28 Abuse Prevention and Mitigation

Prototypical answer:

In order to safeguard the security and stability of .DNP, as well as the Internet at large, Dai Nippon Printing Co., Ltd. (the Applicant) takes abuse very seriously and employs proactive measures to mitigate abusive activities.

In general, the Applicant’s abuse mitigation strategies fall into the following broad areas:

- conducting pre-verification of registration eligibility
- developing and publishing a set of comprehensive abuse policies including clear definitions of abusive activities;
- establishing and publishing a single abuse point of contact to address and resolve abuse complaints at Registry startup and on an ongoing basis; and
- developing procedures for handling complaints, including takedown requests, in a timely manner.

Pre-Verification of Registration Eligibility
.DNP is a domain for Dai Nippon Printing Co., Ltd. and its stakeholders, and the Applicant believes that it is important to prevent unqualified registrations in order to keep the TLD space safe and reliable; therefore, the Applicant will conduct registrant pre-verification in all .DNP registration phases.

Registration and management of .DNP domain names will be carried out via the .DNP dedicated account provided by an accredited registrar. Access to the .DNP dedicated account will be limited to the registrants and their authorized administrative contacts, subject to verification of registration eligibility. The verification will be conducted by the Applicant, and affiliate organizations that wish to apply for a .DNP dedicated account will be required to provide proof of registration eligibility to the Applicant via a .DNP accredited registrar. Proposed valid forms of documentary proof include, but are not limited to,
- company seal (registered or unregistered)
- signature of management staff

The registry will conduct verification on a per-registrant basis only. Once verified, the registrant or its authorized administrative contact will have access to the .DNP dedicated account, through which it may apply for multiple .DNP domain names without further verification, under the condition that the registrant and administrative contact information of an applied-for domain name is identical to that which the Applicant has verified. If there are any material changes to the verified information, the registrant or administrative contact must notify the Applicant of the change. Failure to comply with the policies may result in the suspension or cancellation of the .DNP dedicated account, and⁄or the denial, cancellation or transfer of any registration or transaction, as well as the placement of lock, hold or similar statuses on applying-for and⁄or existing domain names.

The registry believes that the verification will help mitigate abusive activities including abusive registrations as well as promote Whois accuracy.

Draft Abusive Use Policy
The registry defines abuse as any activity that may harm the stability and security of the DNS and Internet, including, but not limited to:

- Illegal or fraudulent activities;
- Phishing;
- Pharming;
- Using or distributing malicious software (malware);
- Sending unsolicited bulk messages (spam);
- Posting, trading, or exchanging information that harms minors; and
- Posting information that is offensive to public order or morals.

The registry reserves the right to deny, cancel or transfer any registration or transaction, or place any domain name on lock, hold or similar status, at its sole discretion, to enforce the policy.

Abuse Public Contact Information
In order to comply with Specification 6.4.1 of New gTLD Agreement, the Applicant will provide to ICANN its Abuse contact details. The information will include a valid e-mail and mailing address and a primary contact, and the Applicant will promptly provide to ICANN a notice of any changes to the contact.

Also, the Applicant will also publish its abuse public contact information on its web site when it publicly releases the .DNP domain name registration policies, The abuse public contact will be responsible for handling complaints concerning abusive activities relating to domains registered under the .DNP TLD that violate the Abuse Use Policy and require expedited attention. The abuse public contact will be available 24 hours a day 7 days a week. A person who wishes to contact the abuse public contact will be required to submit the Abuse Complaint Form via e-mail or via the online Abuse Complaint Form on the Registry web site.

Abuse Complaint Form
In order to gather pertinent information about a reported incident, facilitate accurate investigation, and avoid false alarms ⁄ positives, the Applicant will provide an Abuse Complaint form on the Applicant website. The Abuse complaint form is required at the time a person contacts the abuse public contact and can be submitted online or by email in the format specified on the Applicant website.

Draft Takedown Procedure
- Complaint is submitted using the abuse complaint form via email or the Applicant web site;
- Upon receiving a complaint, the Applicant’s operational and registrar support team will
* assign a ticket number
* review complaint form
- request additional information if complaint form is deemed insufficient to carry out effective investigation
l investigate the complaint to verify accuracy, and to record proof of abuse
l based on the nature of the abuse, assign level of severity: normal or emergency
- Emergency: the Applicant will suspend the domain name in question and close the complaint ticket. At the same time, it will open a ticket to inform the sponsoring registrar of the suspension along with the reason.
- Nomal: open a ticket to inform the sponsoring registrar to take corrective actions. The registrar must inform the Applicant of actions taken. If the registrar does not take any action (that includes no response from the registrar) within a reasonable timeframe, the Applicant will suspend the domain name in question and close the complaint ticket.
* If the domain name was suspended by the Applicant, and the situation is remedied by the registrant, the registrar will contact the Applicant via the ticket number. The registry operational and registrar support team will verify that the issue has indeed been remedied and re-enable the domain name, closing the ticket.
* All actions by the operational and registrar support team will be logged

The registry understands that the Registration Abuse Policies Working Group has been working on developing best practices for registries and registrars addressing the fraudulent use of domain names. The registry will closely follow the working group discussions and documents, with a view of adopting the best practices to enhance abuse mitigation capabilities.

In addition, the Applicant will participate in security forums to keep track of the latest developments in abuse mitigation best practices and refine our abuse policies and procedures from time to time.


Orphan Glue Records
The registry’s view on orphan glue records is consistent with the Security and Stability Advisory Committee Comment on Orphan Glue Records
〈http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf〉. The registry supports the use of orphan glue records for legitimate purposes. Upon receiving a complaint relating to an orphaned glue record used in connection with malicious activities, the Applicant will verify and take corrective actions in accordance with its takedown procedures.

Resourcing Plan
The implementation and operation of this aspect of the Applicant falls under the areas of responsibility of the following teams:
- Cloud Registry Operational Support (six personnels) - monitoring and fault response.
- GMO Registry Operational and Registrar Support (three personnels) - acting as the abuse point of contact, handling matters related to the Crawler, escalating to the relevant departments as required.

Initial Implementation
Initial implementation of this aspect of registry operations refers to the development of detailed procedures on handling abuse reports and Crawler warnings, configuration of the ticketing system, and training of the operational staffs.

During this phase, all teams described above are involved in the planning and implementation of their respective systems in support of this component.

Ongoing Maintenance
The ongoing maintenance of this aspect will fall under the responsibilities of the GMO Registry Operational and Registrar Support Team as well as the Cloud Registry Operational Support Team. GMO Registry acts as the primary abuse point of contact who handles complaints received and escalating to Cloud Registry as necessary. In addition, Cloud Registry also monitors security mailing lists for takedown requests arising from security researchers and emergency response teams.

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