ICANN New gTLD Application

Bloomberg IP Holdings, LLC (“BIP”) was formed by Michael R. Bloomberg for the purpose of applying to run the .bloomberg gTLD. Mr. Bloombergʹs funding of BIP assures it will have the resources to fulfill its obligations as a registry without reliance upon revenue from licensing and immune from budget shortfalls.

BIP intends to use the .bloomberg gTLD to register domain names for Bloomberg Philanthropies, a name used to describe the umbrella of Mr. Bloomberg’s charitable work, including personal giving, and his efforts in political advocacy and other areas. The gTLD may also be used to register domain names for Bloomberg L.P. for use by it and its affiliates in their lines of business, including the BLOOMBERG PROFESSIONAL service (a global financial information service) and other media and consumer businesses.

Bloomberg Philanthropies. Mr. Bloomberg believes in the power of philanthropy and political advocacy to change peopleʹs lives for the better. That is why Mr. Bloomberg has, through Bloomberg Philanthropies, committed so much of his time, energy and resources to the causes in which he believes. Mr. Bloomberg has donated more than $1.6 billion to a variety of causes and organizations. In 2011, $330 million was distributed by Bloomberg Philanthropies, placing Mr. Bloomberg in the top five of The Chronicle of Philanthropyʹs list of Americaʹs top 50 philanthropists. Bloomberg Philanthropies works to advance many areas, primarily including:

Public Health: Bloomberg Philanthropies has invested more than $375 million over the past six-years, and has committed more than $220 million to be spent over the next four years. This money has been and will be used to combat the growing number of deaths caused by non-communicable diseases worldwide. Efforts have been directed toward reducing global tobacco use, improving global road safety, and a program to improve maternal health in Tanzania;

The Environment: As chair of the C40 Cities Climate Leadership Group, Mr. Bloomberg is working with the world’s largest cities to help reduce green house gas emissions, and has made a specific investment in the Sierra Club’s Beyond Coal Campaign, to help eliminate one-third of the top polluting coal plants in the United States by 2020;

Government Innovation: Bloomberg Philanthropies has made investments to spread proven and promising ideas among cities, including the Innovation Delivery Team program to help mayors drive bold reform, and New York City’s efforts to improve outcomes for young black and Hispanic men. Alongside this, Bloomberg Philanthropies contributes to work with Cities of Service, Mayors against Illegal Guns, and the Mayor’s Fund to Advance NYC;

The Arts: Bloomberg Philanthropies invests in strengthening New York City arts and cultural organizations, which include a world-class management training program; and

Education: Bloomberg Philanthropies has targeted efforts to strengthen leadership within school communities and advance good public policy at the federal, state and local levels.

To ensure his charitable efforts are efficient and effective, Mr. Bloomberg has taken steps to protect the goodwill in his name and the marks used by his organizations. Mr. Bloomberg has thus sought trademark protection in the United States and twelve other countries for the marks BLOOMBERG PHILANTHROPIES and BLOOMBERG FAMILY FOUNDATION. Mr. Bloomberg also uses a website, found at 〈bloomberg.org〉, to promote his charitable efforts.

Bloomberg L.P. In 1981, Michael R. Bloomberg founded the company that would come to be called Bloomberg L.P. (“BLP”). BLP has since become one of the largest worldwide providers of financial news, data, analytics and information and related goods and services.

BLP’s international expansion began in 1987 with the opening of offices in London and Tokyo, and continued with establishment of offices in Sydney (1989), Singapore (1990), Frankfurt (1992) and Hong Kong (1993). BLP employs more than 15,000 people in over 135 offices, including over 2,300 professionals in more than 152 news bureaus.

In order to distinguish its products and services, BLP adopted the “Bloomberg” trade name and BLOOMBERG trademark and service mark (the “BLOOMBERG Mark”) at least as early as August 1987. In 2007, BLP reorganized and placed ownership of its BLOOMBERG Marks and the related domain names in a subsidiary, Bloomberg Finance L.P. (“BFLP”), and regional subsidiaries of BFLP (BLP, BFLP and their subsidiaries, collectively, “Bloomberg”). Bloomberg’s corporate website 〈www.bloomberg.com〉 provides details about Bloomberg and the products and services Bloomberg provides to the public worldwide.

Bloomberg has applied for or obtained registration of the BLOOMBERG Mark in the United States and numerous other jurisdictions, including the African Union (O.A.P.I.), Argentina, Aruba, Australia, Austria, Bahamas, Bahrain, Bangladesh, Barbados, Belize, Benelux, Bermuda, Bolivia, Botswana, Brazil, Brunei Darussalam, Bulgaria, Canada, Cayman Islands, Chile, China, Colombia, Costa Rica, Croatia, Cyprus, Czech Republic, Denmark, Ecuador, Egypt, Estonia, European Union, Fiji, Finland, France, Germany, Ghana, Gibraltar, Greece, Guernsey, Hong Kong, Hungary, Iceland, Indonesia, Ireland, Israel, Italy, Jamaica, Japan, Jersey, Jordan, Kenya, Kuwait, Latvia, Lebanon, Liechtenstein, Lithuania, Macao, Malaysia, Malta, Mexico, Monaco, Morocco, Namibia, Netherlands Antilles, New Zealand, Norway, Oman, Pakistan, Panama, Peru, Poland, Portugal, Puerto Rico, Romania, Russia, Saint Kitts and Nevis, St. Vincent and the Grenadines, Saudi Arabia, Singapore, Slovakia, Slovenia, South Africa, South Korea, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tangier Zone, Thailand, Trinidad and Tobago, Turkey, Ukraine, the United Arab Emirates, the United Kingdom, Uruguay, Venezuela and Vietnam.

Bloomberg is the registrant of over 1000 domain names incorporating “bloomberg” or a misspelling thereof, including 〈bloomberg.com〉, 〈bloomberg.net〉, 〈bloomberg.biz〉 and 〈bloomberg.info〉. Bloomberg registered 〈bloomberg.com〉 in 1993 and has used this domain name since then to build one of the most visited financial news websites in the world.

In addition to providing financial information, data and transactional services through its terminal product and over the Internet, Bloomberg collects and reports news through Bloomberg Markets and Bloomberg Businessweek magazines, over the radio through WBBR - 1130 AM in New York City and syndication throughout the US and through satellite radio providers, and over cable and satellite television provided 24-hours a day throughout the world and local television partnerships in India, Turkey, Russia, Mongolia and the Middle East.

Bloomberg has devoted substantial resources to enforcing its rights in the BLOOMBERG Mark. Bloomberg has successfully established BLOOMBERG as a preeminent brand throughout the world, representing the highest quality of news, information and financial transactional services. BIP may register domain names for Bloomberg for its business purposes. Consistent with its provision of cutting-edge online services, Bloomberg looks forward to using these domain names in innovative ways to improve communication with its customers.

All figures, tables and diagrams referenced in the following response can be found in the attachment titled “bloomberg_.string_Q23 Figures”

As BIP’s selected provider of backend registry services, Verisign provides a comprehensive system and physical security solution that is designed to ensure a TLD is protected from unauthorized disclosure, alteration, insertion, or destruction of registry data. Verisign’s system addresses all areas of security including information and policies, security procedures, the systems development lifecycle, physical security, system hacks, break-ins, data tampering, and other disruptions to operations. Verisign’s operational environments not only meet the security criteria specified in its customer contractual agreements, thereby preventing unauthorized access to or disclosure of information or resources on the Internet by systems operating in accordance with applicable standards, but also are subject to multiple independent assessments as detailed in the response to Question 30, Security Policy. Verisign’s physical and system security methodology follows a mature, ongoing lifecycle that was developed and implemented many years before the development of the industry standards with which Verisign currently complies. Please see the response to Question 30, Security Policy, for details of the security features of Verisign’s registry services.

Verisign’s registry services fully comply with relevant standards and best current practice RFCs published by the Internet Engineering Task Force (IETF), including all successor standards, modifications, or additions relating to the DNS and name server operations including without limitation RFCs 1034, 1035, 1982, 2181, 2182, 2671, 3226, 3596, 3597, 3901, 4343, and 4472. Moreover, Verisign’s Shared Registration System (SRS) supports the following IETF Extensible Provisioning Protocol (EPP) specifications, where the Extensible Markup Language (XML) templates and XML schemas are defined in RFC 3915, 5730, 5731, 5732, 5733, and 5734. By strictly adhering to these RFCs, Verisign helps to ensure its registry services do not create a condition that adversely affects the throughput, response time, consistency, or coherence of responses to Internet servers or end systems. Besides its leadership in authoring RFCs for EPP, Domain Name System Security Extensions (DNSSEC), and other DNS services, Verisign has created and contributed to several now well-established IETF standards and is a regular and long-standing participant in key Internet standards forums.

Figure 23-1 summarizes the technical and business components of those registry services, customarily offered by a registry operator (i.e., Verisign), that support this application. These services are currently operational and support both large and small Verisign-managed registries. Customary registry services are provided in the same manner as Verisign provides these services for its existing gTLDs.
Through these established registry services, Verisign has proven its ability to operate a reliable and low-risk registry that supports millions of transactions per day. Verisign is unaware of any potential security or stability concern related to any of these services.

Registry services defined by this application are not intended to be offered in a manner unique to the new generic top-level domain (gTLD) nor are any proposed services unique to this application’s registry.

As further evidence of Verisign’s compliance with ICANN mandated security and stability requirements, Verisign allocates the applicable RFCs to each of the five customary registry services (items A – E above). For each registry service, Verisign also provides evidence in Figure 23-2 of Verisign’s RFC compliance and includes relevant ICANN prior-service approval actions.

Critical Operations of the Registry:

i. Receipt of Data from Registrars Concerning Registration of Domain Names and Name Servers.

See Item A in Figure 23-1 and Figure 23-2

ii. Provision to Registrars Status Information Relating to the Zone Servers. Verisign is BIP’s selected provider of backend registry services. Verisign registry services provisions to registrars status information relating to zone servers for the TLD. The services also allow a domain name to be updated with clientHold, serverHold status, which removes the domain name server details from zone files. This ensures that DNS queries of the domain name are not resolved temporarily. When these hold statuses are removed, the name server details are written back to zone files and DNS queries are again resolved. Figure 23-2 describes the domain name status information and zone insertion indicator provided to registrars. The zone insertion indicator determines whether the name server details of the domain name exist in the zone file for a given domain name status. Verisign also has the capability to withdraw domain names from the zone file in near-real time by changing the domain name statuses upon request by customers, courts, or legal authorities as required.

ii. Dissemination of TLD Zone Files.

See Item B in Figure 23-1 and Figure 23-2.

iv. Operation of the Registry Zone Servers. Verisign is BIP’s selected provider of backend registry services. Verisign, as a company, operates zone servers and serves DNS resolution from 76 geographically distributed resolution sites located in North America, South America, Africa, Europe, Asia, and Australia. Currently, 17 DNS locations are designated primary sites, offering greater capacity than smaller sites comprising the remainder of the Verisign constellation. Verisign also uses Anycast techniques and regional Internet resolution sites to expand coverage, accommodate emergency or surge capacity, and support system availability during maintenance procedures. Verisign operates BIP’s gTLD from a minimum of eight of its primary sites (two on the East Coast of the United States, two on the West Coast of the United States, two in Europe, and two in Asia) and expands resolution sites based on traffic volume and patterns. Further details of the geographic diversity of Verisign’s zone servers are provided in the response to Question 34, Geographic Diversity. Moreover, additional details of Verisign’s zone servers are provided in the response to Question 32, Architecture and the response to Question 35, DNS Service.

v. Dissemination of Contact and Other Information Concerning Domain Name Server Registrations

See Item C in Figure 23-1 and Figure 23-2.

Other Products or Services the Registry Operator Is Required to Provide Because of the Establishment of a Consensus Policy.

Verisign, BIP’s selected provider of backend registry services, is a proven supporter of ICANN’s consensus-driven, bottom-up policy development process whereby community members identify a problem, initiate policy discussions, and generate a solution that produces effective and sustained results. Verisign currently provides all of the products or services (collectively referred to as services) that the registry operator is required to provide because of the establishment of a Consensus Policy. For the 〈.bloomberg〉 gTLD, Verisign implements these services using the same proven processes and procedures currently in-place for all registries under Verisign’s management. Furthermore, Verisign executes these services on computing platforms comparable to those of other registries under Verisign’s management. Verisign’s extensive experience with consensus policy required services and its proven processes to implement these services greatly minimize any potential risk to Internet security or stability. Details of these services are provided in the following subsections. It shall be noted that consensus policy services required of registrars (e.g., Whois Reminder, Expired Domain) are not included in this response. This exclusion is in accordance with the direction provided in the question’s Notes column to address registry operator services.

Inter-Registrar Transfer Policy (IRTP). Technical Component: In compliance with the IRTP consensus policy, Verisign, BIP’s selected provider of backend registry services, has designed its registration systems to systematically restrict the transfer of domain names within 60 days of the initial create date. In addition, Verisign has implemented EPP and “AuthInfo” code functionality, which is used to further authenticate transfer requests. The registration system has been designed to enable compliance with the five-day Transfer grace period and includes the following functionality:

i. Allows the losing registrar to proactively ‘ACK’ or acknowledge a transfer prior to the expiration of the five-day Transfer grace period;

ii. Allows the losing registrar to proactively ‘NACK’ or not acknowledge a transfer prior to the expiration of the five-day Transfer grace period;

iii. Allows the system to automatically ACK the transfer request once the five-day Transfer grace period has passed if the losing registrar has not proactively ACK’d or NACK’d the transfer request.

Business Component: All requests to transfer a domain name to a new registrar are handled according to the procedures detailed in the IRTP. Dispute proceedings arising from a registrarʹs alleged failure to abide by this policy may be initiated by any ICANN-accredited registrar under the Transfer Dispute Resolution Policy. BIP’s compliance office serves as the first-level dispute resolution provider pursuant to the associated Transfer Dispute Resolution Policy. As needed Verisign is available to offer policy guidance as issues arise.

Security and Stability Concerns: Verisign is unaware of any impact, caused by the service, on throughput, response time, consistency, or coherence of the responses to Internet servers or end-user systems. By implementing the IRTP in accordance with ICANN policy, security is enhanced as all transfer commands are authenticated using the AuthInfo code prior to processing.

ICANN Prior Approval: Verisign has been in compliance with the IRTP since November 2004 and is available to support BIP in a consulting capacity as needed.

Unique to the TLD: This service is not provided in a manner unique to the 〈.bloomberg〉 TLD.
Add Grace Period (AGP) Limits Policy.

Technical Component: Verisign’s registry system monitors registrars’ Add grace period deletion activity and provides reporting that permits BIP to assess registration fees upon registrars that have exceeded the AGP thresholds stipulated in the AGP Limits Policy. Further, BIP accepts and evaluates all exemption requests received from registrars and determines whether the exemption request meets the exemption criteria. BIP maintains all AGP Limits Policy exemption request activity so that this material may be included within BIP’s Monthly Registry Operator Report to ICANN.

Registrars that exceed the limits established by the policy may submit exemption requests to BIP for consideration. BIP’s compliance office reviews these exemption requests in accordance with the AGP Limits Policy and renders a decision. Upon request, BIP submits associated reporting on exemption request activity to support reporting in accordance with established ICANN requirements.

Business Component: The Add grace period (AGP) is restricted for any gTLD operator that has implemented an AGP. Specifically, for each operator:

During any given month, an operator may not offer any refund to an ICANN-accredited registrar for any domain names deleted during the AGP that exceed (i) 10% of that registrarʹs net new registrations (calculated as the total number of net adds of one-year through ten-year registrations as defined in the monthly reporting requirement of Operator Agreements) in that month, or (ii) fifty (50) domain names, whichever is greater, unless an exemption has been granted by an operator.

Upon the documented demonstration of extraordinary circumstances, a registrar may seek from an operator an exemption from such restrictions in a specific month. The registrar must confirm in writing to the operator how, at the time the names were deleted, these extraordinary circumstances were not known, reasonably could not have been known, and were outside the registrarʹs control. Acceptance of any exemption will be at the sole and reasonable discretion of the operator; however ʺextraordinary circumstancesʺ that reoccur regularly for the same registrar will not be deemed extraordinary.

In addition to all other reporting requirements to ICANN, BIP identifies each registrar that has sought an exemption, along with a brief description of the type of extraordinary circumstance and the action, approval, or denial that the operator took.

Security and Stability Concerns: Verisign is unaware of any impact, caused by the policy, on throughput, response time, consistency, or coherence of the responses to Internet servers or end-user systems.
ICANN Prior Approval: Verisign, BIP’s backend registry services provider, has had experience with this policy since its implementation in April 2009 and is available to support BIP in a consulting capacity as needed.

Unique to the TLD: This service is not provided in a manner unique to the 〈.bloomberg〉 TLD.
Registry Services Evaluation Policy (RSEP)

Technical Component: Verisign, BIP’s selected provider of backend registry services, adheres to all RSEP submission requirements. Verisign has followed the process many times and is fully aware of the submission procedures, the type of documentation required, and the evaluation process that ICANN adheres to.

Business Component: In accordance with ICANN procedures detailed on the ICANN RSEP website (http:⁄⁄www.icann.org⁄en⁄registries⁄rsep⁄), all gTLD registry operators are required to follow this policy when submitting a request for new registry services.

Security and Stability Concerns: As part of the RSEP submission process, Verisign, BIP’s backend registry services provider, identifies any potential security and stability concerns in accordance with RSEP stability and security requirements. Verisign never launches services without satisfactory completion of the RSEP process and resulting approval.

ICANN Prior Approval: Not applicable.

Unique to the TLD: gTLD RSEP procedures are not implemented in a manner unique to the 〈.bloomberg〉 TLD.

Products or Services Only a Registry Operator Is Capable of Providing by Reason of Its Designation As the Registry Operator

Verisign, BIP’s selected backend registry services provider, has developed a Registry-Registrar Two-Factor Authentication Service that complements traditional registration and resolution registry services. In accordance with direction provided in Question 23, Verisign details below the technical and business components of the service, identifies any potential threat to registry security or stability, and lists previous interactions with ICANN to approve the operation of the service. The Two-Factor Authentication Service is currently operational, supporting multiple registries under ICANN’s purview.
BIP is unaware of any competition issue that may require the registry service(s) listed in this response to be referred to the appropriate governmental competition authority or authorities with applicable jurisdiction. ICANN previously approved the service(s), at which time it was determined that either the service(s) raised no competitive concerns or any applicable concerns related to competition were satisfactorily addressed.

Two-Factor Authentication Service:

Technical Component: The Registry-Registrar Two-Factor Authentication Service is designed to improve domain name security and assist registrars in protecting the accounts they manage. As part of the service, dynamic one-time passwords augment the user names and passwords currently used to process update, transfer, and⁄or deletion requests. These one-time passwords enable transaction processing to be based on requests that are validated both by “what users know” (i.e., their user name and password) and “what users have” (i.e., a two-factor authentication credential with a one-time-password).

Registrars can use the one-time-password when communicating directly with Verisign’s Customer Service department as well as when using the registrar portal to make manual updates, transfers, and⁄or deletion transactions. The Two-Factor Authentication Service is an optional service offered to registrars that execute the Registry-Registrar Two-Factor Authentication Service Agreement.

Business Component: There is no charge for the Registry-Registrar Two-Factor Authentication Service. It is enabled only for registrars that wish to take advantage of the added security provided by the service.

Security and Stability Concerns: Verisign is unaware of any impact, caused by the service, on throughput, response time, consistency, or coherence of the responses to Internet servers or end-user systems. The service is intended to enhance domain name security, resulting in increased confidence and trust by registrants.

ICANN Prior Approval: ICANN approved the same Two-Factor Authentication Service for Verisign’s use on .com and .net on 10 July 2009 (RSEP Proposal 2009004) and for .name on 16 February 2011 (RSEP Proposal 2011001).

Unique to the TLD: This service is not provided in a manner unique to the 〈.bloomberg〉 TLD.

All figures, tables and diagrams referenced in the following response can be found in the attachment titled “bloomberg_.string_Q24 Figures”

ROBUST PLAN FOR OPERATING A RELIABLE SRS

High-Level Shared Registration System (SRS) Description

Verisign, BIP’s selected provider of backend registry services, provides and operates a robust and reliable SRS that enables multiple registrars to provide domain name registration services in the top-level domain (TLD). Verisign’s proven reliable SRS serves approximately 915 registrars, and Verisign, as a company, has averaged more than 140 million registration transactions per day. The SRS provides a scalable, fault-tolerant platform for the delivery of gTLDs through the use of a central customer database, a web interface, a standard provisioning protocol (i.e., Extensible Provisioning Protocol, EPP), and a transport protocol (i.e., Secure Sockets Layer, SSL).

The SRS components include:

Web Interface: Allows customers to access the authoritative database for accounts, contacts, users, authorization groups, product catalog, product subscriptions, and customer notification messages.

EPP Interface: Provides an interface to the SRS that enables registrars to use EPP to register and manage domains, hosts, and contacts.

Authentication Provider: A Verisign developed application, specific to the SRS, that authenticates a user based on a login name, password, and the SSL certificate common name and client IP address.

The SRS is designed to be scalable and fault tolerant by incorporating clustering in multiple tiers of the platform. New nodes can be added to a cluster within a single tier to scale a specific tier, and if one node fails within a single tier, the services will still be available. The SRS allows registrars to manage the 〈.bloomberg〉 gTLD domain names in a single architecture.

To flexibly accommodate the scale of its transaction volumes, as well as new technologies, Verisign employs the following design practices:

Scale for Growth: Scale to handle current volumes and projected growth.

Scale for Peaks: Scale to twice base capacity to withstand “registration add attacks” from a compromised registrar system.

Limit Database CPU Utilization: Limit utilization to no more than 50 percent during peak loads.

Limit Database Memory Utilization: Each user’s login process that connects to the database allocates a small segment of memory to perform connection overhead, sorting, and data caching.

Verisign’s standards mandate that no more than 40 percent of the total available physical memory on the database server will be allocated for these functions.

Verisign’s SRS is built upon a three-tier architecture as illustrated in Figure 24-1 and detailed here:

Gateway Layer: The first tier, the gateway servers, uses EPP to communicate with registrars. These gateway servers then interact with application servers, which comprise the second tier.

Application Layer: The application servers contain business logic for managing and maintaining the registry business. The business logic is particular to each TLD’s business rules and requirements. The flexible internal design of the application servers allows Verisign to easily leverage existing business rules to apply to the 〈.bloomberg〉 gTLD. The application servers store BIP’s data in the registry database, which comprises the third and final tier. This simple, industry-standard design has been highly effective with other customers for whom Verisign provides backend registry services.

Database Layer: The database is the heart of this architecture. It stores all the essential information provisioned from registrars through the gateway servers. Separate servers query the database, extract updated zone and Whois information, validate that information, and distribute it around the clock to Verisign’s worldwide domain name resolution sites. See Figure 24-1.

Scalability and Performance. Verisign, BIP’s selected backend registry services provider, implements its scalable SRS on a supportable infrastructure that achieves the availability requirements in Specification 10. Verisign employs the design patterns of simplicity and parallelism in both its software and systems, based on its experience that these factors contribute most significantly to scalability and reliable performance. Going counter to feature-rich development patterns, Verisign intentionally minimizes the number of lines of code between the end user and the data delivered. The result is a network of restorable components that provide rapid, accurate updates. Figure 24-2 depicts EPP traffic flows and local redundancy in Verisign’s SRS provisioning architecture. As detailed in the figure, local redundancy is maintained for each layer as well as each piece of equipment. This built-in redundancy enhances operational performance while enabling the future system scaling necessary to meet additional demand created by this or future registry applications. See Figure 24-2.

Besides improving scalability and reliability, local SRS redundancy enables Verisign to take down individual system components for maintenance and upgrades, with little to no performance impact. With Verisign’s redundant design, Verisign can perform routine maintenance while the remainder of the system remains online and unaffected. For the 〈.bloomberg〉 gTLD registry, this flexibility minimizes unplanned downtime and provides a more consistent end-user experience.

Representative Network Diagrams

Figure 24-3 provides a summary network diagram of BIP’s selected backend registry services provider’s (Verisign’s) SRS. This configuration at both the primary and alternate-primary Verisign data centers provides a highly reliable backup capability. Data is continuously replicated between both sites to ensure failover to the alternate-primary site can be implemented expeditiously to support both planned and unplanned outages.

Number of Servers

As BIP’s selected provider of backend registry services, Verisign continually reviews its server deployments for all aspects of its registry service. Verisign evaluates usage based on peak performance objectives as well as current transaction volumes, which drive the quantity of servers in its implementations. Verisign’s scaling is based on the following factors:

Server configuration is based on CPU, memory, disk IO, total disk, and network throughput projections.

Server quantity is determined through statistical modeling to fulfill overall performance objectives as defined by both the service availability and the server configuration.

To ensure continuity of operations for the 〈.bloomberg〉 gTLD, Verisign uses a minimum of 100 dedicated servers per SRS site. These servers are virtualized to meet demand.

Description of Interconnectivity with Other Registry Systems

Figure 24-4 provides a technical overview of the BIP’s selected backend registry services provider’s (Verisign’s) SRS, showing how the SRS component fits into this larger system and interconnects with other system components.

Frequency of Synchronization Between Servers

As BIP’s selected provider of backend registry services, Verisign uses synchronous replication to keep the Verisign SRS continuously in sync between the two data centers. This synchronization is performed in near-real time, thereby supporting rapid failover should a failure occur or a planned maintenance outage be required.

Synchronization Scheme

Verisign uses synchronous replication to keep the Verisign SRS continuously in sync between the two data centers. Because the alternate-primary site is continuously up, and built using an identical design to the primary data center, it is classified as a “hot standby.”

SCALABILITY AND PERFORMANCE ARE CONSISTEN WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY

Verisign is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies.

Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the 〈.bloomberg〉 gTLD with necessary implementation and sustainment cost. 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 scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to BIP fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.

TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION

Verisign, the BIP’s selected provider of backend registry services, 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 TLD. 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 this gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services provided to BIP fully accounts for this personnel-related cost, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) 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 more than 13 years for .com, proving Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s TLD 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 SRS performance:

Application Engineers: 19
Database Administrators: 8
Database Engineers: 3
Network Administrators: 11
Network Architects: 4
Project Managers: 25
Quality Assurance Engineers: 11
SRS System Administrators: 13
Storage Administrators: 4
Systems Architects: 9

To implement and manage the 〈.bloomberg〉 gTLD as described in this application, Verisign, BIP’s selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. 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 TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD 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 TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees 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.

EVIDENCE OF COMPLIANCE WITH SPECIFICATION 6 AND 10 TO THE REGISTRY AGREEMENT

Section 1.2 (EPP) of Specification 6, Registry Interoperability and Continuity Specifications.

Verisign, BIP’s selected backend registry services provider, provides these services using its SRS, which complies fully with Specification 6, Section 1.2 of the Registry Agreement. In using its SRS to provide backend registry services, Verisign implements and complies with relevant existing RFCs (i.e., 5730, 5731, 5732, 5733, 5734, and 5910) and intends to comply with RFCs that may be published in the future by the Internet Engineering Task Force (IETF), including successor standards, modifications, or additions thereto relating to the provisioning and management of domain names that use EPP. In addition, Verisign’s SRS includes a Registry Grace Period (RGP) and thus complies with RFC 3915 and its successors. Details of the Verisign SRS’ compliance with RFC SRS⁄EPP are provided in the response to Question 25, Extensible Provisioning Protocol. Verisign does not use functionality outside the base EPP RFCs, although proprietary EPP extensions are documented in Internet-Draft format following the guidelines described in RFC 3735 within the response to Question 25. Moreover, prior to deployment, BIP will provide to ICANN updated documentation of all the EPP objects and extensions supported in accordance with Specification 6, Section 1.2.

Specification 10, EPP Registry Performance Specifications. Verisign’s SRS meets all EPP Registry Performance Specifications detailed in Specification 10, Section 2.

Evidence of this performance can be verified by a review of the .com and .net Registry Operator’s Monthly Reports, which Verisign files with ICANN. These reports detail Verisign’s operational status of the .com and .net registries, which use an SRS design and approach comparable to the one proposed for the 〈.bloomberg〉 gTLD. These reports provide evidence of Verisign’s ability to meet registry operation service level agreements (SLAs) comparable to those detailed in Specification 10. The reports are accessible at the following URL: http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄.

In accordance with EPP Registry Performance Specifications detailed in Specification 10, Verisignʹs SRS meets the following performance attributes:

EPP service availability: ≤ 864 minutes of downtime (≈98%)

EPP session-command round trip time (RTT): ≤4000 milliseconds (ms), for at least 90 percent of the commands

EPP query-command RTT: ≤2000 ms, for at least 90 percent of the commands

EPP transform-command RTT: ≤4000 ms, for at least 90 percent of the commands

Description of EPP

All figures, tables and diagrams referenced in the following response can be found in the attachments titled “bloomberg_.string_Q25 Figures and “bloomberg_.string_Q25 EPP Schemas”.

COMPLETE KNOWLEDGE AND UNDERSTANDING OF THIS ASPECT OF REGISTRY TECHNICAL REQUIREMENTS

Verisign, BIP’s selected backend registry services provider, has used Extensible Provisioning Protocol (EPP) since its inception and possesses complete knowledge and understanding of EPP registry systems. Its first EPP implementation— for a thick registry for the .name generic top-level domain (gTLD)—was in 2002. Since then Verisign has continued its RFC-compliant use of EPP in multiple TLDs, as detailed in Figure 25-1. 

Verisign’s understanding of EPP and its ability to implement code that complies with the applicable RFCs is unparalleled. Mr. Scott Hollenbeck, Verisign’s director of software development, authored the Extensible Provisioning Protocol and continues to be fully engaged in its refinement and enhancement (U.S. Patent Number 7299299 – Shared registration system for registering 
domain names). Verisign has also developed numerous new object mappings and object extensions following the guidelines in RFC 3735 (Guidelines for Extending the Extensible Provisioning Protocol). Mr. James Gould, a principal engineer at Verisign, led and co-authored the most recent EPP Domain Name System Security Extensions (DNSSEC) RFC effort (RFC 5910).

All registry systems for which Verisign is the registry operator or provides backend registry services use EPP. Upon approval of this application, Verisign will use EPP to provide the backend registry services for this gTLD. The .com, .net, and .name registries for which Verisign is the registry operator use an SRS design and approach comparable to the one proposed for this gTLD. Approximately 915 registrars use the Verisign EPP service, and the registry system performs more than 140 million EPP transactions daily without performance issues or restrictive maintenance windows. The processing time service level agreement (SLA) requirements for the Verisign-operated .net gTLD are the strictest of the current Verisign managed gTLDs. All processing times for Verisign-operated gTLDs can be found in ICANN’s Registry Operator’s Monthly Reports at http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄. 

Verisign has also been active on the Internet Engineering Task Force (IETF) Provisioning Registry Protocol (provreg) working group and mailing list since work started on the EPP protocol in 2000. This working group provided a forum for members of the Internet community to comment on Mr. Scott Hollenbeck’s initial EPP drafts, which Mr. Hollenbeck refined based on input and discussions with representatives from registries, registrars, and other interested parties. The working group has since concluded, but the mailing list is still active to enable discussion of different aspects of EPP.

EPP Interface with Registrars
Verisign, BIP’s selected backend registry services provider,  fully supports the features defined in the EPP specifications and provides a set of software development kits (SDK) and tools to help registrars build secure and stable interfaces. Verisign’s SDKs give registrars the option of either fully writing their own EPP client software to integrate with the Shared Registration System (SRS), or using the Verisign-provided SDKs to aid them in the integration effort. Registrars can download the Verisign EPP SDKs and tools from the registrar website (http:⁄⁄www.Verisign.com⁄domain-name-services⁄current-registrars⁄epp-sdk⁄index.html). 

The EPP SDKs provide a host of features including connection pooling, Secure Sockets Layer (SSL), and a test server (stub server) to run EPP tests against. One tool—the EPP tool—provides a web interface for creating EPP Extensible Markup Language (XML) commands and sending them to a configurable set of target servers. This helps registrars in creating the template XML and testing a variety of test cases against the EPP servers. An Operational Test and Evaluation (OT&E) environment, which runs the same software as the production system so approved registrars can integrate and test their software before moving into a live production environment, is also available. 

Technical plan scope⁄scale consistent with the overall business approach and planned size of the registry
Verisign, BIP’s selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies. 
Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the 〈.bloomberg〉 gTLD with necessary implementation and sustainment cost. 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 scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to BIP fully accounts for cost related to this infrastructure, which is provided as  “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.

TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION

Verisign, BIP’s 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 TLD. 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 this gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to BIP fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) 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 more than 13 years for .com, proving Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s TLD 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 provisioning of EPP services:

Application Engineers: 19 
Database Engineers: 3 
Quality Assurance Engineers: 11 

To implement and manage the 〈.bloomberg〉 gTLD as described in this application, Verisign scales, as needed, the size of each technical area now supporting its portfolio of TLDs. 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 TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed TLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internet’s largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees 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.

ABILITY TO COMPLY WITH RELEVANT RFCs

Verisign, BIP’s selected backend registry services provider, incorporates design reviews, code reviews, and peer reviews into its software development lifecycle (SDLC) to ensure compliance with the relevant RFCs. Verisign’s dedicated QA team creates extensive test plans and issues internal certifications when it has confirmed the accuracy of the code in relation to the RFC requirements. Verisign’s QA organization is independent from the development team within engineering. This separation helps Verisign ensure adopted processes and procedures are followed, further ensuring that all software releases fully consider the security and stability of the TLD. 

For the 〈.bloomberg〉 gTLD, the Shared Registration System (SRS) complies with the following IETF EPP specifications, where the XML templates and XML schemas are defined in the following specifications:

EPP RGP 3915 (http:⁄⁄www.apps.ietf.org⁄rfc⁄rfc3915.html): EPP Redemption Grace Period (RGP) Mapping specification for support of RGP statuses and support of Restore Request and Restore Report (authored by Verisign’s Scott Hollenbeck)

EPP 5730 (http:⁄⁄tools.ietf.org⁄html⁄rfc5730): Base EPP specification (authored by Verisign’s Scott Hollenbeck)

EPP Domain 5731 (http:⁄⁄tools.ietf.org⁄html⁄rfc5731): EPP Domain Name Mapping specification (authored by Verisign’s Scott Hollenbeck)

EPP Host 5732 (http:⁄⁄tools.ietf.org⁄html⁄rfc5732): EPP Host Mapping specification (authored by Verisign’s Scott Hollenbeck)

EPP Contact 5733 (http:⁄⁄tools.ietf.org⁄html⁄rfc5733): EPP Contact Mapping specification (authored by Verisign’s Scott Hollenbeck)

EPP TCP 5734 (http:⁄⁄tools.ietf.org⁄html⁄rfc5734): EPP Transport over Transmission Control Protocol (TCP) specification (authored by Verisign’s Scott Hollenbeck)

EPP DNSSEC 5910 (http:⁄⁄tools.ietf.org⁄html⁄rfc5910): EPP Domain Name System Security Extensions (DNSSEC) Mapping specification (authored by Verisign’s James Gould and Scott Hollenbeck)

Proprietary EPP Extensions

Verisign uses its SRS to provide registry services. The SRS supports the following EPP specifications, which Verisign developed following the guidelines in RFC 3735, where the XML templates and XML schemas are defined in the specifications:

IDN Language Tag (http:⁄⁄www.verisigninc.com⁄assets⁄idn-language-tag.pdf): 

EPP internationalized domain names (IDN) language tag extension used for IDN domain name registrations

RGP Poll Mapping (http:⁄⁄www.verisigninc.com⁄assets⁄whois-info-extension.pdf): EPP mapping for an EPP poll message in support of Restore Request and Restore Report

Whois Info Extension (http:⁄⁄www.verisigninc.com⁄assets⁄whois-info-extension.pdf): EPP extension for returning additional information needed for transfers

EPP ConsoliDate Mapping (http:⁄⁄www.verisigninc.com⁄assets⁄consolidate-mapping.txt): EPP mapping to support a Domain Sync operation for synchronizing domain name expiration dates

NameStore Extension (http:⁄⁄www.verisigninc.com⁄assets⁄namestore-extension.pdf): EPP extension for routing with an EPP intelligent gateway to a pluggable set of backend products and services

Low Balance Mapping (http:⁄⁄www.verisigninc.com⁄assets⁄low-balance-mapping.pdf): EPP mapping to support low balance poll messages that proactively notify registrars of a low balance (available credit) condition

As part of the 2006 implementation report to bring the EPP RFC documents from Proposed Standard status to Draft Standard status, an implementation test matrix was completed. Two independently developed EPP client implementations based on the RFCs were tested against the Verisign EPP server for the domain, host, and contact transactions. No compliance-related issues were identified during this test, providing evidence that these extensions comply with RFC 3735 guidelines and further demonstrating Verisign’s ability to design, test, and deploy an RFC-compliant EPP implementation.

EPP Templates and Schemas

The EPP XML schemas are formal descriptions of the EPP XML templates. They are used to express the set of rules to which the EPP templates must conform in order to be considered valid by the schema. The EPP schemas define the building blocks of the EPP templates, describing the format of the data and the different EPP commands’ request and response formats. The current EPP implementations managed by Verisign, BIP’s selected backend registry services provider, use these EPP templates and schemas, as will the proposed TLD. For each proprietary XML template⁄schema Verisign provides a reference to the applicable template and includes the schema.

XML templates⁄schema for idnLang-1.0

Template: The templates for idnLang-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄idn-language-tag.pdf. 

Schema 25-1: This schema describes the extension mapping for the IDN language tag. The mapping extends the EPP domain name mapping to provide additional features required for the provisioning of IDN domain name registrations.

XML templates⁄schema for rgp-poll-1.0

Template: The templates for rgp-poll-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄rgp-poll-mapping.pdf.

Schema 25-2: This schema describes the extension mapping for poll notifications. The mapping extends the EPP base mapping to provide additional features for registry grace period (RGP) poll notifications.

XML templates⁄schema for whoisInf-1.0

Template: The templates for whoisInf-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄whois-info-extension.pdf.

Schema 25-3: This schema describes the extension mapping for the Whois Info extension. The mapping extends the EPP domain name mapping to provide additional features for returning additional information needed for transfers.

XML templates⁄schema for sync-1.0 (consoliDate)

Template: The templates for sync-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄consolidate-mapping.txt.

Schema 25-4: This schema describes the extension mapping for the synchronization of domain name registration period expiration dates. This service is known as ʺConsoliDate.ʺ The mapping extends the EPP domain name mapping to provide features that allow a protocol client to end a domain name registration period on a specific month and day.

XML templates⁄schema for namestore Ext-1.1

• Template: The templates for idnLang-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄idn-language-tag.pdf. 
• Schema 25-1: This schema describes the extension mapping for the IDN language tag. The mapping extends the EPP domain name mapping to provide additional features required for the provisioning of IDN domain name registrations.

All figures, tables and diagrams referenced in the following response can be found in the attachment titled “bloomberg_.string_Q26 Figures”

COMPLETE KNOWLEDGE OF THIS ASPECT OF REGISTRY TECHNICAL REQUIREMENTS

Verisign, BIP’s selected backend registry services provider, has operated the Whois lookup service for the gTLDs and ccTLDs it manages since 1991, and will provide these proven services for the 〈.bloomberg〉 gTLD registry. In addition, it continues to work with the Internet community to improve the utility of Whois data, while thwarting its application for abusive uses.

High-Level Whois System Description

Like all other components of BIP’s selected backend registry services provider’s (Verisign’s) registry service, Verisign’s Whois system is designed and built for both reliability and performance in full compliance with applicable RFCs.

Verisign’s current Whois implementation has answered more than five billion Whois queries per month for the TLDs it manages, and has experienced more than 250,000 queries per minute in peak conditions. The proposed gTLD uses a Whois system design and approach that is comparable to the current implementation. Independent quality control testing ensures Verisign’s Whois service is RFC-compliant through all phases of its lifecycle.

Verisignʹs redundant Whois databases further contribute to overall system availability and reliability. The hardware and software for its Whois service is architected to scale both horizontally (by adding more servers) and vertically (by adding more CPUs and memory to existing servers) to meet future need.

Verisign can fine-tune access to its Whois database on an individual Internet Protocol (IP) address basis, and it works with registrars to help ensure their services are not limited by any restriction placed on Whois. Verisign provides near real-time updates for Whois services for the TLDs under its management. As information is updated in the registration database, it is propagated to the Whois servers for quick publication. These updates align with the near real-time publication of Domain Name System (DNS) information as it is updated in the registration database. This capability is important for the 〈.bloomberg〉 gTLD registry as it is Verisign’s experience that when DNS data is updated in near real time, so should Whois data be updated to reflect the registration specifics of those domain names.

Verisign’s Whois response time has been less than 500 milliseconds for 95 percent of all Whois queries in .com, .net, .tv, and .cc. The response time in these TLDs, combined with Verisign’s capacity, enables the Whois system to respond to up to 30,000 searches (or queries) per second for a total capacity of 2.6 billion queries per day.

The Whois software written by Verisign complies with RFC 3912. Verisign uses an advanced in-memory database technology to provide exceptional overall system performance and security. In accordance with RFC 3912, Verisign provides a website at whois.nic.〈TLD〉 that provides free public query-based access to the registration data.

Verisign currently operates both thin and thick Whois systems.

Verisign commits to implementing a RESTful Whois service upon finalization of agreements with the IETF (Internet Engineering Task Force).

Provided Functionalities for User Interface

To use the Whois service via port 43, the user enters the applicable parameter on the command line as illustrated here:

For domain name: whois EXAMPLE.TLD

For registrar: whois ʺregistrar Example Registrar, Inc.ʺ

For name server: whois ʺNS1.EXAMPLE.TLDʺ or whois ʺname server (IP address)ʺ

To use the Whois service via the web-based directory service search interface:

Go to http:⁄⁄whois.nic.〈TLD〉

Click on the appropriate button (Domain, Registrar, or Name Server)

Enter the applicable parameter:

Domain name, including the TLD (e.g., EXAMPLE.TLD)
Full name of the registrar, including punctuation (e.g., Example Registrar, Inc.)
Full host name or the IP address (e.g., NS1.EXAMPLE.TLD or 198.41.3.39)

Click on the Submit button.

Provisions to Ensure That Access Is Limited to Legitimate Authorized Users and Is in Compliance with Applicable Privacy Laws or Policies

To further promote reliable and secure Whois operations, Verisign, BIP’s selected backend registry services provider, has implemented rate-limiting characteristics within the Whois service software. For example, to prevent data mining or other abusive behavior, the service can throttle a specific requestor if the query rate exceeds a configurable threshold. In addition, QoS technology enables rate limiting of queries before they reach the servers, which helps protect against denial of service (DoS) and distributed denial of service (DDoS) attacks.

Verisign’s software also permits restrictions on search capabilities. For example, wild card searches can be disabled. If needed, it is possible to temporarily restrict and⁄or block requests coming from specific IP addresses for a configurable amount of time. Additional features that are configurable in the Whois software include help files, headers and footers for Whois query responses, statistics, and methods to memory map the database. Furthermore, Verisign is European Union (EU) Safe Harbor certified and has worked with European data protection authorities to address applicable privacy laws by developing a tiered Whois access structure that requires users who require access to more extensive data to (i) identify themselves, (ii) confirm that their use is for a specified purpose and (iii) enter into an agreement governing their use of the more extensive Whois data.

Relevant Network Diagrams

Figure 26-1 provides a summary network diagram of the Whois service provided by Verisign, BIP’s selected backend registry services provider. The figure details the configuration with one resolution⁄Whois site. For the 〈.bloomberg〉 gTLD Verisign provides Whois service from 6 of its 17 primary sites based on the proposed gTLD’s traffic volume and patterns. A functionally equivalent resolution architecture configuration exists at each Whois site.

IT and Infrastructure Resources

Figure 26-2 summarizes the IT and infrastructure resources that Verisign, BIP’s selected backend registry services provider, uses to provision Whois services from Verisign primary resolution sites. As needed, virtual machines are created based on actual and projected demand.

Description of Interconnectivity with Other Registry Systems

Figure 26-3 provides a technical overview of the registry system provided by Verisign, BIP’s selected backend registry services provider, and shows how the Whois service component fits into this larger system and interconnects with other system components.

Frequency of Synchronization Between Servers

Synchronization between the SRS and the geographically distributed Whois resolution sites occurs approximately every three minutes. Verisign, BIP’s selected backend registry services provider, uses a two-part Whois update process to ensure Whois data is accurate and available. Every 12 hours an initial file is distributed to each resolution site. This file is a complete copy of all Whois data fields associated with each domain name under management. As interactions with the SRS cause the Whois data to be changed, these incremental changes are distributed to the resolution sites as an incremental file update. This incremental update occurs approximately every three minutes. When the new 12-hour full update is distributed, this file includes all past incremental updates. Verisign’s approach to frequency of synchronization between servers meets the Performance Specifications defined in Specification 10 of the Registry Agreement for new gTLDs.

TECHNICAL PLAN SCOPE⁄SCALE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY

TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION

Verisign, BIP’s 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 TLD. 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 this gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to BIP fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.

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 Whois services:

Application Engineers: 19

Database Engineers: 3

Quality Assurance Engineers: 11

COMPLIANCE WITH RELEVANT RFC

BIP’s selected backend registry services provider’s (Verisign’s) Whois service complies with the data formats defined in Specification 4 of the Registry Agreement. Verisign will provision Whois services for registered domain names and associated data in the top-level domain (TLD). Verisign’s Whois services are accessible over Internet Protocol version 4 (IPv4) and Internet Protocol version 6 (IPv6), via both Transmission Control Protocol (TCP) port 43 and a web-based directory service at whois.nic.〈TLD〉, which in accordance with RFC 3912, provides free public query-based access to domain name, registrar, and name server lookups. Verisign’s proposed Whois system meets all requirements as defined by ICANN for each registry under Verisign management. Evidence of this successful implementation, and thus compliance with the applicable RFCs, can be verified by a review of the .com and .net Registry Operator’s Monthly Reports that Verisign files with ICANN. These reports provide evidence of Verisign’s ability to meet registry operation service level agreements (SLAs) comparable to those detailed in Specification 10. The reports are accessible at the following URL: http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄.

COMPLIANCE WITH SPECIFICATIONS 4 AND 10 OF REGISTRY AGREEMENT

In accordance with Specification 4, Verisign, BIP’s selected backend registry services provider, provides a Whois service that is available via both port 43 in accordance with RFC 3912, and a web-based directory service at whois.nic.〈TLD〉 also in accordance with RFC 3912, thereby providing free public query-based access. Verisign acknowledges that ICANN reserves the right to specify alternative formats and protocols, and upon such specification, Verisign will implement such alternative specification as soon as reasonably practicable.
The format of the following data fields conforms to the mappings specified in Extensible Provisioning Protocol (EPP) RFCs 5730 – 5734 so the display of this information (or values returned in Whois responses) can be uniformly processed and understood: domain name status, individual and organizational names, address, street, city, state⁄province, postal code, country, telephone and fax numbers, email addresses, date, and times.
Specifications for data objects, bulk access, and lookups comply with Specification 4 and are detailed in the following subsections, provided in both bulk access and lookup modes.

Bulk Access Mode. This data is provided on a daily schedule to a party designated from time to time in writing by ICANN. The specification of the content and format of this data, and the procedures for providing access, shall be as stated below, until revised in the ICANN Registry Agreement.

The data is provided in three files:

Domain Name File: For each domain name, the file provides the domain name, server name for each name server, registrar ID, and updated date.

Name Server File: For each registered name server, the file provides the server name, each IP address, registrar ID, and updated date.

Registrar File: For each registrar, the following data elements are provided: registrar ID, registrar address, registrar telephone number, registrar email address, Whois server, referral URL, updated date, and the name, telephone number, and email address of all the registrarʹs administrative, billing, and technical contacts.

Lookup Mode. Figures 26-4 through 26-6 provide the query and response format for domain name, registrar, and name server data objects.

Specification 10, RDDS Registry Performance Specifications

The Whois service meets all registration data directory services (RDDS) registry performance specifications detailed in Specification 10, Section 2. Evidence of this performance can be verified by a review of the .com and .net Registry Operator’s Monthly Reports that Verisign files monthly with ICANN. These reports are accessible from the ICANN website at the following URL: http:⁄⁄www.icann.org⁄en⁄tlds⁄monthly-reports⁄.

In accordance with RDDS registry performance specifications detailed in Specification 10, Verisignʹs Whois service meets the following proven performance attributes:

RDDS availability: ≤ 864 min of downtime (≈98%)

RDDS query RTT: ≤ 2000 ms, for at least 95% of the queries

RDDS update time: ≤ 60 min, for at least 95% of the probes

SEARCHABLE WHOIS

Verisign, BIP’s selected backend registry services provider, provides a searchable Whois service for the 〈.bloomberg〉 gTLD. Verisign has experience in providing tiered access to Whois for the .name registry, and uses these methods and control structures to help reduce potential malicious use of the function. The searchable Whois system currently uses Apache’s Lucene full text search engine to index relevant Whois content with near-real time incremental updates from the provisioning system.

Features of the Verisign searchable Whois function include:

Provision of a web-based searchable directory service

Ability to perform partial match, at least, for the following data fields: domain name, contacts and registrant’s name, and contact and registrant’s postal address, including all the sub-fields described in EPP (e.g., street, city, state, or province)

Ability to perform exact match, at least, on the following fields: registrar ID, name server name, and name server’s IP address (only applies to IP addresses stored by the registry, i.e., glue records)

Ability to perform Boolean search supporting, at least, the following logical operators to join a set of search criteria: AND, OR, NOT

Search results that include domain names that match the selected search criteria

Verisign’s implementation of searchable Whois is EU Safe Harbor certified and includes appropriate access control measures that help ensure that only legitimate authorized users can use the service. Furthermore, Verisign’s compliance office monitors current ICANN policy and applicable privacy laws or policies to help ensure the solution is maintained within compliance of applicable regulations.

Features of these access control measures include:

All unauthenticated searches are returned as thin results.

Registry system authentication is used to grant access to appropriate users for thick Whois data search results.

Account access is granted by the BIP’s defined 〈.bloomberg〉 gTLD admin user.

Potential Forms of Abuse and Related Risk Mitigation. Leveraging its experience providing tiered access to Whois for the .name registry and interacting with ICANN, data protection authorities, and applicable industry groups, Verisign, BIP’s selected backend registry services provider, is knowledgeable of the likely data mining forms of abuse associated with a searchable Whois service. Figure 26-7 summarizes these potential forms of abuse and Verisign’s approach to mitigate the identified risk.

All figures, tables and diagrams referenced in the following response can be found in the attachment titled “bloomberg_.string_Q27 Figures”.

COMPLETE KNOWLEDGE AND UNDERSTANDING OF REGISTRATION LIFECYCLES AND STATES

Starting with domain name registration and continuing through domain name delete operations, BIP’s selected backend registry services provider’s (Verisign’s) registry implements the full registration lifecycle for domain names supporting the operations in the Extensible Provisioning Protocol (EPP) specification. The registration lifecycle of the domain name starts with registration and traverses various states as specified in the following sections. The registry system provides options to update domain names with different server and client status codes that block operations based on the EPP specification. The system also provides different grace periods for different billable operations, where the price of the billable operation is credited back to the registrar if the billable operation is removed within the grace period. Together Figure 27-1 and Figure 27-2 define the registration states comprising the registration lifecycle and explain the trigger points that cause state-to-state transitions. States are represented as green rectangles within Figure 27-1.

Registration Lifecycle of Create⁄Update⁄Delete

The following section details the create⁄update⁄delete processes and the related renewal process that Verisign, BIP’s selected backend registry services provider, follows. For each process, this response defines the process function and its characterization, and as appropriate provides a process flow chart.

Create Process. The domain name lifecycle begins with a registration or what is referred to as a Domain Name Create operation in EPP. The system fully supports the EPP Domain Name Mapping as defined by RFC 5731, where the associated objects (e.g., hosts and contacts) are created independent of the domain name.

Process Characterization. The Domain Name Create command is received, validated, run through a set of business rules, persisted to the database, and committed in the database if all business rules pass. The domain name is included with the data flow to the DNS and Whois resolution services. If no name servers are supplied, the domain name is not included with the data flow to the DNS. A successfully created domain name has the created date and expiration date set in the database. Creates are subject to grace periods as described in Section 1.3 of this response, Add Grace Period, Redemption Grace Period, and Notice Periods for Renewals or Transfers.

The Domain Name Create operation is detailed in Figure 27-3 and requires the following attributes:

A domain name that meets the string restrictions.

A domain name that does not already exist.

The registrar is authorized to create a domain name in 〈.bloomberg〉.

The registrar has available credit.

A valid Authorization Information (Auth-Info) value.

Required contacts (e.g., registrant, administrative contact, technical contact, and billing contact) are specified and exist.

The specified name servers (hosts) exist, and there is a maximum of 13 name servers.

A period in units of years with a maximum value of 10 (default period is one year).

Renewal Process. The domain name can be renewed unless it has any form of Pending Delete, Pending Transfer, or Renew Prohibited.
A request for renewal that sets the expiry date to more than ten years in the future is denied. The registrar must pass the current expiration date (without the timestamp) to support the idempotent features of EPP, where sending the same command a second time does not cause unexpected side effects.
Automatic renewal occurs when a domain name expires. On the expiration date, the registry extends the registration period one year and debits the registrar account balance. In the case of an auto-renewal of the domain name, a separate Auto-Renew grace period applies. Renewals are subject to grace periods as described in Section 1.3 of this response, Add Grace Period, Redemption Grace Period, and Notice Periods for Renewals or Transfers.

Process Characterization. The Domain Name Renew command is received, validated, authorized, and run through a set of business rules. The data is updated and committed in the database if it passes all business rules. The updated domain name’s expiration date is included in the flow to the Whois resolution service.

The Domain Name Renew operation is detailed in Figure 27-4 and requires the following attributes:

A domain name that exists and is sponsored by the requesting registrar.

The registrar is authorized to renew a domain name in 〈.bloomberg〉.

The registrar has available credit.

The passed current expiration date matches the domain name’s expiration date.

A period in units of years with a maximum value of 10 (default period is one year). A domain name expiry past ten years is not allowed.

Registrar Transfer Procedures. A registrant may transfer his⁄her domain name from his⁄her current registrar to another registrar. The database system allows a transfer as long as the transfer is not within the initial 60 days, per industry standard, of the original registration date.

The registrar transfer process goes through many process states, which are described in detail below, unless it has any form of Pending Delete, Pending Transfer, or Transfer Prohibited.

A transfer can only be initiated when the appropriate Auth-Info is supplied. The Auth-Info for transfer is only available to the current registrar. Any other registrar requesting to initiate a transfer on behalf of a registrant must obtain the Auth-Info from the registrant.

The Auth-Info is made available to the registrant upon request. The registrant is the only party other than the current registrar that has access to the Auth-Info. Registrar transfer entails a specified extension of the expiry date for the object. The registrar transfer is a billable operation and is charged identically to a renewal for the same extension of the period. This period can be from one to ten years, in one-year increments.

Because registrar transfer involves an extension of the registration period, the rules and policies applying to how the resulting expiry date is set after transfer are based on the renewal policies on extension.

Per industry standard, a domain name cannot be transferred to another registrar within the first 60 days after registration. This restriction continues to apply if the domain name is renewed during the first 60 days. Transfer of the domain name changes the sponsoring registrar of the domain name, and also changes the child hosts (ns1.sample.xyz) of the domain name (sample .xyz).

The domain name transfer consists of five separate operations:

Transfer Request (Figure 27-5): Executed by a non-sponsoring registrar with the valid Auth-Info provided by the registrant. The Transfer Request holds funds of the requesting registrar but does not bill the registrar until the transfer is completed. The sponsoring registrar receives a Transfer Request poll message.

Transfer Cancel (Figure 27-6): Executed by the requesting registrar to cancel the pending transfer. The held funds of the requesting registrar are reversed. The sponsoring registrar receives a Transfer Cancel poll message.

Transfer Approve (Figure 27-7): Executed by the sponsoring registrar to approve the Transfer Request. The requesting registrar is billed for the Transfer Request and the sponsoring registrar is credited for an applicable Auto-Renew grace period. The requesting registrar receives a Transfer Approve poll message.

Transfer Reject (Figure 27-8): Executed by the sponsoring registrar to reject the pending transfer. The held funds of the requesting registrar are reversed. The requesting registrar receives a Transfer Reject poll message.

Transfer Query (Figure 27-9): Executed by either the requesting registrar or the sponsoring registrar of the last transfer.

The registry auto-approves a transfer if the sponsoring registrar takes no action. The requesting registrar is billed for the Transfer Request and the sponsoring registrar is credited for an applicable Auto-Renew grace period. The requesting registrar and the sponsoring registrar receive a Transfer Auto-Approve poll message.

Delete Process. A registrar may choose to delete the domain name at any time.

Process Characterization. The domain name can be deleted, unless it has any form of Pending Delete, Pending Transfer, or Delete Prohibited.

A domain name is also prohibited from deletion if it has any in-zone child hosts that are name servers for domain names. For example, the domain name “sample.xyz” cannot be deleted if an in-zone host “ns.sample.xyz” exists and is a name server for “sample2.xyz.”

If the Domain Name Delete occurs within the Add grace period, the domain name is immediately deleted and the sponsoring registrar is credited for the Domain Name Create. If the Domain Name Delete occurs outside the Add grace period, it follows the Redemption grace period (RGP) lifecycle.

Update Process. The sponsoring registrar can update the following attributes of a domain name:

Auth-Info

Name servers

Contacts (i.e., registrant, administrative contact, technical contact, and billing contact)

Statuses (e.g., Client Delete Prohibited, Client Hold, Client Renew Prohibited, Client Transfer Prohibited, Client Update Prohibited)

Process Characterization. Updates are allowed provided that the update includes the removal of any Update Prohibited status. The Domain Name Update operation is detailed in Figure 27-10.

A domain name can be updated unless it has any form of Pending Delete, Pending Transfer, or Update Prohibited, Pending, Locked, Expired, and Transferred

Verisign, BIP’s selected backend registry services provider, handles pending, locked, expired, and transferred domain names as described here. When the domain name is deleted after the five-day Add grace period, it enters into the Pending Delete state. The registrant can return its domain name to active any time within the five-day Pending Delete grace period. After the five-day Pending Delete grace period expires, the domain name enters the Redemption Pending state and then is deleted by the system. The registrant can restore the domain name at any time during the Redemption Pending state.

When a non-sponsoring registrar initiates the domain name transfer request, the domain name enters Pending Transfer state and a notification is mailed to the sponsoring registrar for approvals. If the sponsoring registrar doesn’t respond within five days, the Pending Transfer expires and the transfer request is automatically approved.

EPP specifies both client (registrar) and server (registry) status codes that can be used to prevent registry changes that are not intended by the registrant. Currently, many registrars use the client status codes to protect against inadvertent modifications that would affect their customers’ high-profile or valuable domain names.

Verisign’s registry service supports the following client (registrar) and server (registry) status codes:

clientHold

clientRenewProhibited

clientTransferProhibited

clientUpdateProhibited

clientDeleteProhibited

serverHold

serverRenewProhibited

serverTransferProhibited

serverUpdateProhibited

serverDeleteProhibited

Add Grace Period, Redemption Grace Period, and Notice Periods for Renewals or Transfers

Verisign, BIP’s selected backend registry services provider, handles Add grace periods, Redemption grace periods, and notice periods for renewals or transfers as described here.

Add Grace Period: The Add grace period is a specified number of days following the initial registration of the domain name. The current value of the Add grace period for all registrars is five days.

Redemption Grace Period: If the domain name is deleted after the five-day grace period expires, it enters the Redemption grace period and then is deleted by the system. The registrant has an option to use the Restore Request command to restore the domain name within the Redemption grace period. In this scenario, the domain name goes to Pending Restore state if there is a Restore Request command within 30 days of the Redemption grace period. From the Pending Restore state, it goes either to the OK state, if there is a Restore Report Submission command within seven days of the Restore Request grace period, or a Redemption Period state if there is no Restore Report Submission command within seven days of the Restore Request grace period.

Renew Grace Period: The Renew⁄Extend grace period is a specified number of days following the renewal⁄extension of the domain name’s registration period. The current value of the Renew⁄Extend grace period is five days.

Auto-Renew Grace Period: All auto-renewed domain names have a grace period of 45 days.

Transfer Grace Period: Domain names have a five-day Transfer grace period.

Aspects of the Registration Lifecycle Not Covered by Standard EPP RFCs

BIP’s selected backend registry services provider’s (Verisign’s) registration lifecycle processes and code implementations adhere to the standard EPP RFCs related to the registration lifecycle. By adhering to the RFCs, Verisign’s registration lifecycle is complete and addresses each registration-related task comprising the lifecycle. No aspect of Verisign’s registration lifecycle is not covered by one of the standard EPP RFCs and thus no additional definitions are provided in this response.

CONSISTENCY WITH ANY SPECIFIC COMMITMENTS MADE TO REGISTRANTS AS ADAPTED TO THE OVERALL BUSINESS APPROACH FOR THE PROPOSED gTLD

The registration lifecycle described above applies to the 〈.bloomberg〉 gTLD as well as other TLDs managed by Verisign, BIP’s selected backend registry services provider; thus Verisign remains consistent with commitments made to its registrants. No unique or specific registration lifecycle modifications or adaptations are required to support the overall business approach for the 〈.bloomberg〉 gTLD.

To accommodate a range of registries, Verisign’s registry implementation is capable of offering both a thin and thick Whois implementation, which is also built upon Verisign’s award-winning ATLAS infrastructure.

COMPLIANCE WITH RELEVANT RFCs

BIP’s selected backend registry services provider’s (Verisign’s) registration lifecycle complies with applicable RFCs, specifically RFCs 5730 – 5734 and 3915. The system fully supports the EPP Domain Name Mapping as defined by RFC 5731, where the associated objects (e.g., hosts and contacts) are created independent of the domain name.

In addition, in accordance with RFCs 5732 and 5733, the Verisign registration system enforces the following domain name registration constraints:

Uniqueness⁄Multiplicity: A second-level domain name is unique in the 〈.bloomberg〉 database. Two identical second-level domain names cannot simultaneously exist in 〈.bloomberg〉. Further, a second-level domain name cannot be created if it conflicts with a reserved domain name.

Point of Contact Associations: The domain name is associated with the following points of contact. Contacts are created and managed independently according to RFC 5733.
Registrant
Administrative contact
Technical contact
Billing contact

Domain Name Associations: Each domain name is associated with:
A maximum of 13 hosts, which are created and managed independently according to RFC 5732
An Auth-Info, which is used to authorize certain operations on the object
Status(es), which are used to describe the domain name’s status in the registry
A created date, updated date, and expiry date

DEMONSTRATES THAT TECHNICAL RESOURCES REQUIRED TO CARRY THROUGH THE PLANS FOR THIS ELEMENT ARE ALREADY ON HAND OR READILY AVAILABLE

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 registration lifecycle:

Application Engineers: 19

Customer Support Personnel: 36

Database Administrators: 8

Database Engineers: 3

Quality Assurance Engineers: 11

SRS System Administrators: 13

All figures, tables and diagrams referenced in the following response can be found in the attachment titled “bloomberg_.string_Q28 Figures”.

COMPREHENSIVE ABUSE POLICIES, WHICH INCLUDE CLEAR DEFINITIONS OF WHAT CONSTITUTES ABUSE IN THE TLD, AND PROCEDURES THAT WILL EFFECTIVELY MINIMIZE POTENTIAL ABUSE IN THE TLD

Bloomberg IP Holdings, LLC (“BIP”) intends to use the 〈.bloomberg〉 gTLD for register domain names for Bloomberg-related entities. BIP will be the only entity allowed to register domain names in the gTLD. We will exercise complete control of the gTLD, ensuring that no other may register names ending in 〈.bloomberg〉. This single point of control will help us eliminate fraudulent registrations in the gTLD and allow us to rapidly react to any reports of abuse in the gTLD.

BIP has elected to partner with Verisign to provide back-end services for the 〈.bloomberg〉 registry. In making this decision, BIP recognized that Verisign already possesses a production-proven registry system that can be quickly deployed and smoothly operated over its robust, flexible and scalable world-class infrastructure. In particular, Verisign acts as the operator for the key internet registries of the .com and .net domains.  These existing registry services will be leveraged for the 〈.bloomberg〉 registry. 

〈.bloomberg〉 Abuse Prevention and Mitigation Implementation Plan 
Strong abuse prevention of a new gTLD will be an important benefit to the internet community. BIP and its back-end registry services provider, Verisign, agree that a registry must not only aim for the highest standards of technical and operational competence, but also must act as a steward of the space on behalf of the Internet community and ICANN in promoting the public interest.  Verisign brings to this effort extensive experience establishing and implementing registration policies. BIP will leverage Verisign’s experience in the Internet space, as well as experience as a registry and registrar, to help BIP combat abusive and malicious domain activity within the new gTLD space.

One public interest function of a responsible domain name registry is working toward 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
	Trademark abuse
	Online sale or distribution of illegal pharmaceuticals

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, BIP’s partner, Verisign, has developed the ability efficiently to work with 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 to combat abusive DNS practices.  As BIP’s registry provider, Verisign is at the forefront of the prevention of such abusive practices and is one of the few currently existing registry operators to have actually developed and implemented an active “Domain Takedown Policy.”  Verisign also believes 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 mechanisms to enable illegitimate activities on the Internet, often 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 email.  The use of this technique should not be entered into lightly. BIP, through its registry provider Verisign, has an extensive, defined, and documented process for taking the necessary action of removing a domain from the zone when its presence poses a threat to the security and stability of the infrastructure of the Internet or the 〈.bloomberg〉 registry.

Abuse Point of Contact  

As required by the Registry Agreement, BIP 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.  〈.bloomberg〉 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 email 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 is kept accurate and up to date and that any changes will be provided to ICANN in a timely manner.  In addition, with respect to inquiries from ICANN-Accredited registrars, our registry services provider, Verisign, will have an additional point of contact, as it does today, to handle requests by registrars related to abusive domain name practices.

Policies for Handling Complaints Regarding Abuse

One of the key policies of the 〈.bloomberg〉 gTLD is its Acceptable Use Policy, which clearly delineates the types of activities that constitute “abuse” and the repercussions associated with an abusive domain name registration.  This policy will be incorporated into the applicable Registry-Registrar Agreement and reserve the right for the registry to take actions appropriate to the type of abuse.  This will include locking down the domain name, preventing any changes to the contact and name server 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 a law enforcement investigation, substituting name servers to collect information about the DNS queries to assist the investigation.  
BIP will adopt a final Acceptable Use Policy that clearly defines the types of activities that will not be permitted in the gTLD and reserves the right of BIP to lock, cancel, transfer or otherwise suspend or take down domain names violating the Acceptable Use Policy and allow BIP, 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 gTLD registrants.  Below is BIP’s initial Acceptable Use Policy that we will use in connection with the 〈.bloomberg〉 gTLD.

〈.bloomberg〉 Acceptable Use Policy

This Acceptable Use Policy gives BIP the ability to quickly lock, cancel, transfer or take ownership of any 〈.bloomberg〉 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 BIP 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 BIP and its partners. In all cases, BIP or its designees will alert BIP’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 〈.bloomberg〉’s 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 implemented to: (1) remotely control the computer or computer system of an Internet user without his⁄her knowledge or consent, and (2) 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.

BIP 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, BIP 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, which 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, requests of law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of BIP 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 BIP or any Registrar in connection with a domain name registration. BIP also reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a dispute.

Taking Action against Abusive and⁄or Malicious Activity

BIP 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.  BIP shall take action against any domain names being used to threaten the stability and security of the gTLD, or that are part of a real-time investigation by law enforcement. 

Once a complaint is received from a trusted source third-party, or detected by BIP, BIP 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 BIP, the sponsoring registrar will be notified and be given 12 hours to investigate the activity and either taking down the domain name by placing the domain name on hold, deleting the domain name in its entirety, or providing a compelling argument to BIP 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), BIP will place the domain on “ServerHold.”  Although this action removes the domain name from the gTLD zone, the domain name record still appears in the gTLD Whois database so that the name and entities can be investigated by law enforcement or concerned third parties.

Coordination with Law Enforcement

With the assistance of Verisign as its back-end registry services provider, BIP can readily meet its obligations under 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 〈.bloomberg〉 gTLD.  BIP 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 BIP for rapid resolution of the request.  

In the event such request involves any of the activities that can be validated by BIP and involves the type of activity set forth in the Acceptable Use Policy, the sponsoring registrar will then be 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), BIP will place the domain on “ServerHold.”

Proposed Measures for Removal of Orphan Glue Records

Although orphan glue records often support correct and ordinary operation of the Domain Name System (DNS), registry operators will be required to remove orphan glue records (as defined at http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf) when provided with evidence in written form that such records are present in connection with malicious conduct. Verisignʹs registration system is specifically designed to not allow orphan glue records. Registrars are required to delete⁄move all dependent DNS records before they are allowed to delete the parent domain.

To prevent orphan glue records, Verisign performs the following checks before removing a domain or name server: 

Checks during domain delete: 
Parent domain delete is not allowed if any other domain in the zone refers to the child name server. 
If the parent domain is the only domain using the child name server, then both the domain and the glue record are removed from the zone.

Check during explicit name server delete: 
Verisign confirms that the current name server is not referenced by any domain name (in-zone) before deleting the name server. 

Zone-file impact:
If the parent domain references the child name server AND if other domains in the zone also reference it AND if the parent domain name is assigned a serverHold status, then the parent domain goes out of the zone but the name server glue record does not. 
If no domains reference a name server, then the zone file removes the glue record.

Resourcing Plans

Details related to resourcing plans for the initial implementation and ongoing maintenance of BIP’s abuse plan are provided in Section 2 of this response. 

Measures to Promote Whois Accuracy

BIP views Whois accuracy as key to the efficient administration of the Internet and of domains.  Because BIP will be the only permitted registrant, Whois information will be accurate and complete. Nevertheless, BIP will adopt a policy of authentication, regular monitoring of registration data, and expected use by registrars in order to ensure Whois accuracy.

Authentication of Registrant Information 

Registrant verification and authentication will be an inherent step in development of the 〈.bloomberg〉 domain.  Each application for a 〈.bloomberg〉 domain name will be manually authenticated with an authority at BIP prior to registration.  Therefore, the quality of the 〈.bloomberg〉 Whois information is anticipated to be accurate and reliable.

Regular Monitoring of Registration Data for Accuracy and Completeness

Verisign, BIP’s selected backend registry services provider, has established policies and procedures to encourage registrar compliance with ICANN’s Whois accuracy requirements. Verisign provides the following services to BIP for incorporation into its full-service registry operations.

Registrar self certification.  
	
The self-certification program consists, in part, of evaluations applied equally to all operational ICANN accredited registrars and conducted from time to time throughout the year. Process steps are as follows:

Verisign sends an email notification to the ICANN primary registrar contact, requesting that the contact go to a designated URL, log in with his⁄her Web ID and password, and complete and submit the online form. The contact must submit the form within 15 business days of receipt of the notification. 

When the form is submitted, Verisign sends the registrar an automated email confirming that the form was successfully submitted.

Verisign reviews the submitted form to ensure the certifications are compliant.

Verisign sends the registrar an email notification if the registrar is found to be compliant in all areas. 

If a review of the response indicates that the registrar is out of compliance or if Verisign has follow-up questions, the registrar has 10 days to respond to the inquiry.

If the registrar does not respond within 15 business days of receiving the original notification, or if it does not respond to the request for additional information, Verisign sends the registrar a Breach Notice and gives the registrar 30 days to cure the breach.

If the registrar does not cure the breach, Verisign terminates the Registry-Registrar Agreement (RRA). 

Whois data reminder process. Verisign regularly reminds registrars of their obligation to comply with ICANN’s Whois Data Reminder Policy, which was adopted by ICANN as a consensus policy on 27 March 2003 (http:⁄⁄www.icann.org⁄en⁄registrars⁄wdrp.htm). Verisign sends a notice to all registrars once a year reminding them of their obligation to be diligent in validating the Whois information provided during the registration process, to investigate claims of fraudulent Whois information, and to cancel domain name registrations for which Whois information is determined to be invalid. 

Use of Registrars

BIP will use its corporate registrar to register names in the 〈.bloomberg〉 gTLD.  As BIP will be the only registrant, there will be no need for any other registrars.  

In the unlikely event that this model changes, as part of our Registry Registrar Agreement with any registrar, we will require the registrar to ensure the accuracy and completeness of Whois data on behalf of the applicant.  Such procedures may include random audits which, if not ultimately verified, may lead to cancellation of domain registrations.  

BIP will require registrars to publish for applicants the following recommendations regarding Whois accuracy: 

Review your Public Whois Information - You can review your Whois information by simply selecting the link at the bottom of this page. If you have several domains with [Registrar], you may prefer to access your user account and view all of your domains on one screen. If no changes are required, then no further action is required;

Review your Private Customer Record - We recommend that you login and review your private customer record periodically. This is used to send renewal notices to your private postal address and customer email address; 

Updating Whois Information - Please follow these steps to update your WHOIS information. [Registrar to insert specific information on how to update WHOIS records]; and 

Replacing a Whois Contact - If you would like to replace a contact, select the link for modifying the domain name. You can either re-use an existing contact you own or create a new one to use.

Malicious or Abusive Behavior Definitions, Metrics, and Service Level Requirements for Resolution

As described in Response 1.2 above, BIP 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.  BIP shall take action against any domain names being used to threaten the stability and security of the TLD, or that are part of a real-time investigation by law enforcement. 

Once a complaint is received from a trusted source third-party, or detected by BIP, BIP shall use commercially reasonable efforts to verify the information in the complaint.  If that information can be verified to the best of the ability of BIP, 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, by deleting the domain name in its entirety, or providing a compelling argument to BIP 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), BIP will place the domain on “ServerHold.”  

Although this action removes the domain name from the gTLD zone, the domain name record will still appear in the TLD WHOIS database so that the name and entities can be investigated by law enforcement or concerned third parties.

Controls to Ensure Proper Access to Domain Functions

Access controls are important to BIP to ensure the integrity of the 〈.bloomberg〉 gTLD and efficient functioning of the domains.  BIP has applied, in part, because of its desire to obtain domains that can be authenticated and ensured by users to be free from abuse and otherwise not cause consumer confusion.  As a result, BIP and its backend service provider shall employ the following controls in order to ensure the proper access to domain functions and administration:

Multi-Factor Authentication

To ensure proper access to domain functions, BIP incorporates Verisign’s Registry-Registrar Two-Factor Authentication Service into its full-service registry operations. The service is designed to improve domain name security and assist registrars in protecting the accounts they manage by providing another level of assurance that only authorized personnel can communicate with the registry. As part of the service, dynamic one-time passwords (OTPs) augment the user names and passwords currently used to process update, transfer, and⁄or deletion requests. These one-time passwords enable transaction processing to be based on requests that are validated both by “what users know” (i.e., their user name and password) and “what users have” (i.e., a two-factor authentication credential with a one-time-password).

Registrars can use the one-time-password when communicating directly with Verisign’s Customer Service department as well as when using the registrar portal to make manual updates, transfers, and⁄or deletion transactions. The Two-Factor Authentication Service is an optional service offered to registrars that execute the Registry-Registrar Two-Factor Authentication Service Agreement. As shown in Figure 28-1, the registrars’ authorized contacts use the OTP to enable strong authentication when they contact the registry. There is no charge for the Registry-Registrar Two-Factor Authentication Service. It is enabled only for registrars that wish to take advantage of the added security provided by the service.   

TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION

Resource Planning     

BIP will rely upon its backend registry provider, Verisign, to devote the necessary resources to oversee the technical operation of the 〈.bloomberg〉 gTLD.  The .bloomberg gTLD will be supported by a cross functional team of BIP professionals. Numbers and types of employees will vary for each function but Web.com projects it will use the following personnel to support the operational requirements of the gTLD:

Technical Project Manager - .5 FTE
Legal and Compliance Officers -1 FTE (2 x .5 FTEs)

BIP believes that the resources will be more than adequate to support the abuse mitigation procedures of the 〈.bloomberg〉 gTLD.

Resource Planning Specific to Backend Registry Activities

Verisign, BIP’s 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 TLD. 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 this gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to BIP fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response. 

Verisign employs more than 1,040 individuals of whom 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 more than 13 years for .com, proving 

Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s TLD 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 abuse prevention and mitigation:

Application Engineers: 19

Business Continuity Personnel: 3

Customer Affairs Organization: 9

Customer Support Personnel: 36

Information Security Engineers: 11

Network Administrators: 11

Network Architects: 4

Network Operations Center (NOC) Engineers: 33

Project Managers: 25

Quality Assurance Engineers: 11

Systems Architects: 9

To implement and manage the 〈.bloomberg〉 gTLD as described in this application, Verisign, BIP’s selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. 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 TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD 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 TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees 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.

POLICIES AND PROCEDURES IDENTIFY AND ADDRESS THE ABUSIVE USE OF REGISTERED NAMES AT STARTUP AND ON AN ONGOING BASIS

Policies and Procedures That Identify Malicious or Abusive Behavior

Verisign, BIP’s selected backend registry services provider, provides the following service to BIP for incorporation into its full-service registry operations.

Malware scanning service. Registrants are often unknowing victims of malware exploits. 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. 

Verisign’s malware scanning service helps prevent websites from infecting other websites by scanning web pages for embedded malicious content that will infect visitors’ websites. Verisign’s malware scanning technology uses a combination of in-depth malware behavioral analysis, anti-virus results, detailed malware patterns, and network analysis to discover known exploits for the particular scanned zone. If malware is detected, the service sends the registrar a report that contains the number of malicious domains found and details about malicious content within its TLD zones. Reports with remediation instructions are provided to help registrars and registrants eliminate the identified malware from the registrant’s website. 

Policies and Procedures That Address the Abusive Use of Registered Names

Suspension processes. 

BIP 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.  BIP shall take action against any domain names being used to threaten the stability and security of the gTLD, or that are part of a real-time investigation by law enforcement. 

Once a complaint is received from a trusted source third-party, or detected by BIP, BIP 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 BIP, 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 BIP 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), BIP 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.

Suspension processes conducted by backend registry services provider. 

In the case of domain name abuse, BIP will determine whether to take down the subject domain name. Verisign, BIP’s selected backend registry services provider, will follow auditable processes to comply with the suspension request as represented in Figure 28-2. 

Verisign Suspension Notification.  BIP submits the suspension request to Verisign for processing, documented by:

Threat domain name
Registry incident number 
Incident narrative, threat analytics, screen shots to depict abuse, and⁄or other evidence
Threat classification 
Threat urgency description
Recommended timeframe for suspension⁄takedown 
Technical details (e.g., Whois records, IP addresses, hash values, anti-virus detection results⁄nomenclature, name servers, domain name statuses that are relevant to the suspension) 
Incident response, including surge capacity 

Verisign Notification Verification. When Verisign receives a suspension request from BIP, it performs the following verification procedures:

Validate that all the required data appears in the notification.
Validate that the request for suspension is for a registered domain name.
Return a case number for tracking purposes.

Suspension Rejection. If required data is missing from the suspension request, or the domain name is not registered, the request will be rejected and returned to BIP with the following information:

Threat domain name
Registry incident number 
Verisign case number
Error reason

Domain Suspension. Verisign places the domain to be suspended on the following statuses:

serverUpdateProhibited 
serverDeleteProhibited
serverTransferProhibited
serverHold 

Suspension Acknowledgement. Verisign notifies BIP that the suspension has been completed. Acknowledgement of the suspension includes the following information:

Threat domain name
Registry incident number 
Verisign case number 
Case number
Domain name
BIP abuse contact name and number, or registrar abuse contact name and number
Suspension status

WHEN EXECUTED IN ACCORDANCE WITH THE REGISTRY AGREEMENT, PLANS WILL RESULT IN COMPLIANCE WITH CONTRACTUAL REQUIREMENTS

The above-described plans for abuse prevention and mitigation should exceed, the contractual requirements outlined in the Registry Agreement.  As described below, the abuse prevention and mitigation policies, while stringent, will comply with the Registry Interoperability and Continuity Specifications set forth in Section 2.7 of the Registry Agreement.  Specifically, BIP shall provide to ICANN and publish on BIP’s website accurate contact details, including an email address and mailing address and primary contact for handling inquiries related to malicious conduct in the 〈.bloomberg〉 gTLD, and will provide ICANN with prompt notice of any changes to contact details.  These abuse prevention and mitigation policies will also take into account the protection of the legal rights of third parties and, in particular, BIP shall take reasonable steps to investigate and respond to any reports from law enforcement and governmental or quasi-governmental agencies regarding any illegal conduct in connection with the use of the 〈.bloomberg〉 gTLD. 

Additionally, BIP’s outlined plan to remove orphan glue records, when provided with written evidence that such records are present in connection with malicious conduct, meets the requirements of the Registry Agreement.

TECHNICAL PLAN SCOPE⁄SCALE THAT IS CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY

Scope⁄Scale Consistency

BIP’s technical plan exceeds the scope and scale required for the planned size of the planned 〈.bloomberg〉 registry.  As noted above, BIP intends to use the 〈.bloomberg〉 gTLD for two broad purposes.  First, BIP will register domain names to Bloomberg Philanthropies for use in its charitable work.  Second, BIP may issue domains to Bloomberg for use in its global news, information and financial services businesses.  Nevertheless, the planned size of the registry is anticipated to be relatively limited.  Therefore, the current technical plan – which is robust enough to operate a registry of a moderate-to-large public gTLD – is more than sufficient to operate the 〈.bloomberg〉 gTLD.

Scope⁄Scale Consistency Specific to Backend Registry Activities

Verisign, BIP’s selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies. 
Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the 〈.bloomberg〉 gTLD with necessary implementation and sustainment cost. 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 scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to BIP fully accounts for cost related to this infrastructure, which is provided as “Other Operating Cost” (Template 1, Line I.L) within the Question 46 financial projections response.

MECHANISMS DESIGNED TO PREVENT ABUSIVE REGISTRATIONS

Rights protection is a core objective of Bloomberg IP Properties LLC (“BIP”). BIP will implement and adhere to any rights protection mechanisms (RPMs) that may be mandated from time to time by ICANN, including each mandatory RPM set forth in the Trademark Clearinghouse model contained in the Registry Agreement, specifically Specification 7. BIP 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 〈.bloomberg〉 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, BIP cannot fully detail the specific implementation of the Trademark Clearinghouse within this application. BIP will adhere to all processes and procedures to comply with ICANN guidance once this guidance is finalized.

BIP intends to use the 〈.bloomberg〉 gTLD to register domain names for Bloomberg- related entities. BIP will be the only entity allowed to register domain names in the gTLD. We will exercise complete control of the gTLD, ensuring that no others may register names ending in 〈.bloomberg〉. This single point of control will help us eliminate infringing registrations in the TLD and allow us to rapidly react to any reports of such activity in the TLD.

As described in this response, BIP will implement a Sunrise period and Trademark Claims service with respect to the registration of domain names within the 〈.bloomberg〉 gTLD. Certain aspects of the Sunrise period and⁄or Trademark Claims service may be administered on behalf of BIP by BIP-approved registrars or by subcontractors of BIP, such as its selected backend registry services provider, Verisign.

Since BIP intends to register domain names only for its related entities, Bloomberg Philanthropies and Bloomberg, it is unlikely that disputes will arise concerning entitlement to specific 〈.bloomberg〉 domain names. In the event that both these entities seek to register the same domain name, BIP will look to management of these organizations to determine who should be entitled to the registration.

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 BIP 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 BIP either directly or through BIP-approved registrars.

BIP will require all registrants, either directly or through BIP-approved registrars, to i) affirm that said registrants meet the Sunrise Eligibility Requirements (SER) and ii) submit to the Sunrise Dispute Resolution Policy (SDRP) consistent with Section 6 of the Trademark Clearinghouse model. At a minimum BIP will recognize and honor all word marks for which a proof of use was submitted and validated by the Trademark Clearinghouse as well as any additional eligibility requirements as specified in Question 18.

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

Although the exact process for the Sunrise program and its interaction between the trademark owner, Registry, Registrar, and Trademark Clearinghouse is not completely defined in the Applicant Guidebook and is dependent on the current Request for Information issued by ICANN in its selection of a Trademark Clearinghouse provider, Verisign’s expertise in launching multiple Sunrise processes and its established software will implement a smooth and compliant Sunrise process for the new gTLDs.

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, BIP or the BIP-approved 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 that is 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, BIP or the BIP-approved 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, the BIP or the BIP-approved registrar will not process the domain name registration.

Following the registration of a domain name, the BIP-approved 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 BIP will recognize and honor all word marks validated by the Trademark Clearinghouse.

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

In addition to the Sunrise and Trademark Claims services described in Section 1 of this response, BIP shall implement and adhere to RPMs post-launch as mandated by ICANN, and confirms that registrars accredited for the 〈.bloomberg〉 gTLD are and shall remain in compliance with these mechanisms. Certain aspects of these post-launch RPMs may be administered on behalf of BIP by BIP-approved registrars or by subcontractors of BIP, such as its selected backend registry services provider, Verisign.

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, BIP 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 〈.bloomberg〉 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 not successful, ownership of the domain name remains with the domain name registrant. BIP and entities operating on its behalf adhere to all decisions rendered by UDRP providers.

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 on 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 web page provided by the URS provider. 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. If the complainant is not successful, the URS is terminated and full control of the domain name registration is returned to the domain name registrant. Similar to the existing UDRP, BIP and entities operating on its behalf adhere to decisions rendered by the URS providers.

BIP is fully aware of each of these requirements and will have the capability to implement these requirements for new gTLDs in 〈.bloomberg〉. In fact, during the IRT’s development of the URS, Verisign 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

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. BIP participates in the PDDRP process as specified in the Applicant Guidebook.

Thick WHOIS: The .bloomberg registry will include a thick WHOIS database as required in Specification 4 of the Registry agreement. A thick WHOIS provides numerous advantages including a centralized location of registrant information, the ability to more easily manage and control the accuracy of data, and a consistent user experience

Additional Measures Specific to Rights Protection. BIP provides the following additional measures against potentially abusive registrations, which 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:

Rapid Takedown or Suspension Based on Court Orders: BIP complies 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 TLD registry. These orders may be issued when abusive content, such as child pornography, counterfeit goods, or illegal pharmaceuticals, is associated with the domain name.

Anti-Abuse Process: BIP implements 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.

RESOURCING PLANS

BIP will rely upon its backend registry provider, Verisign, to devote the necessary resources to oversee the technical operation of the 〈.bloomberg〉 gTLD. However, the 〈.bloomberg〉 gTLD will also be supported by a cross functional team of BIP professionals. Numbers and types of employees will vary for each function but Web.com projects it will use the following personnel to support the operational requirements of the gTLD:

Legal and Compliance Officers 1 FTE (2 x .5 FTEs)
Technical Project Manager .5 FTE

The resources are more than adequate to support the rights protection mechanisms of the .bloomberg registry.

Resource Planning

Resource Planning Specific to Backend Registry Activities

Verisign, BIP’s 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 TLD. 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 this gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to BIP 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 whom 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 more than 13 years for .com, proving Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s TLD service offerings.

Customer Affairs Organization: 9
Customer Support Personnel: 36
Information Security Engineers: 11

All figures, tables and diagrams referenced in the following response can be found in the attachment titled “bloomberg_.string_Q30A Figures”

DETAILED DESCRIPTION OF THE PROCESSES AND SOLUTIONS DEPLOYED TO MANAGE LOGICAL SECURITY ACROSS INFRASTRUCTURE AND SYSTEMS, MONITORING AND DETECTING THREATS AND SECURITY VULNERABILITIES AND TAKING APPROPRIATE STEPS TO RESOLVE THEM

BIP’s selected backend registry services provider’s (Verisign’s) comprehensive security policy has evolved over the years as part of managing some of the world’s most critical TLDs. Verisign’s Information Security Policy is the primary guideline that sets the baseline for all other policies, procedures, and standards that Verisign follows. This security policy addresses all of the critical components for the management of backend registry services, including architecture, engineering, and operations.

Verisign’s general security policies and standards with respect to these areas are provided as follows:

Architecture

Information Security Architecture Standard: This standard establishes the Verisign standard for application and network architecture. The document explains the methods for segmenting application tiers, using authentication mechanisms, and implementing application functions.

Information Security Secure Linux Standard: This standard establishes the information security requirements for all systems that run Linux throughout the Verisign organization.

Information Security Secure Oracle Standard: This standard establishes the information security requirements for all systems that run Oracle throughout the Verisign organization.

Information Security Remote Access Standard: This standard establishes the information security requirements for remote access to terminal services throughout the Verisign organization.

Information Security SSH Standard: This standard establishes the information security requirements for the application of Secure Shell (SSH) on all systems throughout the Verisign organization.

Engineering

Secure SSL⁄TLS Configuration Standard: This standard establishes the information security requirements for the configuration of Secure Sockets Layer⁄Transport Layer Security (SSL⁄TLS) for all systems throughout the Verisign organization.

Information Security C++ Standards: These standards explain how to use and implement the functions and application programming interfaces (APIs) within C++. The document also describes how to perform logging, authentication, and database connectivity.

Information Security Java Standards: These standards explain how to use and implement the functions and APIs within Java. The document also describes how to perform logging, authentication, and database connectivity.

Operations

Information Security DNS Standard: This standard establishes the information security requirements for all systems that run DNS systems throughout the Verisign organization.

Information Security Cryptographic Key Management Standard: This standard provides detailed information on both technology and processes for the use of encryption on Verisign information security systems.

Secure Apache Standard: Verisign has a multitude of Apache web servers, which are used in both production and development environments on the Verisign intranet and on the Internet. They provide a centralized, dynamic, and extensible interface to various other systems that deliver information to the end user. Because of their exposure and the confidential nature of the data that these systems host, adequate security measures must be in place. The Secure Apache Standard establishes the information security requirements for all systems that run Apache web servers throughout the Verisign organization.

Secure Sendmail Standard: Verisign uses sendmail servers in both the production and development environments on the Verisign intranet and on the Internet. Sendmail allows users to communicate with one another via email. The Secure Sendmail Standard establishes the information security requirements for all systems that run sendmail servers throughout the Verisign organization.

Secure Logging Standard: This standard establishes the information security logging requirements for all systems and applications throughout the Verisign organization. Where specific standards documents have been created for operating systems or applications, the logging standards have been detailed. This document covers all technologies.

Patch Management Standard: This standard establishes the information security patch and upgrade management requirements for all systems and applications throughout Verisign.

General

Secure Password Standard: Because passwords are the most popular and, in many cases, the sole mechanism for authenticating a user to a system, great care must be taken to help ensure that passwords are “strong” and secure. The Secure Password Standard details requirements for the use and implementation of passwords.

Secure Anti-Virus Standard: Verisign must be protected continuously from computer viruses and other forms of malicious code. These threats can cause significant damage to the overall operation and security of the Verisign network. The Secure Anti-Virus Standard describes the requirements for minimizing the occurrence and impact of these incidents.

Security processes and solutions for the 〈.bloomberg〉 TLD are based on the standards defined above, each of which is derived from Verisign’s experience and industry best practice. These standards comprise the framework for the overall security solution and applicable processes implemented across all products under Verisign’s management. The security solution and applicable processes include, but are not limited to:

System and network access control (e.g., monitoring, logging, and backup)
Independent assessment and periodic independent assessment reports
Denial of service (DoS) and distributed denial of service (DDoS) attack mitigation
Computer and network incident response policies, plans, and processes
Minimization of risk of unauthorized access to systems or tampering with registry data
Intrusion detection mechanisms, threat analysis, defenses, and updates
Auditing of network access
Physical security

Further details of these processes and solutions are provided in Part B of this response.

Security Policy and Procedures for the Proposed Registry

Specific security policy related details, requested as the bulleted items of Question 30 – Part A, are provided here.

Independent Assessment and Periodic Independent Assessment Reports. To help ensure effective security controls are in place, BIP, through its selected backend registry services provider, Verisign, conducts a yearly American Institute of Certified Public Accountants (AICPA) and Canadian Institute of Chartered Accountants (CICA) SAS 70 audit on all of its data centers, hosted systems, and applications. During these SAS 70 audits, security controls at the operational, technical, and human level are rigorously tested. These audits are conducted by a certified and accredited third party and help ensure that Verisign in-place environments meet the security criteria specified in Verisign’s customer contractual agreements and are in accordance with commercially accepted security controls and practices. Verisign also performs numerous audits throughout the year to verify its security processes and activities. These audits cover many different environments and technologies and validate Verisign’s capability to protect its registry and DNS resolution environments. Figure 30A-1 lists a subset of the audits that Verisign conducts. For each audit program or certification listed in Figure 30A-1, Verisign has included, as attachments to the Part B component of this response, copies of the assessment reports conducted by the listed third-party auditor. From Verisign’s experience operating registries, it has determined that together these audit programs and certifications provide a reliable means to ensure effective security controls are in place and that these controls are sufficient to meet ICANN security requirements and therefore are commensurate with the guidelines defined by ISO 27001.

Augmented Security Levels or Capabilities. See Section 5 of this response.

Commitments Made to Registrants Concerning Security Levels. See Section 4 of this response.

SECURITY CAPABILITIES ARE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY

Verisign, BIP’s selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies.
Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the 〈.bloomberg〉 gTLD with necessary implementation and sustainment cost. 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 scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to BIP fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.

TECHNICAL PLAN ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION

Verisign, BIP’s 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 TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign continually to 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 this gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to BIP fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.

Verisign projects it will use the following personnel role, which is described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support its security policy:

Information Security Engineers: 11

SECURITY MEASURES ARE CONSISTENT WITH ANY COMMITMENTS MADE TO REGISTRANTS REGARDING SECURITY LEVELS

Verisign is BIP’s selected backend registry services provider. For the 〈.bloomberg〉 gTLD, no unique security measures or commitments must be made by Verisign or BIP to any registrant.

Security measures are appropriate for the applied-for gTLD string (For example, applications for strings with unique trust implications, such as financial services-oriented strings, would be expected to provide a commensurate level of security)

No unique security measures are necessary to implement the 〈.bloomberg〉 gTLD. As defined in Section 1 of this response, Verisign, BIP’s selected backend registry services provider, commits to providing backend registry services in accordance with the following international and relevant security standards:
American Institute of Certified Public Accountants (AICPA) and Canadian Institute of Chartered Accountants (CICA) SAS 70

WebTrust⁄SysTrust for Certification Authorities.

Paul Ramundo	VP⁄Assistant Secretary
Richard K. DeScherer	President⁄Secretary
William M. Ried	VP⁄Assistant Secretary

Paul Ramundo	VP⁄Assistant Secretary
William M. Ried	VP⁄Assistant Secretary

New gTLD Application Submitted to ICANN by: Bloomberg IP Holdings LLC

String: bloomberg

Originally Posted: 13 June 2012

Application ID: 1-1981-76785

Applicant Information

1. Full legal name

2. Address of the principal place of business

3. Phone number

4. Fax number

5. If applicable, website or URL

Primary Contact

6(a). Name

6(b). Title

6(c). Address

6(d). Phone Number

6(e). Fax Number

6(f). Email Address

Secondary Contact

7(a). Name

7(b). Title

7(c). Address

7(d). Phone Number

7(e). Fax Number

7(f). Email Address

Proof of Legal Establishment

8(a). Legal form of the Applicant

8(b). State the specific national or other jursidiction that defines the type of entity identified in 8(a).

8(c). Attach evidence of the applicant's establishment.

9(a). If applying company is publicly traded, provide the exchange and symbol.

9(b). If the applying entity is a subsidiary, provide the parent company.

9(c). If the applying entity is a joint venture, list all joint venture partners.

Applicant Background

11(a). Name(s) and position(s) of all directors

11(b). Name(s) and position(s) of all officers and partners

11(c). Name(s) and position(s) of all shareholders holding at least 15% of shares

11(d). For an applying entity that does not have directors, officers, partners, or shareholders: Name(s) and position(s) of all individuals having legal or executive responsibility

Applied-for gTLD string

13. Provide the applied-for gTLD string. If an IDN, provide the U-label.

14(a). If an IDN, provide the A-label (beginning with "xn--").

14(b). If an IDN, provide the meaning or restatement of the string in English, that is, a description of the literal meaning of the string in the opinion of the applicant.

14(c). If an IDN, provide the language of the label (in English).

14(c). If an IDN, provide the language of the label (as referenced by ISO-639-1).

14(d). If an IDN, provide the script of the label (in English).

14(d). If an IDN, provide the script of the label (as referenced by ISO 15924).

14(e). If an IDN, list all code points contained in the U-label according to Unicode form.

15(a). If an IDN, Attach IDN Tables for the proposed registry.

15(b). Describe the process used for development of the IDN tables submitted, including consultations and sources used.

15(c). List any variant strings to the applied-for gTLD string according to the relevant IDN tables.

16. Describe the applicant's efforts to ensure that there are no known operational or rendering problems concerning the applied-for gTLD string. If such issues are known, describe steps that will be taken to mitigate these issues in software and other applications.

17. (OPTIONAL) Provide a representation of the label according to the International Phonetic Alphabet (http://www.langsci.ucl.ac.uk/ipa/).

Mission/Purpose

18(a). Describe the mission/purpose of your proposed gTLD.

18(b). How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

18(c). What operating rules will you adopt to eliminate or minimize social costs?

Community-based Designation

19. Is the application for a community-based TLD?

20(a). Provide the name and full description of the community that the applicant is committing to serve.

20(b). Explain the applicant's relationship to the community identified in 20(a).

20(c). Provide a description of the community-based purpose of the applied-for gTLD.

20(d). Explain the relationship between the applied-for gTLD string and the community identified in 20(a).

20(e). Provide a description of the applicant's intended registration policies in support of the community-based purpose of the applied-for gTLD.

20(f). Attach any written endorsements from institutions/groups representative of the community identified in 20(a).

Geographic Names

21(a). Is the application for a geographic name?

Protection of Geographic Names

22. Describe proposed measures for protection of geographic names at the second and other levels in the applied-for gTLD.

Registry Services

23. Provide name and full description of all the Registry Services to be provided.

Demonstration of Technical & Operational Capability

24. Shared Registration System (SRS) Performance

25. Extensible Provisioning Protocol (EPP)

26. Whois

27. Registration Life Cycle

28. Abuse Prevention and Mitigation

29. Rights Protection Mechanisms

30(a). Security Policy: Summary of the security policy for the proposed registry

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