satisfies the criteria in section 7.2), (ii) optional registry elected requirements re: international class of goods or services covered by registration; (iii) representation that all provided information is true and correct; and (iv) provision of data sufficient to document rights in the trademark. The The proposed SDRP will allow challenges based on the four grounds specified in the New gTLD Registry Agreement: (i) at time the challenged domain name was registered, the registrant did not hold a trademark registration of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; (ii) the domain name is not identical to the mark on which the registrant based its Sunrise registration; (iii) the trademark registration on which the registrant based its Sunrise registration is not of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; or (iv) the trademark registration on which the domain name registrant based its Sunrise registration did not issue on or before the effective date of the Registry Agreement and was not applied for on or before ICANN announced the applications received.

The launch of this TLD will include the operation of a trademark claims service according to the defined ICANN processes for checking a registration request and alerting trademark holders of potential rights infringement. The Trademark Claims Service will operate for at least the first 60 days that the registry is open for general registration. We will use the Trademark Claims Notice provided in the Applicant Guidebook, We will provide the prospective registrant access to the Trademark Clearinghouse Database information referenced in the Trademark Claims Notice to enhance understanding of the Trademark rights being claimed by the trademark holder. These links shall be provided in real time without cost to the prospective registrant.


B. Ongoing rights protection mechanisms

Several mechanisms will be in place to protect rights in this TLD. As described in responses #27 and #28, measures are in place to ensure domain transfers and updates are only initiated by the appropriate domain holder, and an experienced team is available to respond to legal actions by law enforcement or court orders.

This TLD will conform to all ICANN RPMs including URS (defined below), UDRP, PDDRP, RRDRP and all measures defined in Specification 7 of the new TLD agreement.

B.1 Uniform Rapid Suspension (URS)

The Registry Operator will implement decisions rendered under the URS on an ongoing basis. Per the URS policy posted on ICANN’s Web site as of this writing, the Registry Operator will receive notice of URS actions from the ICANN-approved URS providers. These emails will be directed immediately to the Registry Operator’s support staff, which is on duty 24x7. The support staff will be responsible for creating a ticket for each case, and for executing the directives from the URS provider. All support staff will receive pertinent training.

As per ICANN’s URS guidelines, within 24 hours of receipt of the notice of complaint from the URS provider, the Registry Operator shall “lock” the domain, meaning the registry shall restrict all changes to the registration data, including transfer and deletion of the domain names, but the name will remain in the TLD DNS zone file and will thus continue to resolve. The support staff will “lock” the domain by associating the following EPP statuses with the domain and relevant contact objects:

- ServerUpdateProhibited, with an EPP reason code of “URS”
- ServerDeleteProhibited, with an EPP reason code of “URS”
- ServerTransferProhibited, with an EPP reason code of “URS”
- The registry operator’s support staff will then notify the URS provider immediately upon locking the domain name, via email

The Registry Operator’s support staff will retain all copies of emails from the URS providers, assign them a tracking or ticket number, and will track the status of each opened URS case through to resolution via spreadsheet or database.

The Registry Operator’s support staff will execute further operations upon notice from the URS providers. The URS provider is required to specify the remedy and required actions of the registry operator, with notification to the registrant, the complainant, and the registrar.

As per the URS guidelines, if the complainant prevails, the “registry operator shall suspend the domain name, which shall remain suspended for the balance of the registration period and would not resolve to the original web site. The nameservers shall be redirected to an informational web page provided by the URS provider about the URS. The WHOIS for the domain name shall continue to display all of the information of the original registrant except for the redirection of the nameservers. In addition, the WHOIS shall reflect that the domain name will not be able to be transferred, deleted or modified for the life of the registration.”

B.2 Community TLD considerations

In addition to the above-referenced RPMs (URS, DRP, PDDRP and RRDRP), and the Trademark Clearing House and Sunrise registration periods, the Registry Operator intends to implement two further rights protection mechanisms within the “.MERCK” space. These additional policies, the Charter Eligibility Dispute Resolution Policy (CEDRP) and the “.MERCK” Eligibility and Functionality Reconsideration Policy (ʺMEFRPʺ) are designed address circumstances of unqualified registrations within the space.

As provided in detail above, in sections 18(c), 20(e) and 28, the “.MERCK” space will contain a set of safeguards to ensure that only valid members of the Merck Community may register domain names within the new TLD. These procedures are fully detailed in our response to Question 28. In brief, the process to register a domain name in the space is three-fold, and a brief outline of the process is as follows:

- A prospective applicant must apply to the Corporate Legal Department of Merck KGaA to request a Merck Community Membership ID. A Membership ID is unique to a particular applicant⁄registrant, and therefore this step needs only be performed once by Community Member. When an application to receive a Merck Community Membership ID is received by Merck KGaA, the Registry Operator will evaluate the request and determine whether the prospective registrant qualifies as a member of the Merck Community. If the applicant is a member of the Community, a Merck Community Membership ID will be issued. If not, and no Membership ID is issued, the denied applicant would have recourse to an appeals process under the MEFRP (full text available for reference at the end of this section)
- Once a Merck Community Membership ID has been issued to a member, said member must also receive pre-approval of the particular second-level string or strings which the member would like to register. Again, the request must be submitted to the Corporate Legal Department of Merck KGaA. If Merck determines that the requested domain name registration would serve the purposes, and be in the best interests, of the Merck Community, the Registry Operator will issue a statement of consent to the member for each requested second-level string
- Once a prospective applicant for a “.MERCK” domain name has obtained a Merck Community Membership ID, and pre-approval for the its requested domain name string(s), it may then register the indicated “.MERCK” domain name through any ICANN-accredited registrar. The Registry Operator will then have the opportunity to review each “Pending Create” request for a domain name string to confirm compliance with the above process, and to ensure that all registrations within the space serve the best interests of the Merck Community

Pursuant to its reserved authority in the “.MERCK” Domain Name Registration Restrictions and Use Policy, MerckKGaA shall have the right to cancel, transfer, terminate, or otherwise make changes to any domain name application or registration within the space for the benefit of the Merck Community at large. Merck KGaA will undertake routine monitoring efforts to ensure that all of the websites active within the “.MERCK” space are being used within the guidelines set forward in the Registration Restrictions and Use Policy.

Should any third party believe that a “.MERCK” domain name has been registered by an entity which is not a member of the Merck Community, it may file a CEDRP complaint to have the issue addressed. Likewise, should a prospective applicant for a Merck Community Membership ID believe its application was denied incorrectly, it may appeal the decision under the MEFRP. Any registrant of a “.MERCK” domain name who believes Merck KGaA acts unfairly in cancelling, transferring or otherwise modifying its domain name registration on the basis of non-compliance with the Registration Restrictions and Use Policy for “.MERCK” shall also have recourse to an appeal under the MEFRP. The full text of the MEFRP Policy has been provided below for reference, and the a draft copy of the Registration Restrictions and Use Policy may be found in the answer to Question 28 above.

B.3 Rights protection via the Registry-Registrar and Registrar-Registrant Agreements

The following will be memorialized and be made binding via the Registry-Registrar and Registrar-Registrant Agreements (RRAs):

- The registry may reject a registration request or a reservation request, or may delete, revoke, suspend, cancel, or transfer a registration or reservation under the following criteria:

- to enforce registry policies and ICANN requirements; each as amended from time to time;
- that is not accompanied by complete and accurate information as required by ICANN requirements and⁄or registry policies or where required information is not updated and⁄or corrected as required by ICANN requirements and⁄or registry policies;
- to protect the integrity and stability of the registry, its operations, and the TLD system;
- to comply with any applicable law, regulation, holding, order, or decision issued by a court, administrative authority, or dispute resolution service provider with jurisdiction over the registry;
- to establish, assert, or defend the legal rights of the registry or a third party or to avoid any civil or criminal liability on the part of the registry and⁄or its affiliates, subsidiaries, officers, directors, representatives, employees, contractors, and stockholders;
- to correct mistakes made by the registry or any accredited registrar in connection with a registration; or
- as otherwise provided in the Registry-Registrar Agreement and⁄or the Registrar-Registrant Agreement


C. Reducing opportunities for behaviors such as phishing or pharming

In our response to question #28, the registry operator has described its anti-abuse program designed to address phishing and pharming. This program is designed to actively discover, verify, and mitigate problems without infringing upon the rights of legitimate registrants. This program is designed for use in the open registration period and includes an optional system for monitoring the TLD for phishing attacks and policies and procedures for verifying and mitigating phishing attacks. These procedures include the reporting of compromised Websites⁄domains to registrars for cleanup by the registrants and their hosting providers, and rapid takedown procedures for maliciously registered phishing domains. Additionally, in order reduce the risk of malicious activity no registrations within the space will be permitted through the use of privacy services.

Rather than repeating the policies and procedures here, please see our response to question #28 for full details.

Since all “.MERCK” applicants and domain names will be reviewed and approved, there is an exceptionally low chance that “.MERCK” domain names will be registered by criminals, for purposes such as phishing. There is a chance that the Web sites of innocent “.MERCK” community members may get compromise by criminals, in which case any cases will be reported to the registrar and registrant for mitigation and cleanup.


D. Draft “.MERCK” Eligibility and Functionality Reconsideration Policy (ʺMEFRPʺ)

This Policy is designed to address disputes between you, the Applicant for a Merck Community Membership ID number, the Applicant for a “.MERCK” domain name registration seeking approval from Merck KGaA for a particular second-level domain name within the “.MERCK” space, or the Registrant of a “.MERCK” domain name, and the Registry Operator of the “.MERCK” space. This Policy is incorporated by reference into all applications for Merck Community Membership IDs, requests for domain name Approval Statements, and Registration Agreements for domain name registrations in the “.MERCK” space.

D.1 Purpose

This “.MERCK” Eligibility and Functionality Reconsideration Policy (the ʺPolicyʺ) has been adopted by the Registry Operator and is incorporated by reference into your application for a Merck Community Membership ID and⁄or request for an Approval Statement for a “.MERCK” domain name string, and into any Registration Agreement you may have for a “.MERCK” domain name. It sets out the terms and conditions in connection with any challenge you may wish to make in relation to a Decision by the Registry Operator:

- that you do not or that you no longer meet the “.MERCK” eligibility requirements as described in the Registration Restrictions and Use Policy for “.MERCK” (ʺEligibility Requirementsʺ); or
- that your requested second-level domain name textual string is not in the best interests of the Mercy Community as a whole, or fails to meet the technical requirements for the domain space; or
- if you are the holder of a “.MERCK” domain name, to revoke your domain name registration (ʺrevocationʺ)

Any Challenge brought pursuant to this Policy must be submitted to Merck KGaA within thirty (30) days of the relevant Decision which forms the basis of the Challenge action.

Throughout this document, the terms ʺyouʺ, ʺyourʺ and “the Challenger” refer to the applicant for a Merck Community Membership ID or domain name Approval Statement, or the Registrant of a “.MERCK” domain name, as the case may be. The terms ʺus,ʺ ʺourʺ and ʺweʺ refer to the Registry Operator.

D.2 Your Representations

By applying for a Merck Community Membership ID, an Approval Statement, a “.MERCK” domain name registration, or by asking the Registrar to maintain or renew a domain name registration, you hereby represent and warrant to us that:

- the assertions that you made in your Merck Community Membership ID application, your Approval Statement request, and⁄or your Registration Agreement are complete and accurate;
- you are eligible to register a domain name within the “.MERCK” TLD space;
- to your knowledge, your registration of the requested domain name will not infringe upon or otherwise violate the rights of any third party;
- you are not registering the “.MERCK” domain name for an unlawful purpose, or for any purpose violative of the “.MERCK” Registration Restrictions and Use Policy; and
- you will not knowingly use the domain name in violation of the “.MERCK” Registration Restrictions and Use Policy, or any applicable laws or regulations

It is your responsibility to determine whether your domain name registration infringes or violates someone elseʹs rights.

D.3 Definitions

Approval Statement: A notice issued by Merck KGaA to a prospective Applicant for a “.MERCK” domain name, stating that the Registry Operator consents to the Applicant’s registration of such domain through an accredited Registrar.

Challenge: A Challenge is a request made by and Applicant for reconsideration under the “.MERCK” Eligibility and Functionality Reconsideration Policy of a Decision rendered by the Registry Operator.

Challenger: An applicant or registrant bringing a Challenge under the “.MERCK” Eligibility and Functionality Reconsideration Policy. Any person or entity against whom an adverse Decision has been made by the Registry Operator, with respect to i) a request to receive a Merck Community Membership ID, ii) a request to receive an Approval Statement, or iii) a domain name registration within the “.MERCK” space, may bring a Challenge pursuant to this Policy.

Community Panel: The Community Panel is the three-member panel appointed by the Registry Operator to resolve the Challenge brought pursuant to the “.MERCK” Eligibility and Functionality Reconsideration Policy. The Panel shall consist of one (1) representative of Merck KGaA, and two (2) representatives of members of the Merck Community.

Decision: Any Decision made by the Registry Operator:

- that the Applicant does not meet the Eligibility Requirements set out in the “.MERCK” Registration Restrictions and Use Policy; or
- that the Applicant’s requested second-level string does not in the best interests of the Merck Community; or
- to issue a Rejection Statement, indicating that the Applicant’s request for approval of a particular “.MERCK” domain name string has been rejected by Merck KGaA; or
- to revoke, transfer or otherweise modify the Registrant’s “.MERCK” domain name registration on the grounds that its use of the domain name is contrary to the requirements set forth in the “.MERCK” Registration Restrictions and Use Policy

Finding: This is the decision made by the Community Panel respect to any Challenge brought pursuant to this Policy.

ICANN: The Internet Corporation for Assigned Names and Numbers.

Merck Community Membership ID: A permanently assigned identification number assigned by the TLD Registry Operator to a member of the Merck Community. Such Merck Community Membership ID must be applied for by the Applicant and, once issued, may be used to enable the registration of a “.MERCK” domain name.

Panelist: A member of the Community Panel appointed by the Registry Operator to hear the Challenge.

Party: A Party means the Challenger or the Registry Operator.

Registrar: Any ICANN-accredited registrar who offers “.MERCK” domain names for registration, following the registration mechanism outlined in the “.MERCK” Registration Restrictions and Use Policy and in conjunction with the Registry Service Provider.

Registry Operator: The Registry Operator for the “.MERCK” TLD is Merck KGaA.

Registry Service Provider: The Registry Service Provider for the “.MERCK” TLD shall be Afilias LTD.

Rejection Statement: A notice issued by Merck KGaA to a prospective Applicant for a “.MERCK” domain name, stating that the Registry Operator does not consent to the Applicant’s registration of such domain through an accredited Registrar


D.4 Mandatory Proceeding.

You are required to submit any challenge concerning a Decision by us denying the issuance of a Merck Community Membership ID or Approval Statement, or revocation of your “.MERCK” domain name registration, to a mandatory Challenge proceeding conducted in accordance with this Policy. Any such Challenge will serve as a request for reconsideration, or appeal, of our Decision, and will be decided by a three-member panel consisting of one (1) representative from Merck KGaA, and two (2) representatives from Merck Community members.


D.5 Challenge Procedure

- The Challenger shall submit its Challenge, including any annexes, electronically to the Registry Operator, to the email address: [insert email address when available].

- The Challenge shall:
* Request that the Challenge be submitted for decision in accordance with the Policy and these Rules;
* Confirm that the Challenge is being submitted no later than thirty (30) calendar days from the rendering of the relevant Decision by the Registry Operator;
* Provide the name and electronic contact information of the Challenger and of any representative authorized to act on behalf of the Challenger for this purposes of the proceeding;
- As appropriate for the given Challenge, the Challenger must:
* provide a copy of the rejected Application for a Merck Community Membership ID;
* Provide a copy of the Rejection Statement; or
* specify the domain name(s) that is⁄are the subject of the Challenge
* In the case of a Challenge to a Decision regarding a registered “.MERCK” domain name(s), the Challenger must identify the Registrar(s) with whom the domain name(s) is⁄are registered at the time the Challenge is filed;
- Describe, in accordance with this Policy, the grounds on which the Challenge is made, including, as appropriate:
* why the Challenger believes it should be properly deemed a member of the Merck Community
* why the second-level string applied would, in fact, be in the best interests of the Merck Community and serve the purposes outlined in the “.MERCK” Registration Restrictions and Use Policy; and⁄or
* why the Challenger’s “.MERCK” domain name(s) should be considered as having been used properly in accordance with the “.MERCK” Registration Restrictions and Use Policy
- Specify the remedy sought;
-identify any other legal proceedings, if any, that have been commenced or terminated in connection with or relating to any of the domain name(s) that may be the subject of the Challenge;
- Conclude with the following statement followed by the signature (in any electronic format) of the Challenger or its authorized representative:
* ʺThe Challenger agrees that its claims and remedies concerning the registration of the domain name (if any), the dispute, or the disputeʹs resolution shall be solely against the Registry Operator and waives all such claims and remedies against
* the Registrar,
* the Registry Service Provider, and
* the Internet Corporation for Assigned Names and Numbers, as well as their directors, officers, employees, and agentsʺ
* ʺThe Challenger certifies that the information contained in this Challenge is to the best of Challengerʹs knowledge complete and accurate, that this Challenge is not being presented for any improper purpose, such as to harass, and that the assertions in this Challenge are warranted under these Rules and under applicable law, as it now exists or as it may be extended by a good-faith and reasonable argument.ʺ; and
- Annex any documentary or other evidence, together with a schedule indexing such evidence

The Challenge may relate to more than one domain name, provided that the domain names are registered by the same Challenger and were the subject of the same Decision which forms the basis of the Challenge filing

The Registry Operator shall review the Challenge for formal compliance with this MEFRP Policy, and will provide the Challenger with a period of time, not to exceed 5 calendar days, to correct any deficiencies or supply additional information. The Registry Operator shall then appoint a Community Panel to hear the Challenge.

The Registry Operator shall send to the Community Panel, upon its appointment, a copy of the Challenge, including any annexes, and a statement from the Registry Operator outlining the reasons for its Decision
- The Community Panel shall:
* conduct the proceeding in such manner as it considers appropriate in accordance with this Policy;
* ensure that the Parties are treated with equality and that each Party is given a fair opportunity to present its case;
* ensure that the proceeding takes place with due expedition. It may, at the request of a Party or on its own motion, extend, in exceptional cases, a period of time fixed by these Rules or by the Community Panel
* determine the admissibility, relevance, materiality and weight of the evidence;
* in its sole discretion, request any additional information from either the Challenger or the Registry Operator that it deems necessary in order to make its Finding
- There shall be no in-person hearings (including hearings by teleconference, videoconference, and web conference), unless the Community Panel determines, in its sole discretion and as an exceptional matter, that such a hearing is necessary for deciding the Challenge
- The Community Panel shall decide a Challenge on the basis of the statements and documents submitted and in accordance with this Policy, the “.MERCK” Registration Restrictions and Use Policy, and any rules and principles of law that it deems applicable. In the absence of exceptional circumstances, the Panel shall forward its Finding on the Challenge to the Parties no later than twenty (20) business days from its appointment. All Findings shall be made by majority

The remedies available to a Challenger pursuant to any proceeding before a Community Panel shall be limited to, as appropriate:
* the issuance by the Registry Operator of a Merck Community Membership ID,
* the issuance by the Registry Operator of an Approval Statement for a requested domain name registration, or
* the issuance by the Registry Operator of a new Approval Statement, enabling the Challenger to re-register a domain name previously revoked under the initial Decision.
- Should the Panel decide in favor of the Challenger the Registry Operator shall, no later than 14 days from the issuance of the Panel’s decision, provide the Challenger with the panel-ordered Merck Community Membership ID or Approval Statement, as appropriate

D.6 Maintaining the Status Quo

We will not request the Registrar to cancel, transfer, activate, deactivate, or otherwise change the status of any domain name registration the subject of a Challenge, or held by a Challenger bringing a Challenge regarding the revocation of either its Merck Community Membership ID or Approval Statement, during the pendency of any proceeding brought pursuant to this Policy.

D.7 Settlement or Other Grounds for Termination

If, before the Community Panel has reached its Finding, the Parties agree on a settlement, the Community Panel shall terminate the proceeding.

D.8 Transfers During a Dispute

- Transfers of a Domain Name to a New Holder. You may not transfer your domain name registration to another holder (i) during a pending proceeding brought pursuant to this Policy or for a period of fifteen (15) business days (as observed in the location of the Registrar’s principal place of business) after such proceeding is concluded; or (ii) during a pending court proceeding or arbitration commenced regarding your domain name, unless you have received permission for said transfer (pursuant to the “.MERCK” Registration Restrictions and Use Policy) from the Registry Operator, and the party to whom the domain name registration is being transferred agrees, in writing, to be bound by the decision of the court or arbitrator. We reserve the right to request the Registrar to cancel any transfer of a domain name registration to another holder that is made in violation of this subparagraph, or in violation of the terms and conditions of the “.MERCK” Registration Restrictions and Use Policy.
- Changing Registrars. You may not transfer your domain name registration to another registrar during a pending proceeding brought pursuant to this Policy or for a period of fifteen (15) business days (as observed in the location of our principal place of business) after such proceeding is concluded. You may transfer administration of your domain name registration to another registrar during a pending court action or arbitration, provided that the domain name you have registered shall continue to be subject to the proceeding commenced by you in accordance with the terms of this Policy.

D.9 Policy Modifications

We reserve the right to modify this Policy at any time with the permission of ICANN. We will post our revised Policy at [insert URL when finalized] at least thirty (30) calendar days before it becomes effective. Unless this Policy has already been invoked by the submission of a Challenge, in which event the version of the Policy in effect at the time it was invoked will apply to you until the dispute is over, all such changes will be binding upon you with respect to any domain name registration dispute, whether the dispute arose before, on or after the effective date of our change. In the event that you object to a change in this Policy, your sole remedy is to cancel your “.MERCK” domain name registration, provided that you will not be entitled to a refund of any fees paid. The revised Policy will apply to you until you cancel or fail to renew your “.MERCK” domain name registration.


F. Rights protection resourcing plans

Merck KGaA will provide members of its legal department staff to review membership applications, review requests for domain name strings, and process business related to the Charter Eligibility Dispute Resolution Policy (CEDRP) and the “.MERCK” Eligibility and Functionality Reconsideration Policy (MEFRP). During the start-up⁄roll-out period, this function may require the full-time equivalent of one staff member. The responsibilities may be split among several existing staff members, including a staff attorney or attorneys, and an administrator⁄manager. On an ongoing basis, these RPM functions will require the full-time equivalent of one-half staff member.

Supporting RPMs also requires several departments within the registry operator as well as within Afilias. The implementation of Sunrise and the Trademark Claims service and on-going RPM activities will pull from the 102 Afilias staff members of the engineering, product management, development, security and policy teams at Afilias and staff at the Registry Operator. No additional hardware or software resources are required to support this as Afilias has fully-operational capabilities to manage abuse today.

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