ICANN New gTLD Application

At Microsoft, we are motivated and inspired every day by how our customers use our software, services, and hardware to find creative solutions to business problems, to develop breakthrough ideas, and to stay connected to whatʹs most important to them.

Based on the information provided by ICANN, we expect that our customers will benefit if our new gTLD helps us to deliver a more secure, private computing experience.

i. What is the goal of your proposed gTLD in terms of areas of speciality, service levels or reputation?

The goal of the proposed .microsoft gTLD is to promote Microsoft’s products, services and brand. Because the .microsoft gTLD is the gTLD counterpart to our world-famous Microsoft brand, the importance of maintaining and strengthening this brand dictates that we operate the .microsoft registry to the highest service levels.

ii. What do you anticipate your proposed gTLD will add to the current space in terms of competition, differentiation or innovation?

Our proposed .microsoft gTLD will add differentiation to the current space because there is no .brand registry operated by the brand owner – let alone a .brand registry for a brand as widely known as the MICROSOFT brand, with connections to billions of customers, millions of developers, and hundreds of thousands of partners.

iii. What goals does your proposed gTLD have in terms of user experience?

We believe that the most engaging digital experiences will grow out of the combination of four things: smart devices, cloud-based services, natural forms of interaction between people and technology, and peopleʹs imaginations.

The opportunity to operate a new gTLD that exactly matches our primary brand – one of the most globally recognized brands in the world -- may help us to assist our customers in interacting securely across devices and services.

iv. Provide a complete description of the applicants intended registration policies in support of the goals above

The Microsoft Domain Name Management team is responsible for the development, maintenance and enforcement of the .microsoft Domain Management Policy (Msft DMP). The Msft DMP defines the rules for eligibility and domain name allocation, sets out the terms governing the use of a .microsoft domain name, and describes the dispute resolution policies for the .microsoft TLD. We intend to update and revise the Msft DMP as appropriate to reflect Microsoft’s commercial and strategic interests as well as ICANN Consensus Policy and Temporary Policy developments. We summarize below the Msft DMP.

Registration of a .microsoft domain name is a four-step process: Eligibility Confirmation, Naming Convention Check, Acceptable Use Review, and Registration.

Registration of a .microsoft domain name will be restricted to Microsoft Corporation and its wholly owned subsidiaries.

All domains in the .microsoft registry will be registered to Microsoft Corporation or one of its wholly owned subsidiaries.

Checks will be performed to ensure that each applied-for domain name satisfies the .microsoft Naming Conventions. Each .microsoft domain name must:
• not be a prohibited label such as “example”
• be at least 3 characters and no more than 63 characters long;
• not contain a hyphen on the 3rd and 4th position (tagged domains);
• contain only letters (a-z), numbers (0-9) and hyphens or a combination of these;
• start and end with an alphanumeric character, not a hyphen;
• not match any character strings reserved by ICANN; and
• not match any protected country or territory name identified in the internationally recognized lists set forth in Specification 5 to the New gTLD Agreement, unless Microsoft reaches agreement regarding release of such names with the applicable government or pursuant to a proposal reviewed by the ICANN Governmental Advisory Committee and approved by ICANN.

The .microsoft registry may support Internationalized domain names (IDN) at the second level.

.microsoft domain names must be used solely for purposes that, in Microsoft’s sole discretion and judgment, enhance its strategic or commercial interests. .microsoft domains may not be used to knowingly infringe, violate, or misappropriate the intellectual property rights of any third party.

Registrants may not assign any rights in .microsoft domains to any third party.

Microsoft will require that the WHOIS data for all .microsoft domains is accurate and complete.

v. Will your proposed gTLD impose any measures for protecting the privacy of confidential information of registrants or users?

Microsoft is committed to protecting the privacy of employee and customer data.

The .microsoft registry will be operated by the Microsoft Corporation, a corporation organized under the laws of the State of Washington; data will be processed in accordance with applicable data protection requirements. We intend to comply with the Personal Data obligations set forth in Section 2.10 of the Registry Agreement.

vi. Describe whether and in what ways outreach and communications will help to achieve your projected benefits?

We anticipate engaging in the types and scope of outreach and communications appropriate to the operation of a .brand registry in which the brand owner and its wholly owned subsidiaries are the registrants of all second-level domain names.

1 CUSTOMARY REGISTRY SERVICES
As Microsoft Corporation (“Microsoft”)’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. 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.
1.1 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 Microsoft’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 3 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.
iii. 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 Microsoft’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 Microsoft’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.
2 OTHER PRODUCTS OR SERVICES THE REGISTRY OPERATOR IS REQUIRED TO PROVIDE BECAUSE OF THE ESTABLISHMENT OF A CONSENSUS POLICY
Verisign, Microsoft’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 .MICROSOFT 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.
2.1 Inter-Registrar Transfer Policy (IRTP)
Technical Component: In compliance with the IRTP consensus policy, Verisign, Microsoft’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:
• Allows the losing registrar to proactively ‘ACK’ or acknowledge a transfer prior to the expiration of the five-day Transfer grace period
• Allows the losing registrar to proactively ‘NACK’ or not acknowledge a transfer prior to the expiration of the five-day Transfer grace period
• 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. Microsoft’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 Microsoft in a consulting capacity as needed.
Unique to the TLD: This service is not provided in a manner unique to the .MICROSOFT TLD.
2.2 Add Grace Period (AGP) Limits Policy
Technical Component: Verisign’s registry system monitors registrars’ Add grace period deletion activity and provides reporting that permits Microsoft to assess registration fees upon registrars that have exceeded the AGP thresholds stipulated in the AGP Limits Policy. Further, Microsoft accepts and evaluates all exemption requests received from registrars and determines whether the exemption request meets the exemption criteria. Microsoft maintains all AGP Limits Policy exemption request activity so that this material may be included within Microsoft’s Monthly Registry Operator Report to ICANN.
Registrars that exceed the limits established by the policy may submit exemption requests to Microsoft for consideration. Microsoft’s compliance office reviews these exemption requests in accordance with the AGP Limits Policy and renders a decision. Upon request, Microsoft 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, Microsoft 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, Microsoft’s backend registry services provider, has had experience with this policy since its implementation in April 2009 and is available to support Microsoft in a consulting capacity as needed.
Unique to the TLD: This service is not provided in a manner unique to the .MICROSOFT TLD.
2.3 Registry Services Evaluation Policy (RSEP)
Technical Component: Verisign, Microsoft’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, Microsoft’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 .MICROSOFT TLD.
3 PRODUCTS OR SERVICES ONLY A REGISTRY OPERATOR IS CAPABLE OF PROVIDING BY REASON OF ITS DESIGNATION AS THE REGISTRY OPERATOR
Verisign, Microsoft’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.
Microsoft 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.
3.1 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 .MICROSOFT TLD.

1 ROBUST PLAN FOR OPERATING A RELIABLE SRS
1.1 High-Level Shared Registration System (SRS) System Description
Verisign, Microsoft Corporation (“Microsoft”)’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 .MICROSOFT 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 .MICROSOFT gTLD. The application servers store Microsoft’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.

Scalability and Performance. Verisign, Microsoft’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.
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 .MICROSOFT gTLD registry, this flexibility minimizes unplanned downtime and provides a more consistent end-user experience.
1.2 Representative Network Diagrams
Figure 24 3 provides a summary network diagram of Microsoft’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.
1.3 Number of Servers
As Microsoft’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 .MICROSOFT gTLD, Verisign uses a minimum of 100 dedicated servers per SRS site. These servers are virtualized to meet demand.

1.4 Description of Interconnectivity with Other Registry Systems
Figure 24 4 provides a technical overview of the Microsoft’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.
1.5 Frequency of Synchronization Between Servers
As Microsoft’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.
1.6 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.”
2 SCALABILITY AND PERFORMANCE ARE CONSISTENT 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 .MICROSOFT 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 Microsoft 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.
3 TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION
Verisign, the Microsoft’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 Microsoft 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 .MICROSOFT gTLD as described in this application, Verisign, Microsoft’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.
4 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,Microsoft’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, Microsoft 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 .MICROSOFT 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

1	COMPLETE KNOWLEDGE AND UNDERSTANDING OF THIS ASPECT OF REGISTRY TECHNICAL REQUIREMENTS
Verisign, Microsoft Corporation (“Microsoft”)’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.
1.1	EPP Interface with Registrars
Verisign, Microsoft’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. 
2	TECHNICAL PLAN SCOPE⁄SCALE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY
Verisign, Microsoft’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 .MICROSOFT 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 Microsoft 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.
3	TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION
Verisign, Microsoft’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 Microsoft 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 .MICROSOFT gTLD as described in this application, Verisign, Microsoft’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 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.
4	ABILITY TO COMPLY WITH RELEVANT RFCS 
Verisign, Microsoft’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 .MICROSOFT 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)
5	PROPRIETARY EPP EXTENSIONS
Verisign, Microsoft’s selected backend registry services provider, 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.
5.1	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, Microsoft’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: 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 version=ʺ1.0ʺ encoding=ʺUTF-8ʺ?〉

〈schema targetNamespace=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄idnLang-1.0ʺ
  xmlns:idnLang=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄idnLang-1.0ʺ
  xmlns=ʺhttp:⁄⁄www.w3.org⁄2001⁄XMLSchemaʺ
  elementFormDefault=ʺqualifiedʺ〉

〈annotation〉
  〈documentation〉
    Extensible Provisioning Protocol v1.0 domain name
    extension schema for IDN Lang Tag.
  〈⁄documentation〉
〈⁄annotation〉

〈!--
Child elements found in EPP commands.
--〉
  〈element name=ʺtagʺ type=ʺlanguageʺ⁄〉

  〈!--
  End of schema.
  --〉
〈⁄schema〉


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: 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 version=ʺ1.0ʺ encoding=ʺUTF-8ʺ?〉

〈schema targetNamespace=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄rgp-poll-1.0ʺ
  xmlns:rgp-poll=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄rgp-poll-1.0ʺ
  xmlns:eppcom=ʺurn:ietf:params:xml:ns:eppcom-1.0ʺ
  xmlns:rgp=ʺurn:ietf:params:xml:ns:rgp-1.0ʺ
  xmlns=ʺhttp:⁄⁄www.w3.org⁄2001⁄XMLSchemaʺ
  elementFormDefault=ʺqualifiedʺ〉

〈!--
Import common element types.
--〉
〈import namespace=ʺurn:ietf:params:xml:ns:eppcom-1.0ʺ
  schemaLocation=ʺeppcom-1.0.xsdʺ⁄〉
〈import namespace=ʺurn:ietf:params:xml:ns:rgp-1.0ʺ
  schemaLocation=ʺrgp-1.0.xsdʺ⁄〉

〈annotation〉
  〈documentation〉
    Extensible Provisioning Protocol v1.0
    Verisign poll notification specification for registry grace period
    poll notifications.
  〈⁄documentation〉
〈⁄annotation〉

〈!--
Child elements found in EPP commands.
--〉
〈element name=ʺpollDataʺ type=ʺrgp-poll:pollDataTypeʺ⁄〉

〈!--
Child elements of the 〈notifyData〉 element for the
redemption grace period.
--〉
〈complexType name=ʺpollDataTypeʺ〉
  〈sequence〉
    〈element name=ʺnameʺ type=ʺeppcom:labelTypeʺ⁄〉
    〈element name=ʺrgpStatusʺ type=ʺrgp:statusTypeʺ⁄〉
    〈element name=ʺreqDateʺ type=ʺdateTimeʺ⁄〉
    〈element name=ʺreportDueDateʺ type=ʺdateTimeʺ⁄〉
  〈⁄sequence〉
〈⁄complexType〉
〈
!--
End of schema.
--〉
〈⁄schema〉


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: 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 version=ʺ1.0ʺ encoding=ʺUTF-8ʺ?〉

〈schema targetNamespace=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄whoisInf-1.0ʺ
  xmlns:whoisInf=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄whoisInf-1.0ʺ
  xmlns:eppcom=ʺurn:ietf:params:xml:ns:eppcom-1.0ʺ
  xmlns=ʺhttp:⁄⁄www.w3.org⁄2001⁄XMLSchemaʺ
  elementFormDefault=ʺqualifiedʺ〉

〈import namespace=ʺurn:ietf:params:xml:ns:eppcom-1.0ʺ
  schemaLocation=ʺeppcom-1.0.xsdʺ⁄〉

〈annotation〉
  〈documentation〉
    Extensible Provisioning Protocol v1.0
    extension schema for Whois Info
  〈⁄documentation〉
〈⁄annotation〉

〈!--
Possible Whois Info extension root elements.
--〉
〈element name=ʺwhoisInfʺ type=ʺwhoisInf:whoisInfTypeʺ⁄〉
〈element name=ʺwhoisInfDataʺ type=ʺwhoisInf:whoisInfDataTypeʺ⁄〉

〈!--
Child elements for the 〈whoisInf〉 extension which
is used as an extension to an info command.
--〉
〈complexType name=ʺwhoisInfTypeʺ〉
  〈sequence〉
    〈element name=ʺflagʺ type=ʺbooleanʺ⁄〉
  〈⁄sequence〉
〈⁄complexType〉

〈!--
Child elements for the 〈whoisInfData〉 extension which
is used as an extension to the info response.
--〉
〈complexType name=ʺwhoisInfDataTypeʺ〉
  〈sequence〉
  〈element name=ʺregistrarʺ type=ʺstringʺ⁄〉
  〈element name=ʺwhoisServerʺ type=ʺeppcom:labelTypeʺ
    minOccurs=ʺ0ʺ⁄〉
  〈element name=ʺurlʺ type=ʺtokenʺ minOccurs=ʺ0ʺ⁄〉
  〈element name=ʺirisServerʺ type=ʺeppcom:labelTypeʺ
    minOccurs=ʺ0ʺ⁄〉
  〈⁄sequence〉
  〈⁄complexType〉

〈⁄schema〉


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: 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 version=ʺ1.0ʺ encoding=ʺUTF-8ʺ?〉

   〈schema targetNamespace=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄sync-1.0ʺ
           xmlns:sync=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄sync-1.0ʺ
           xmlns=ʺhttp:⁄⁄www.w3.org⁄2001⁄XMLSchemaʺ
           elementFormDefault=ʺqualifiedʺ〉

     〈annotation〉
       〈documentation〉
         Extensible Provisioning Protocol v1.0 domain name
         extension schema for expiration date synchronization.
       〈⁄documentation〉
     〈⁄annotation〉

   〈!--
   Child elements found in EPP commands.
   --〉
     〈element name=ʺupdateʺ type=ʺsync:updateTypeʺ⁄〉

   〈!--
   Child elements of the 〈update〉 command.
   --〉
     〈complexType name=ʺupdateTypeʺ〉
       〈sequence〉
         〈element name=ʺexpMonthDayʺ type=ʺgMonthDayʺ⁄〉
       〈⁄sequence〉
     〈⁄complexType〉

   〈!--
   End of schema.
   --〉
   〈⁄schema〉


XML templates⁄schema for namestoreExt-1.1
•	Template: The templates for namestoreExt-1.1 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄namestore-extension.pdf.
•	Schema: This schema describes the extension mapping for the routing with an EPP intelligent gateway to a pluggable set of backend products and services. The mapping extends the EPP domain name and host mapping to provide a sub-product identifier to identify the target sub-product that the EPP operation is intended for.

〈?xml version=ʺ1.0ʺ encoding=ʺUTF-8ʺ?〉

〈schema targetNamespace=ʺhttp:⁄⁄www.Verisign-grs.com⁄epp⁄namestoreExt-1.1ʺ
  xmlns=ʺhttp:⁄⁄www.w3.org⁄2001⁄XMLSchemaʺ
  xmlns:namestoreExt=ʺhttp:⁄⁄www.Verisign-grs.com⁄epp⁄namestoreExt-1.1ʺ
  elementFormDefault=ʺqualifiedʺ〉

〈annotation〉
  〈documentation〉
    Extensible Provisioning Protocol v1.0 Namestore extension schema
    for destination registry routing.
  〈⁄documentation〉
〈⁄annotation〉

〈!-- General Data types. --〉
〈simpleType name=ʺsubProductTypeʺ〉
  〈restriction base=ʺtokenʺ〉
    〈minLength value=ʺ1ʺ⁄〉
    〈maxLength value=ʺ64ʺ⁄〉
  〈⁄restriction〉
〈⁄simpleType〉

〈complexType name=ʺextAnyTypeʺ〉
  〈sequence〉
    〈any namespace=ʺ##otherʺ maxOccurs=ʺunboundedʺ⁄〉
  〈⁄sequence〉
〈⁄complexType〉

〈!-- Child elements found in EPP commands and responses. --〉
〈element name=ʺnamestoreExtʺ type=ʺnamestoreExt:namestoreExtTypeʺ⁄〉

〈!-- Child elements of the 〈product〉 command. --〉
〈complexType name=ʺnamestoreExtTypeʺ〉
  〈sequence〉
    〈element name=ʺsubProductʺ
      type=ʺnamestoreExt:subProductTypeʺ⁄〉
  〈⁄sequence〉
〈⁄complexType〉

〈!-- Child response elements. --〉
〈element name=ʺnsExtErrDataʺ type=ʺnamestoreExt:nsExtErrDataTypeʺ⁄〉

〈!-- 〈prdErrData〉 error response elements. --〉
〈complexType name=ʺnsExtErrDataTypeʺ〉
  〈sequence〉
    〈element name=ʺmsgʺ type=ʺnamestoreExt:msgTypeʺ⁄〉
  〈⁄sequence〉
  〈⁄complexType〉

〈!-- 〈prdErrData〉 〈msg〉 element. --〉
〈complexType name=ʺmsgTypeʺ〉
  〈simpleContent〉
    〈extension base=ʺnormalizedStringʺ〉
      〈attribute name=ʺcodeʺ
        type=ʺnamestoreExt:prdErrCodeTypeʺ use=ʺrequiredʺ⁄〉
      〈attribute name=ʺlangʺ type=ʺlanguageʺ default=ʺenʺ⁄〉
    〈⁄extension〉
  〈⁄simpleContent〉
〈⁄complexType〉

〈!-- 〈prdErrData〉 error response codes. --〉
〈simpleType name=ʺprdErrCodeTypeʺ〉
  〈restriction base=ʺunsignedShortʺ〉
    〈enumeration value=ʺ1ʺ⁄〉
  〈⁄restriction〉
〈⁄simpleType〉

〈!-- End of schema. --〉
〈⁄schema〉

XML templates⁄schema for lowbalance-poll-1.0
•	Template: The templates for lowbalance-poll-1.0 can be found in Chapter 3, EPP Command Mapping of the relevant EPP documentation, http:⁄⁄www.verisigninc.com⁄assets⁄low-balance-mapping.pdf.
•	Schema: This schema describes the extension mapping for the account low balance notification. The mapping extends the EPP base mapping so an account holder can be notified via EPP poll messages whenever the available credit for an account reaches or goes below the credit threshold.

〈?xml version=ʺ1.0ʺ encoding=ʺUTF-8ʺ?〉

〈schema targetNamespace=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄lowbalance-poll-1.0ʺ
  xmlns:lowbalance-poll=ʺhttp:⁄⁄www.Verisign.com⁄epp⁄lowbalance-poll-1.0ʺ
  xmlns:eppcom=ʺurn:ietf:params:xml:ns:eppcom-1.0ʺ
  xmlns=ʺhttp:⁄⁄www.w3.org⁄2001⁄XMLSchemaʺ
  elementFormDefault=ʺqualifiedʺ〉

〈!-- Import common element types.--〉
〈import namespace=ʺurn:ietf:params:xml:ns:eppcom-1.0ʺ
  schemaLocation=ʺeppcom-1.0.xsdʺ⁄〉

〈annotation〉
  〈documentation〉
    Extensible Provisioning Protocol v1.0
    Verisign poll notification specification for low balance notifications.
  〈⁄documentation〉
〈⁄annotation〉

〈!--Child elements found in EPP commands.--〉
〈element name=ʺpollDataʺ type=ʺlowbalance-poll:pollDataTypeʺ⁄〉

〈!--Child elements of the 〈notifyData〉 element for the low balance.--〉
〈complexType name=ʺpollDataTypeʺ〉
  〈sequence〉
    〈element name=ʺregistrarNameʺ type=ʺeppcom:labelTypeʺ⁄〉
    〈element name=ʺcreditLimitʺ type=ʺnormalizedStringʺ⁄〉
    〈element name=ʺcreditThresholdʺ
      type=ʺlowbalance-poll:thresholdTypeʺ⁄〉
    〈element name=ʺavailableCreditʺ type=ʺnormalizedStringʺ⁄〉
  〈⁄sequence〉
〈⁄complexType〉

〈complexType name=ʺthresholdTypeʺ〉
  〈simpleContent〉
    〈extension base=ʺnormalizedStringʺ〉
      〈attribute name=ʺtypeʺ
        type=ʺlowbalance-poll:thresholdValueTypeʺ
        use=ʺrequiredʺ⁄〉
    〈⁄extension〉
  〈⁄simpleContent〉
〈⁄complexType〉

〈simpleType name=ʺthresholdValueTypeʺ〉
  〈restriction base=ʺtokenʺ〉
    〈enumeration value=ʺFIXEDʺ⁄〉
    〈enumeration value=ʺPERCENTʺ⁄〉
  〈⁄restriction〉
〈⁄simpleType〉

〈!-- End of schema.--〉
〈⁄schema〉

6	PROPRIETARY EPP EXTENSION CONSISTENCY WITH REGISTRATION LIFECYCLE 
Microsoft’s selected backend registry services provider’s (Verisign’s) proprietary EPP extensions, defined in Section 5 above, are consistent with the registration lifecycle documented in the response to Question 27, Registration Lifecycle.  Details of the registration lifecycle are presented in that response. As new registry features are required, Verisign develops proprietary EPP extensions to address new operational requirements. Consistent with ICANN procedures Verisign adheres to all applicable Registry Services Evaluation Process (RSEP) procedures.

1 COMPLETE KNOWLEDGE AND UNDERSTANDING OF THIS ASPECT OF REGISTRY TECHNICAL REQUIREMENTS
Verisign, Microsoft Corporation (“Microsoft”)’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 .MICROSOFT 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.
1.1 High-Level Whois System Description
Like all other components of Microsoft’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 .MICROSOFT 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:
o Domain name, including the TLD (e.g., EXAMPLE.TLD)
o Full name of the registrar, including punctuation (e.g., Example Registrar, Inc.)
o 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, Microsoft’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.
1.2 Relevant Network Diagrams
Figure 26 1 provides a summary network diagram of the Whois service provided by Verisign, Microsoft’s selected backend registry services provider. The figure details the configuration with one resolution⁄Whois site. For the .MICROSOFT 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.
1.3 IT and Infrastructure Resources
Figure 26 2 summarizes the IT and infrastructure resources that Verisign, Microsoft’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.
1.4 Description of Interconnectivity with Other Registry Systems
Figure 26 3 provides a technical overview of the registry system provided by Verisign, Microsoft’s selected backend registry services provider, and shows how the Whois service component fits into this larger system and interconnects with other system components.
1.5 Frequency of Synchronization Between Servers
Synchronization between the SRS and the geographically distributed Whois resolution sites occurs approximately every three minutes. Verisign, Microsoft’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.
2 TECHNICAL PLAN SCOPE⁄SCALE CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY
Verisign, Microsoft’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 .MICROSOFT 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 Microsoft 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.
3 TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION
Verisign, Microsoft’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 Microsoft 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 Whois services:
• Application Engineers: 19
• Database Engineers: 3
• Quality Assurance Engineers: 11

To implement and manage the .MICROSOFT gTLD as described in this application, Verisign, Microsoft’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.
4 COMPLIANCE WITH RELEVANT RFC
Microsoft’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⁄.
5 COMPLIANCE WITH SPECIFICATIONS 4 AND 10 OF REGISTRY AGREEMENT
In accordance with Specification 4, Verisign, Microsoft’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. Figure 26 4 through Figure 26 6 provide the query and response format for domain name, registrar, and name server data objects.
5.1 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 (approx. 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
6 SEARCHABLE WHOIS
Verisign, Microsoft’s selected backend registry services provider, provides a searchable Whois service for the .MICROSOFT 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 Microsoft’s defined .MICROSOFT 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, Microsoft’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.

1 COMPLETE KNOWLEDGE AND UNDERSTANDING OF REGISTRATION LIFECYCLES AND STATES

Starting with domain name registration and continuing through domain name delete operations, Microsoft Corporation (“Microsoft”)’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.

1.1 Registration Lifecycle of Create⁄Update⁄Delete

The following section details the create⁄update⁄delete processes and the related renewal process that Verisign, Microsoft’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 .MICROSOFT.
• 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 .MICROSOFT.
• 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.

1.2 Pending, Locked, Expired, and Transferred

Verisign, Microsoft’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

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

Verisign, Microsoft’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.

1.4 Aspects of the Registration Lifecycle Not Covered by Standard EPP RFCs

Microsoft’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.

2 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 .MICROSOFT gTLD as well as other TLDs managed by Verisign, Microsoft’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 .MICROSOFT 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.

3 COMPLIANCE WITH RELEVANT RFCs

Microsoft’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 .MICROSOFT database. Two identical second-level domain names cannot simultaneously exist in .MICROSOFT. 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

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

Verisign, Microsoft’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 Microsoft 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 the registration lifecycle:
• Application Engineers: 19
• Customer Support Personnel: 36
• Database Administrators: 8
• Database Engineers: 3
• Quality Assurance Engineers: 11
• SRS System Administrators: 13

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.

1. COMPREHENSIVE ABUSE POLICIES, WHICH INCLUDE CLEAR DEFINITIONS OF WHAT CONSTITUTES ABUSE IN THE TLD, AND PROCEDURES THAT WILL EFFECTIVELY MINIMIZE POTENTIAL FOR ABUSE IN THE TLD
Microsoft is fully aware that a robust abuse prevention and mitigation plan is essential for a new gTLD to guarantee the stability and security of the Internet space. Microsoft and its registry services provider believe that a registry must achieve all the technical standards established by ICANN, which will ultimately benefit the entire Internet community.

Microsoft has systems and experts in place to combat malicious behaviors targeted at Microsoft and indeed at internet users: it is Microsoft’s policy to be pro-active in tackling malicious behaviors to prevent its millions of customers around the world from having their systems and data compromised. For example, see http:⁄⁄www.MICROSOFT.com⁄presspass⁄press⁄2009⁄feb09⁄02-12confickerpr.mspx which describes how Microsoft’s Trustworthy Computing Group helped unify broad efforts being employed across the security industry and within academia, to implement a community-based defense to disrupt the spread of Conficker. Co-operating with security researchers, ICANN and operators within the Domain Name System, Microsoft coordinated a response designed to disable domains targeted by Conficker. Microsoft also announced a $250,000 reward for information leading to the arrest and conviction of those responsible for illegally launching the Conficker malicious code on the Internet.

In addition, Verisign, Microsoft’s registry services provider, also brings extensive experience on minimizing malicious and abusive behaviors within the domain name space. Microsoft will be fully prepared and supported by Verisign to combat any kind of threat or malicious activity in its new gTLD.

Abusive or malicious activities cover a wide range of threats, including but not limited to:
• Illegal or fraudulent actions
• Spam
• Phishing
• Pharming
• Distribution of malware
• Botnets command and control
• Misuse of trademarks and other IPR
• Unauthorized distribution of copyright material
• Distribution of child pornography

In addition to the measures required by ICANN to eliminate and minimize domain name abuse, Microsoft will implement an Anti-Abuse policy, provide Whois accuracy services, and conduct monitoring activities to maintain the security of its registry.

Microsoft will implement its abuse prevention strategy in accordance with ICANN requirements for the benefit of the entire Internet community. The following paragraphs explain the Anti-Abuse policies and procedures that Microsoft will implement with the support and expertise of Verisign.
1.1 .MICROSOFT Abuse Prevention and Mitigation Implementation Plan

Microsoft designed its Anti-Abuse Policy, which will apply to all of its new gTLDs, to combat malicious or abusive use activities that could harm not only Microsoft, but also Internet users. Because Microsoft intends to run a closed brand TLD registry, abusive or malicious behavior will be less likely to occur.

1.2 Policies for Handling Complaints Regarding Abuse

Microsoft will establish and publish a unique Abuse Point of Contact, which will include a role e-mail address and a telephone number and mailing address. This role e-mail address will allow the designated staff to receive and promptly respond to reports of or complaints about abuse and⁄or malicious activity in the new gTLD.

Microsoft’s Abuse Point of Contact will evaluate complaints and reports and produce abuse reports when necessary. All reports and complaints will be analyzed by abuse prevention staff and experts to assess the threat posed by the reported abusive or malicious behavior. Action in response to reported and confirmed abusive or malicious behavior will be commensurate with the assessed threat level. Such action may include rapid takedown, suspension, or cancellation, and sharing of information regarding abusive or malicious behavior with other organizations and entities with which Microsoft cooperates in combating abusive and malicious behavior.

The Abuse Point of Contact email and telephone number will be monitored 24⁄7. A response will be supplied to 99.9% of on-line reports of malicious or abusive behavior within one minute of reporting with the subsequent investigations starting the next working day when verification of malicious activity and the process to remove infections will be commenced. The aim will be to conclude a response within 24 hours if this is technically possible.

Microsoft intends to cooperate with appropriate law enforcement entities and investigations in connection with and in furtherance of abuse prevention in .MICROSOFT.

1.3 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. Microsoft’s selected backend registry services provider’s (Verisign’s) 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.

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

1.5 Measures to Promote Whois Accuracy
The .MICROSOFT registry will implement several measures to promote Whois accuracy.

Whois service for .MICROSOFT will operate as follows: all basic contact details for each domain name is kept in a unique internal system by the registry, which facilitates the access to the domain information. In addition, Microsoft will perform internal monitoring checks and procedures which will only allow accurate Whois information and remove outdated data.

1.5.1 Authentication of Registrant Information
All registrant information will be authenticated as complete and accurate at the time of registration through verification of all contact information mentioned in registration data. In addition, the .MICROSOFT registry will regularly monitor registration data for accuracy and completeness, employ authentication methods, and establish policies and procedures to address domain names with inaccurate or incomplete Whois data.

1.5.2 Regular Monitoring of Registration Data for Accuracy and Completeness
Verisign, Microsoft’s selected backend registry services provider, has implemented specific policies and procedures to require registrars to comply with ICANN’s Whois requirements. Microsoft will regularly remind its registrar of its obligation to comply with ICANN’s Whois Data Reminder Policy, which includes accuracy in dealing with the Whois information provided, to evaluate claims of fraudulent Whois data and to cancel domain name registrations with outdated Whois details.

1.5.3 Use of Registrars
As stated previously in other answers, only Microsoft Corporation and its Affiliates will be permitted to register and use .MICROSOFT domain names. Accordingly, the duties of the .MICROSOFT registrar will be very limited and closely defined. However, as part of the RRA (Registry Registrar Agreement), Microsoft will require the .MICROSOFT registrar to take steps necessary to ensure Whois data is complete and accurate and to implement the .MICROSOFT registration policies.

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

Microsoft defines malicious or abusive behavior as including, without limitation, the following:

• Illegal or fraudulent actions
• Spam
• Phishing
• Pharming
• Willful distribution of malware
• Botnet command and control
• Misuse of trademarks and other IPR
• Unauthorized distribution of copyright material
• Distribution of child pornography

The Registry Abuse team will respond to reports alleging malicious or abusive behaviors in conformance with strict SLAs that will be set to reflect industry Best Practice. Currently it is anticipated that a response will be supplied to 99.9% of on-line reports of malicious or abusive behavior within one minute of reporting with the subsequent investigations starting the next working day when verification of malicious activity and the process to remove infections will be commenced. The aim will be to conclude a response within 24 hours if this is technically possible. As suspending or cancelling a compromised domain can be undertaken very quickly, we are confident abusive behaviors will be minimized. A valid email address will be maintained to assist with reporting.

1.7 Controls to Ensure Proper Access to Domain Functions
Microsoft takes very seriously a registry operator’s responsibility of ensuring secure and stable access to domain functions. Microsoft believes that its decision to restrict registration and use of .MICROSOFT domains to itself and its Affiliates will decrease the likelihood of abusive or malicious domain activity in .MICROSOFT. However, Microsoft’s registry services provider will employ a multi-factor authentication process (to be explained below) to minimize potential threats to Microsoft, the registry services provider and Internet users.

1.7.1 Multi-Factor Authentication
To ensure proper access to domain functions, Microsoft 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.

1.7.2 Requiring Multiple, Unique Points of Contact

The Registry Service Provider will maintain correspondence with multiple points of contact within Microsoft including but not limited to the Legal Manager and the Domain Management Team in order to ensure that all relevant stakeholders are kept abreast of important issues as they occur. Any decision in relation to the suspension or termination of a domain name that is supporting abusive behavior will be taken by the Legal Manager who will first consult with the Domain Management Team. Microsoft has an experienced Anti-Abuse & Security Team who will be available around the clock to assist with the most serious incidents.

1.7.3 Requiring the Notification of Multiple, Unique Points of Contact
The primary contact for all abuse incidents will be the Legal Manager. The Legal Manager will have the responsibility, for example, of determining when a domain should be locked or cancelled.

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

Resource Planning
Microsoft dedicates significant financial and personnel resources to combating malicious and abusive behavior in the DNS. Microsoft will extend these resources to encompass the designation and maintenance of the unique Abuse Point of Contact, regular monitoring of potential abusive and malicious activities with support from dedicated technical staff, analysis of reported abuse and malicious activity, and action to address such reported activity.

The designated abuse prevention staff will be subject to regular evaluations, receive adequate training and work under expert supervision. The abuse prevention resources will comprise both internal staff and external abuse prevention experts who will give extra advice and support when necessary.

Resource Planning Specific to Backend Registry Activities
Verisign, Microsoft’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 gTLDs initial implementation and ongoing maintenance. VeriSign’s pricing for the backend registry services it provides to Microsoft 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.

• 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

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.

3. POLICIES AND PROCEDURES IDENTIFY AND ADDRESS THE ABUSIVE USE OF REGISTERED NAMES
3.1 Policies and Procedures That Identify Malicious or Abusive Behavior
Verisign, Microsoft’s selected backend registry services provider, provides the following service to Microsoft 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.

3.2 Policies and Procedures That Address the Abusive Use of Registered Names

Suspension processes based on Court Orders or investigations. Because domain names can be used to engage in malicious and abusive activity on the Internet, including malware, pharming, and phishing, the most efficient measure to combat such activity may, under certain circumstances, be to deactivate the domain. Microsoft will implement a rapid takedown process based on, for example, court orders, appropriate and documented requests from law enforcement, and the results of its own internal threat analyses and assessment.

Suspension processes conducted by backend registry services provider. In the case of domain name abuse, Microsoft will determine whether to take down the subject domain name. Verisign, Microsoft’s selected backend registry services provider, will follow the following auditable processes to comply with the suspension request.

Verisign Suspension Notification. Microsoft 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 Microsoft, 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 Microsoft with the following information:
• Threat domain name
• Registry incident number
• Verisign case number
• Error reason

Upon Microsoft request, Verisign can provide a process for registrants to protest the suspension.

Domain Suspension. Verisign places the domain to be suspended on the following statuses:
• serverUpdateProhibited
• serverDeleteProhibited
• serverTransferProhibited
• serverHold

Suspension Acknowledgement. Verisign notifies Microsoft 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
• Microsoft abuse contact name and number, or registrar abuse contact name and number
• Suspension status

4. WHEN EXECUTED IN ACCORDANCE WITH THE REGISTRY AGREEMENT, PLANS WILL RESULT IN COMPLIANCE WITH CONTRACTUAL REQUIREMENTS
Microsoft is confident that its vast expertise in combating malicious and abusive activity on the Internet, its extensive and detailed attention to the potential issue of abuse, and the experience and advice of its chosen backend registry provider, Verisign, will enable Microsoft to comply with all its contractual requirements in the Registry Agreement.

5. TECHNICAL PLAN SCOPE⁄SCALE THAT IS CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY
Scope⁄Scale Consistency
Microsoft intends to register a maximum of 1,000 .MICROSOFT domains for its own use across three years of operation. Microsoft is confident that the plans and processes outlined in this answer are, in fact, consistent with a registry of much greater size.

Scope⁄Scale Consistency Specific to Backend Registry Activities
Verisign, Microsoft’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 .MICROSOFT 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 Microsoft 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.

1 MECHANISMS DESIGNED TO PREVENT ABUSIVE REGISTRATIONS

Rights protection is a core objective of Microsoft.

Microsoft 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. Microsoft 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 .MICROSOFT 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, Microsoft cannot fully detail the specific implementation of the Trademark Clearinghouse within this application. Microsoft will adhere to all processes and procedures to comply with ICANN guidance once this guidance is finalized.

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

This registry will be a private brand registry with eligibility requirements and rules of registration that permit only Microsoft and its Affiliates to register and use domains. This means that bad faith registration should be minimized or even completely eliminated.

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.

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 Microsoft either directly or through Microsoft-approved registrars.

The Sunrise period will be executed by Microsoft in accordance with its Sunrise policy. A team will be designated by Microsoft to oversee the execution of Right Protection Mechanisms (RPM), compromising its current domain name manager and an IP specialist. Registrants that wish to participate in the Sunrise must register their rights in the Trademark Clearinghouse and approved registrars must give affirmative consent to the terms of the Registry-Registrar Agreement in advance of the Sunrise process. Microsoft’s RPM team will then generate the trademark data of the Sunrise applicants, and review the documentation and information submitted by approved registrars in order to verify the sunrise eligibility of the applications according to Sunrise Eligibility Requirements included in the sunrise policy.

Microsoft requires all registrants, either directly or through Microsoft-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 Microsoft recognizes and honors 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.

Both the registration policy and sunrise policy will require all registrants to be either Microsoft or one of its wholly owned subsidiaries. Upon review, the RPM team will either verify the trademark information or notify the potential registrant of any deficiencies. If the trademark information and eligibility of the registrants are eventually verified, the domain name registration will resolve. All domains in the .MICROSOFT will be registered to Microsoft or one of its wholly owned subsidiaries for their own exclusive use and Microsoft will appear as the owner in all WHOIS records. Microsoft will grant a non-exclusive, non-transferable, worldwide limited license to registrants to use the domain names for a period of no less than one (1) year and no more than ten (10) years, commencing on the date on which the registration request submitted by the approved registrar.

Microsoft will implement an Eligibility Reconsideration Process which will allow Microsoft to reconsider registrant’s license to use a domain name upon a change in the status of the registrant. Registrants will be able to challenge any decision made by the applicant regarding their eligibility through Eligibility Dispute Resolution procedure. Under Microsoft’s registration policy, prospective registrants will also have to comply with the Acceptable Use policy incorporated into the Sunrise and general registration policies. Microsoft will undertake checks to ensure that the intended use of each .MICROSOFT domain conforms with the Acceptable Use policy. According to the Acceptable Use policy:

• Registrants must use their domains solely for purposes that enhance the strategic or commercial interests of Microsoft.
• Domain names may not be used in a way which knowingly infringe, violate, or misappropriate any third party intellectual property rights.
• A domain name registration must be an acceptable term that will not in any way damage the strategic interests or reputation of Microsoft.
• Registrants may not delegate or assign any rights in domain names to external organizations, institutions, or individuals.
• All .MICROSOFT gTLD domains will be pointed to either Microsoft’s website or the main home page or the home page of the .MICROSOFT gTLD registry.
• If the registrant ceases to be a member of Microsoft or its affiliates to which their domain name is associated, then the registrant must cancel registration of that domain name within 14 days of ceasing to be a member.

Microsoft may reject a registration request, or may delete, revoke, suspend, cancel or transfer a .MICROSOFT domain name at any time without notice: to enforce registry policies and ICANN requirements to protect the integrity and stability of the registry, its operations, and the .MICROSOFT gTLD system; if there is a change in the eligibility status of the Registrant; or if otherwise instructed by Microsoft.

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, Microsoft or the Microsoft-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, Microsoft or the Microsoft-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 Microsoft or the Microsoft-approved registrar will not process the domain name registration.

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

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

In addition to the Sunrise and Trademark Claims services described in Section 1 of this response, Microsoft implements and adheres to RPMs post-launch as mandated by ICANN, and confirms that registrars accredited for this gTLD are in compliance with these mechanisms. Certain aspects of these post-launch RPMs may be administered on behalf of Microsoft by Microsoft-approved registrars or by subcontractors of Microsoft, 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, Microsoft 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 .MICROSOFT 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. Microsoft 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 to the domain name registrant, who has an opportunity to respond. If the complainant is successful, the registry operator is informed and the domain name is suspended for the balance of the registration period; the domain name will not resolve to the original website, but to an informational web page provided by the URS provider. 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, Microsoft and entities operating on its behalf adhere to decisions rendered by the URS providers.
• 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. Microsoft participates in the PDDRP process as specified in the Applicant Guidebook. The Microsoft RPM team will deal with and handle PDDRP complaints. As set out in the Applicant Guidebook in the appendix summarizing the PDDRP, the grounds for a complaint on a second level registration are that , “(a) there is a substantial pattern or practice of specific bad faith intent by the registry operator to profit from the sale of trademark infringing domain names; and (b) the registry operator’s bad faith intent to profit from the systematic registration of domain names within the gTLD that are identical or confusingly similar to the complainant’s mark, which: (i) takes unfair advantage of the distinctive character or the reputation of the complainantʹs mark; or (ii) impairs the distinctive character or the reputation of the complainantʹs mark, or(iii) creates a likelihood of confusion with the complainantʹs mark.”. Whilst we will co-operate with any complaints made under the PDDRP, we think it is highly improbable that any PDDRP complaints will succeed because the grounds set out above cannot be satisfied as domains in the registry will not be for sale and cannot be transferred to third parties.

Additional Measures Specific to Rights Protection.
The .MICROSOFT gTLD will be a closed registry that will be solely owned and controlled by Microsoft for its own commercial and strategic interests. Therefore, it is highly unlikely that third parties will find the opportunity to engage in abusive activities such as phishing, pharming or other types of behavior which violate the rights of others. However, in the unlikely event that the .MICROSOFT domains are attacked by third parties, Microsoft will have the following measures in place to deal swiftly with the abuse:

Abuse Point of Contact: Microsoft will establish and publish a unique abuse point of contact from within the RPM team. This contact will be a role e-mail address such as abuse@registry.microsoft. This role address will allow designated staff to regularly monitor abuse and⁄or malicious activities in .MICROSOFT. The registry’s designated staff will then evaluate complaints and produce abuse reports when necessary. Following the evaluation, they must decide whether the abuse report is a serious matter of concern and take a decision whether to dismiss the report or proceed to the next step. Since any decision regarding abuse reports implies serious consequences, the registry operator will be supported by abuse prevention staff and experts that will accurately and responsibly deal with the abuse report. After the adequate evaluation procedure via the registry operator, Microsoft can determine whether or not to take any action against such alleged abusive or malicious activity. In particular circumstances, Microsoft can allow Verisign to suspend or cancel a domain name on its behalf. Microsoft will also take steps to investigate and respond to any reports from law enforcement, governmental and quasi-governmental agencies of illegal conduct in connection with the use of the TLD.

Rapid Takedown or Suspension Based on Court Orders: Because domain names can be used to engage in malicious and abusive activity on the Internet, including malware, pharming, and phishing, the most efficient measure to combat such activity may, under certain circumstances, be to deactivate the domain. Microsoft will implement a rapid takedown process based on, for example, court orders, appropriate and documented requests from law enforcement, and the results of its own internal threat analyses and assessment. Microsoft 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: Microsoft 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.

Authentication Procedures: Verisign, Microsoft’s selected backend registry services provider, uses two-factor authentication to augment security protocols for telephone, email, and chat communications.

Malware Code Identification: This safeguard reduces opportunities for abusive behaviors that use registered domain names in the gTLD. Registrants are often unknowing victims of malware exploits. As Microsoft’s backend registry services provider, Verisign has developed proprietary code to help identify malware in the zones it manages, which in turn helps registrars by identifying malicious code hidden in their domain names.

Rights Protection Help Desk We will maintain a Rights Protection Help Desk. Enquirers will be allocated a Case Number and the following details will be captured:

The contact details of the complainant
The domain name that is the subject of the complaint or query
The registered right, if any, that is associated with the request
An explanation of the issues such as why the complainant believes that its mark has been infringed
An initial response to a query or complaint will be made within 24 hours. The Rights Protection Help Desk will be in place on Day One of the registry. The cost of the Rights Help Desk is reflected in the Projections Templates provided at Q46 as part of on-going registry maintenance costs.
The aim of the Rights Protection Help Desk is to assist third parties in understanding the mission and purpose of our registry and to see if a resolution can be found that is quicker and easier than the filing of a UDRP or URS complaint.

Registry Legal Expert We will allocate to one or more expert(s) within Microsoft the responsibility of ensuring that we are compliant with ICANN policies. The(se) compliance contact(s) will also handle all disputes relating to RPMs. This will involve evaluating complaints, working with external legal counsel and law enforcement, and resolving disputes. The compliance contact(s) will also liaise with external stakeholders including URS and UDRP panel providers, the TMCH operator, and trademark holders as needed.

Twice Yearly Registrar Accreditation & Audits We will audit the performance of our registrars every six months and re-validate our Registry-registrar Agreements annually. Our audits will include site visits to ensure the security of data etc.

Registrant Pre-Verification All requests for registration will be verified by our registrar to ensure that they come from a legitimate representative of Microsoft or our Affiliates. A record of the request will be kept in our on-line domain management console including the requestor’s email address and other contact information.

3 RESOURCING PLANS
Resource Planning
Microsoft’s RPM team comprises its current domain name manager and an IP specialist.

Resource Planning Specific to Backend Registry Activities
Verisign, Microsoft’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 Microsoft 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.

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

Microsoft’s registrar will also be supporting Microsoft by validating the eligibility of registration requests, assisting with ICANN compliance and acting against abusive registrations. This registrar will be assigning one legal specialist and four operational staff to assist Microsoft with these tasks.

The Microsoft Domain Name Management Team of two will work under the leadership of Microsoft’s Associate General Counsel.

Implementation Plans
Our proposed Sunrise and IP Claims service is currently anticipated to be introduced according to the following timetable:

Day One: Announcement of Registry Launch and publication of registry website with details of the Sunrise and Trademark Claim Service (“TMCS”)
Day 30: Sunrise opens for 30 days on a first-come, first served basis. Once registrations are approved, they will be entered into the SRS and published in our Thick-Whois database.
Day 60-75: Registry Open, domains applied for in the Sunrise registered and TMCS begins for a minimum of 60 days
Day 120-135: TMCS ends; normal operations continue. Our systems to support the implementation of complaints under the UDRP, the URS, and the PDDRP will be available from Day One, as will Thick Whois.

The Implementation Team will create a formal Registry Launch plan by 1 November 2012. This will set out the exact process for the launch of the .MICROSOFT registry and will define responsibilities and budgets. The Microsoft Registry website, which is budgeted for in the three year plans provided in our answers to question 46 will be built by 1 February 2013 (or within 30 days of pre-delegation testing starting, whichever is the soonest). It will feature Rules of Registration, Rules of Eligibility, Terms & Conditions of Registration, Acceptable Use Policies as well as the Rules of the Sunrise, the Rules of the Sunrise Dispute Resolution Policy and the Rules of the Trademark Claims Service.

The registry website will promote the contact details of our Abuse Point of Contact which will be available 24⁄7.

We will comply with all requests from courts, law enforcement, and governmental bodies, and any decisions⁄judgments from UDRP and URS panels.

Technical implementation between the registry and the Trademark Clearinghouse will be undertaken by our registry service provider as soon as practical after the Trademark Clearinghouse is operational and announces its integration process.
As demonstrated in our financial answers, a budget has been set aside to pay fees charged by the Trademark Clearinghouse Operator for this integration.

The contract we have with our registrar (the RAA) will require that the registrar adheres to the Terms & Conditions of the TMCH and will prohibit the registrar from filing domains in our registry on its own behalf or utilizing any data from the TMCH except in the provision of its duties as our registrar.

When processing TMCS claims, our registrar will be required to use the specific form of notice provided by ICANN in the Applicant Guidebook’.

We will also require our registrar to implement appropriate privacy policies reflecting the location of our registry in the United States and the high standards that we set. See http:⁄⁄privacy.microsoft.com⁄en-us⁄default.mspx.

1 DETAILED DESCRIPTION OF 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

Microsoft Corporation (“Microsoft”)’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 .MICROSOFT 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.

1.1 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, Microsoft, 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.

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

Verisign, Microsoft’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 .MICROSOFT 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 Microsoft 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.

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

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

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

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

5 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 .MICROSOFT gTLD. As defined in Section 1 of this response, Verisign, Microsoft’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 (CA)

As defined in Section 1 of this response, Verisign, Microsoft’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 (CA)

Charles H. Noski	Director
David F. Marquardt	Director
Dina Dublon	Director
Helmut G. W. Panke	Director
John W. Thompson	Director
Maria M. Klawe	Director
Raymond V. Gilmartin	Director
Steven A. Ballmer	Chief Executive Officer
W. Reed Hastings	Director
William H. Gates III	Chairman

B. Kevin Turner	Chief Operating Officer
Bradford L. Smith	Senior Vice President, General Counsel and Secretary
Craig J. Mundie	Chief Research and Strategy Officer
Kurt D. DelBene	President, Microsoft Office Division
Lisa E. Brummel	Senior Vice President, Human Resources
Peter S. Klein	Chief Financial Officer
Satya Nadella	President, Server & Tools
Steven A. Ballmer	Chief Executive Officer
Steven J. Sinofsky	President, Windows & Windows Live Division

New gTLD Application Submitted to ICANN by: Microsoft Corporation

String: MICROSOFT

Originally Posted: 13 June 2012

Application ID: 1-1129-74317

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

© Internet Corporation For Assigned Names and Numbers.