ICANN New gTLD Application

Table of Contents

1 - Describe the mission⁄purpose of your proposed gTLD

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1 - Describe the mission⁄purpose of your proposed gTLD

The mission of the proposed gTLD is to serve the Breton community, to represent, characterize and display all of its cultural, economic and social productions on the

internet. The Breton community is defined by all the people who feel attached to Brittany, its culture and its languages and who wish to display this attachment by

using a domain name.

Brittany is a western region of France with a specific culture and history, including two local languages (Breton and Gallo), and a strong identity. The members of the

community are, first and foremost, the inhabitants of the cultural and linguistic Breton area (4,441,000 people in 2009) and its diaspora (between 4 and 6 million

people), established across the globe, and in particular in France.

The Breton language (brezhoneg in Breton) is one of the six Celtic languages still spoken in Europe alongside Welsh and Cornish, with which it forms the Brittonic

branch of Celtic languages, and Scottish Gaelic, Irish and Manx. Today it is the Celtic language with the third largest number of speakers.
It is recognized as a regional and minority language in France, one of the languages of the Brittany area as well as the Gallo and the French. It is deemed severely

endangered by the UNESCO. A cultural language, the Breton has an extensive written literature. Its revival essentially occurred in the 1970s, when the population

showed a renewed interest. It started being taught at that time, with the creation of the Diwan associative schools in 1977, then the network of bilingual schools in

the national educational system and private schools around the parents’ associations Div Yezh (two languages) and Dihun (awakening). The Breton language also gained in

visibility by appearing in public life (bilingual signs, communication…), leading to the creation of the Office for the Breton Language in 1999, a public institution

for cultural cooperation since 2010. The Breton is practiced in the west of Brittany as well as in the large Breton cities (Nantes, Rennes…). Today, according to

sources, since no official census has been made, the total number of Breton speakers could be 500,000 (including occasional speakers and those who understand without

speaking). The number of active speakers is estimated to be close to 200,000.

The Gallo is part of the langues d’oil languages - as is French -, a group that includes for instance the Picard, the Norman and the Walloon. In 2004, the Regional

Council of Brittany has recognized the Breton and the Gallo as ‘languages of Brittany alongside the French language’. It is also recognized by governmental

institutions (1998, 1999, 2001), such as the Department of the French language and languages of France, in charge of linguistic policy. The Gallo is spoken in Upper

Brittany in the East. It is very difficult to determine the number of regular speakers. The National Institute for Statistics (INSEE, 1999) estimated this figure at

28,300, whereas other studies evaluated the number at 200,000 (including passive speakers). The Gallo is very close to other roman dialects such as Mayennais or

Angevin.

Brittany offers a rich and original cultural production (1st French region for the number of festivals, for its associative system, 2nd region for the production of

music records), while a significant part of its economy relies on a strong regional and cultural identity. Brittany is the second French region in Information

Technologies: it hosts 35% of French public research, 44,000 jobs are in this sector within 650 dedicated companies and 65 laboratories from 4 universities and higher

education establishments (more than 3,500 high level researchers). Brittany ranks second for telecommunication engineering degrees and third for electronics, IT and

communication degrees.

Brittany is widely referenced on the internet both directly (144,000,000 search results for Bretagne, 134,000,000 for Brittany) and through domain names: 14,000 names

are directly related to Brittany in the main registries (com, net, org, info and biz) with community keywords (Bretagne, Breton, breizh, bzh).

The purpose of the proposed gTLD is to provide the community of Brittany with a specific Internet tool that will better reflect the specificity of its cultural,

linguistic, economic and social activities and thus to :
* Serve the needs and interests of the Breton community and promote its culture, its languages and its economy by highlighting its products and productions
* Provide the online recognition expected by the community just as it benefits from this recognition offline
* Develop Information Technologies in Brittany while reinforcing the local innovation ecosystem, increase the value of the know-how and regional capacities in IT
* Work against the digital divide that separates high tech savvy users from the others.

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1 - Introduction

The goal of the .BZH registry to develop a close relationship with the Breton community, mainly based in Brittany, by developing the use of domain names and related
websites. This will happen through close collaboration with local private and public players in order to promote uses and provide services related to the new registry
(creation of websites, web hosting…).

The level of service aims both to meet international standards and to build a close relationship with the final user who favors the development of a regional, cultural
and linguistic registry. Indeed, the level of service aimed at is that of an international registry: the technical service to registrars will be provided by the AFNIC,
registry in charge of the .fr geographical domain and therefore fully able to guarantee, through its proven track record, the level of service expected by
international operators. The close relationship with the community will be managed with the help of networks supporting the gTLD project, informative meetings in the
whole cultural and linguistic area and by the installation of the registry in Quimper, one of the most vibrant Breton cities in terms of language and culture.

A particular effort will be made to improve the quality of the gTLD in terms of technology and innovation in relation with the IT players in the area. The example of
the Catalan .CAT registry shows how innovative services (IDN, DNSSEC) can be developed in a niche market. This approach has resulted in an 80% annual renewal rate for
.cat names, i.e. 10 % more than the average rate.

Since the proposed gTLD directly addresses the community attached to Brittany, in particular in cultural and economic areas, its reputation is extremely important.

This reputation will be guaranteed by compliance with a fair use that will assure that uses are harmless to the image of the community and the consistency of the gTLD.
The registry will be extremely mindful of the implementation of standards and best practices in terms of trademark protection and users security, including personal
data protection. These topics will be developed in questions 28 and 29.

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

There is currently only one gTLD related to a pre-existing cultural and linguistic community, the Catalan .CAT. The .bzh gTLD addresses a specific need by allowing
individuals, associations, businesses, etc., to display their attachment to Brittany, its culture and its languages.

The success of the online petition (more than 20,000 signatories) published on the candidate’s website (http:⁄⁄www.pointbzh.com) testifies to this potential demand
that will complement the current offer of gTLDs. In collaboration with the public and private players involved in the development of digital uses (Regional Council of
Brittany, Images et Réseaux cluster,...), the promotion of this grassroots registry and the information released in the field will reach new audiences, less accustomed
to IT but willing to display a particular identity online, thus expanding the global market for domain names. This principle is a reality for .cat: a third of
registrants for the .cat registry did not previously own a domain name. The gTLD will therefore stimulate competition by allowing targeted segmentation and
communication.

The concept of differentiation is directly applicable to the project since the gTLD is designed to reflect the existence of a particular cultural and linguistic
identity, to reflect the diversity and expand the choices of registrants and users. It will allow particular contents to be marked and enable communication through
affinities with people related to or interested in the Breton community.

The gTLD will therefore be a tool for the promotion of the territory for players who wish to gear their communication towards audiences related to the Breton
community. The gTLD can thus be used by existing networks that encourage local production and identity such as or Produit en Bretagne the Marque Bretagne.

One of the goals of the proposed gTLD being to highlight the know-how and abilities of Brittany in IT, the registry will rely on the resources of the Breton community
to invent or support the implementation of new services (portals, commercial offers, etc.) in areas where the Breton identity matters. It will also highlight local
innovations through dedicated websites.

Brittany indeed relies on a widely recognized know-how in IT, with the creation of or contribution to technologies and standards such as JPG2, MP3 or ATM (Asynchronous
Transfer Mode). It is also in Brittany that the HD Wireless was produced and broadcast in 2006.

The wealth of networks and the extent of Breton Research & Development will also benefit projects related to the future gTLD. Today, 35 % of the French public research
is located in Brittany and 44,000 jobs are related to this sector. The world-class Images & Networks competitiveness cluster brings together more than 220 regional
players in industry and research, who work on new digital image technologies and new networks for content distribution.

The gTLD will also be keen to develop innovative services for users of cultural and linguistic registries in relation with the gTLDs of the ECLID network.

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3 - What goals does your proposed gTLD have in terms of user experience?

Many benefits are expected from the .bzh gTLD :
* Improved online representation. Thanks to the registry, Internet will better reflect offline reality. The gTLD will better represent the community of Brittany on
the internet, notably by helping to display online its cultural and linguistic vitality. Indeed, Brittany is the second French region for its listed heritage or for
music record production. It is the first region for the number of festivals, for its associative system or for the reading of daily newspapers. Part of its internet
contents are displayed in one of its two regional languages, Breton or Gallo (for instance the Breton language is the 51st language used on Wikipedia and the first
Celtic language).

* An answer to the community’s expectations. The number and variety of the support received are indicators of high expectations from the community for the creation of
this new gTLD. Users of the Breton community can currently choose only between geographic or generic TLDs that do not reflect their Breton identity. However, in
addition to its linguistic and cultural expression, this identity appears to be fundamental in various aspects of the community’s life

* From an economic standpoint : the tourism sector is very large (about 10% of regional GDP) and relies to a great extent on the heritage and cultural identity of
Brittany. The food & agricultural sector (close to 40 % of the regional industry) also heavily relies on the Breton image and culture for marketing purposes.

* From a social standpoint : a sizeable and ancient Breton diaspora has been identified (estimated between 4 and 6 million people), partly due to poverty-related
emigration, partly to the maritime character of Brittany. Close to a million Bretons live in Paris and its surroundings. There is also dozens of thousands of them in
the French largest harbor cities as well as in the European Union, Canada or the United States. The members of the diaspora have expressed the wish to keep strong
cultural and identity ties with Brittany and regularly arrange events (music, dance…).

The proximity of the registry to its community (involvement of the community in management, meetings, awareness of requests from the Breton community…) will ensure it
addresses existing expectations :
* Highlighting of the websites related to the Breton community. The gTLD aims to federate websites related to Brittany, its culture, its languages, and to structure
the Breton internet community. The .bzh gTLD will provide additional information, helping the user to immediately understand the purpose of a website and the targeted
affinity audience. The registrants will therefore benefit from a specific marker to better label their products and contents, just like they do offline with symbols
representative of the Breton identity (flag, Celtic symbols…). Access to contents, especially linked to culture and language, will become more user-friendly.

* Adequate naming. While the registrants today display their identity by using various words in their domain names (Breton, breizh, Bretagne, bzh), with the new gTLD
they will be able to offer added value through adequate and available naming.

* A trusted interaction-friendly area. The use of an identity symbol, in the case .bzh, will de facto establish preferential communication and trust between the
registrant and the user in terms of significance and values shared by a single community. This trust will be reinforced by the regulations implemented by the registry,
which will guarantee compliance with registration rules, prior intellectual property rights and compliance with a fair use by the registrants (fight against
typosquatting, parking sites…).

* Development of uses. Further development of uses and practices is expected through the creation of a community gTLD, that will encourage first-time name ownership
through attachment to the community, and then subsequently develop into wider on-line practices. The link between the creation of a gTLD and the development of uses
has been demonstrated by the .cat registry whereby a third of registrants did not previously own a domain name.

* The image of an innovative regional territory. By highlighting Brittany on the internet, the gTLD will reinforce its image of an innovative territory, already
related to the strong presence of IT players and the programs implemented by public institutions (ultra high speed internet, public access points, open data,…).

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4 - Provide a complete description of the applicant’s intended registration policies in support of the goals listed above

The registration policies have been prepared based on the track record of existing TLDs operation and launches so as to facilitate registrant’s activities, guarantee
fair treatment, take prior rights into account, limit costs and manage the procedures.

Registration will take place in several phases, so as to progressively build up momentum for registration and manage the collective learning curve of the community.

= Phase 1 =

First of all a pre-launch phase will be implemented, upstream of the next steps. Pioneer names will be launched in relation with representative partners in the
community (public institutions, cultural organizations, companies…), carefully selected for the value they add to the gTLD.

Meanwhile an open call for projects will be launched on generic terms, with priority given to the value added for the community by the services proposed by the
candidates.

These registrants will be involved far upstream so that their communication on a .bzh website is planned in advance and the website activated as soon as the launch
phase of the registry starts.

This pre-launch phase will be limited to a few dozen domain names. The registrants will thus benefit from the scarcity of the names and maximum exposure to the
community during the sunrise ⁄ landrush phase, with temporary exclusivity on .bzh websites. In return, the registry will benefit from communication efforts from the

registrants, arousing public interest for the next phase, open to all community members :
* The first flagships will show the many possible uses of .bzh
* The impact of this communication will be strong since the pre-launch phase will coordinate the communication strategies of the registry and the registrants

= Phase 2 =

The sunrise and landrush phases will take place simultaneously during a 3-month period.

The first-come, first-served method will therefore not be the only rule for name allocation.

The sunrise phase will take prior rights into account. A priority order will be given in case of multiple requests, taking into account the interests of the community:
* Institutions that are representative of the linguistic and cultural community
* Public institutions
* Cultural and linguistic associations
* Prior rights related to intellectual property
* Trademarks with legal value in Brittany
* Other registred distinctive signs with legal value in Brittany
* Individual members of the cultural and linguistic community (booking of family name) and members of the association www.bzh.

These registrants will be allowed to apply for domain names directly related to their prior rights.

The application procedure will be automated to ensure a secure and transparent procedure. A WHOIS will be set up during the sunrise phase to allow participants to keep
track of applications and enforce their prior rights in the event.

Each application will be individually validated against both the general requirements of .BZH registration policies and the specific requirements of each Category or
Sub-Category. Priority will be differentiated by Category (and Sub-category) each one having absolute priority over the next one.
Within each Category (and Sub-category) all validated applications will be deemed to carry the same rights.

Priorities should solve most of multiple applications. In case priorities cannot provide a resolution, the following procedures will be applied (in that order):
agreement between registrants, random selection, mediation, arbitration, auction.

An agreement between registrants means that one registrant will keep the domain name while the other or others will withdraw their application (and get a refund
accordingly).

Random selection is optional : the contenders must unanimously accept to use the procedure.

In case of disagreement, mediation then arbitration would then be implemented at the expense of registrants. The registry will charge any cost borne by the procedure.
Mediation will be directly handled by the Registry. Arbitration will be carried out by an independent and experienced Mediation and Arbitration Authority. In that
case, no application for the same name from the same or lower rank in Sunrise priority will be approved, pending the decision.

An auction will be made if all others means of resolution have failed.

The landrush phase will be running in parallel during the Sunrise and will be open to all eligible applicants (see question 20) for domain names not subject to prior
rights, on a first-come, first-served basis. The domain names registered during this period will be activated at the end of the 3-month phase.

= Phase 3 =

The subsequent phase will be general availability. The domain names will be sold to eligible applicants (see question 20) on a first-come, first-served basis with
immediate activation. The price will be adjusted to ensure adequate operation of the registry while allowing the largest number of community members to register a
domain name.

Advertising and communication campaigns will be implemented before each phase so that community members fully understand the changes made, with clear rules and
detailed process explanations.

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5 - Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users? If so, please describe any such
measures

The gTLD will thoroughly enforce measures to protect registrants and users privacy and confidential information, a key aspect of its reputation. All available
technologies will be used to ensure this, in compliance with European and French regulations. Anti data-mining procedures may include rate limitation, authenticated
access, black ⁄ white listing, prevention of unauthorized repetitive access. Such procedures will be detailed in question 28.

Describe whether and in what ways outreach and communications will help to achieve your projected benefits.
The registry will intially rely on the communication work already carried out to promote the new gTLD: awareness of the .bzh project has been recognized for several
years and the project is clearly identified by the community and the media, both regional and national, that broadcast news about the project.

The idea of a .bzh gTLD was launched in 2004 by a member of the French parliament Christian Ménard. An online petition, initiated by Mikael Bodlore-Penlaez, has
rallied internet users for the first time in 2006. Several Breton communities in 2006 expressed unanimous votes in favor of the project, giving the project
institutional visibility: General Council of Ille-et-Vilaine, Regional Council of Brittany,, General Council of Finistère, General Council of Loire Atlantique.

The project was then structured in 2008 around an association, www.bzh, bringing together the various players involved in the .bzh project, previously involved in a
study commissionned by the Regional Council of Brittany to the think tank Bretagne Prospective. The purpose of the association www.bzh is to prepare the application,
collect the funds required for it to be filed and ensure the promotion of the .bzh project within the Breton community. It will subsequently manage the gTLD.

Within the bounds of this mission, the association www.bzh has developed actions of communication and promotion actions on the gTLD geared towards the Breton community
(website, social networks, meetings…) but also the ICANN, notably within the ECLID network (European Cultural and Linguistic Internet Domains), which brings together
various associations managing similar projects in Europe.

This communication work has resulted in many public events organized or joined by the association, constant online animation (website, Facebook and Twitter accounts…),
numerous mentions in national or regional media… All these efforts have raised the community’s awareness of the project. Evidence of genuine popular support, the
petition to support the gTLD on the association’s website (http:⁄⁄www.pointbzh.com) has collected more than 20,000 signatures to date.

Likewise, the effort made from the start to inform the Breton community representatives has resulted in formal support for the gTLD application (see question 20) and
financial support (Regional Council of Brittany, General Council of Loire-Atlantique, Quimper Community, French Government,..).

To further these actions, the gTLD will rely on the many networks that structure the Breton community, which are already mobilized for the application : cultural and
linguistic networks, political networks, business networks, media, higher education establishments (see question 20f for further information).

This involvement, in addition to creating valuable communication channels in their various domains, will build interdependence of the community members around the .bzh project, which will reinforce consistency and good use of the registry.

Communication actions toward the community are planned during the various phases of commercial development of the gTLD and can be amplified by the associated networks that structure the Breton community :
* Pre-launch with pioneer names representative of the community and calls for projects to propose innovative services to the Breton community
* Sunrise phase to highlight the institutions representative of the cultural and linguistic community
* General availability, intended to allow the largest number of community members to register while guaranteeing sound development of the registry

Table of Contents

1 - What operating rules will you adopt to eliminate or minimize social costs (e.g., time or financial resource costs, as well as various types of consumer

vulnerabilities)? What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?
1.1 - How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first serve basis?
1.2 - Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).
1.3 - Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years

at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases. Do you

intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.

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1 - What operating rules will you adopt to eliminate or minimize social costs (e.g., time or financial resource costs, as well as various types of consumer

vulnerabilities)? What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?

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1.1 - How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first serve basis?

The first-come, first-served principle will not be applied during the phases of pre-launch or launch phases. Any possible dispute will be resolved by an agreement

between registrants involved during the pre-launch phase.

During the sunrise phase, the priorities defined should solve most of multiple applications. Where priorities cannot provide a resolution, the following procedures

will be applied (in this order): agreement between registrants, random selection, mediation, arbitration, auction.

An agreement between registrants means that one registrant will keep the domain name while the other or others will withdraw their application (and get a refund

accordingly).

Random selection is optional: the contenders must unanimously accept to use the procedure.

In case of disagreement, mediation then arbitrage would then be implemented at the expense of registrants. The registry will charge any cost borne by the procedure. In

the event, arbitrage will be carried out by an experienced third party.

An auction will be made if all others means of resolution have failed.

During the landrush phase subject to third parties rights and during the general availability phase, domain names will be sold on a first-come, first-served basis.

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1.2 - Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).

The goal of the proposed gTLD being to serve the Breton community, the objective of minimizing costs is a priority for the non-profit association that applies for the

gTLD. While ensuring high quality operation of the gTLD, transaction costs (i.e. social costs) will be kept as low as possible to allow optimum accessibility for

community members wishing to register a domain name.

The registry will carry out a posteriori checks on registrations. Procedures to ensure compliance will include thorough processing of complaints and random or semi-

random checks. Cases will be processed expediently and given publicity so as to deter abuse or unwanted behavior. The purpose of these checks is to curb bad behavior

cases that generate costs for the users.

The registry aims to implement a decreasing sales price policy so as to share part of the gTLD’s success with the consumer.

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1.3 - Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years

at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases. Do you

intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.

The proposed gTLD will allow registration from 1 to 10 years so as to comply with the Registry Agreement.

The Dot BZH business plan is designed to prevent any future necessity to increase registry price in real terms. The fundamental principle is caution: starting from

conservative price levels and gradually lowering them. This method ensures sufficient financial reserves, favors optimal allocation of domain names, helps prevent

misuse and supports an orderly registration process.

= Provide the name and full description of the community that the applicant is committing to serve. =

The proposed gTLD .bzh refers to the Breton community defined as all the people who feel attached to Brittany, its culture and its languages and who wish to display this attachment by using a specific domain name.
Indeed, the BZH string refers primarily to a geographical area, Brittany, its culture and its languages since BZH derives from the Breton word Breizh which means Brittany.
All those present in this reference territory are legitimate members of the community, for instance individuals with a residence in Brittany, organization with either its headquarters or an office in Brittany.
The abbreviation BZH is also a marker of a cultural and linguistic identity. People who refer to this culture (based on UNESCO’s definition: ʹculture should be regarded as the set of distinctive spiritual, material, intellectual and emotional features of society or a social group, and it encompasses, in addition to art and literature, lifestyles, ways of living together, value systems, traditions and beliefs’) or to the languages of Brittany (Breton, Gallo) are members of the community.

Attachment to Brittany, its culture and its languages (i.e. community membership) can then result from
* A geographical residence (physical address, headquarters or office) in Brittany
* Any expression or reference to the Breton culture according to UNESCO culture’s definition
* Any practice of or reference to the languages of Brittany

Furthermore, registration implies compliance with a fair use that only allows a use harmless to the image of Brittany and the community. Non-compliance will result in suspension or termination of the domain name.
This fair use will be based among other things on notions such as legitimate interest and bona fide for registration (and renewal) of domain names, that the registrant must be able to justify in case of a challenge related to the domain name use.

= How the community is delineated from Internet users generally. =

The Breton community refers to a specific territory, culture and languages (A) that are reflected in particular on the internet (B).

A) The Breton community refers to the territory of Brittany which is historically spread over five French ‘départements’: Côtes d’Armor, Finistère, Loire-Atlantique, Morbihan and Ille-et-Vilaine.

The Breton community has a strong and specific cultural and linguistic identity.
The Breton language (brezhoneg in Breton) is one of the six Celtic languages still spoken in Europe. It is the Celtic language with the third largest number of speakers. The number of active speakers is estimated to be close to 200,000 in Brittany and close to 16,000 in Paris region. The total number of Breton speakers, including occasional speakers and those who understand without speaking, could be around 500,000.
Gallo, the second language of Brittany, is part of the langues d’oil languages - as is French. The French National Institute for Statistics estimated this figure the number of regular speakers at 28,300, whereas other studies (UNESCO) evaluated the number at 200,000.

Brittany develops also a rich and original culture in terms of :
* music. Brittany is the 1st French region for the number of festivals, 2nd region for the production of music records. There is a lively practice of traditional music with bands known as bagadoù and traditional song (kan ha diskan, gwerz, …).
* dance. Traditional fetes called ʺFest-nozʺ involving various folk dances in line or pairs. Amateur dancing in Brittany is structured through confederations (13,000 members of 160 Celtic dance circles).
* architectural heritage. With over 2900 protected monuments, Brittany classes as the French region with the second richest architectural heritage.
* gastronomy. The traditional pancakes ʺcrêpesʺ and ʺgalettesʺ or pastries such as the ‘far Breton’, the ‘kouign amann’ (butter pastry) are part of Brittany’s culinary heritage.

B) The importance of this attachment to Brittany, its culture and its language is reflected in the media, particularly on the Internet. Breton diaspora was largely organized on the web through websites and social networks. Events (Cyber Fest Noz) are held around the world to gather the Breton community online.
Members of the community using internet refer to Brittany in different ways on their website either using terms referring to Brittany in the domain name, using Breton or gallo, using images (landscapes, architecture,...) or specific symbols (Breton flag, ermine ...).
Second largest region in France in IT, Brittany aims to create a gTLD which reflects its culture, its identity and its relationship with the internet.

= How the community is structured and organized. =

The Breton community is defined as all the people who feel attached to Brittany, its culture and its languages and wish to display this attachment by using a domain name.
Britanny area i.e. the Breton language and culture area extends over the region of Brittany and the ‘département’ of Loire Atlantique. These communities are run by elected councils which are related to all the Breton community networks, including Bretons established across the globe.
Breton culture is notably represented by the Cultural Council of Brittany. It is made of representatives of associations and institutions, as well as people working for Breton culture. The Council is in support of suggestions and advice on public cultural policies in Brittany.
The Breton language is notably represented by the Public Office of the Breton language (Ofis Publik ar Brezhoneg). Its general task is to ensure the advancement of the Breton language in public life.
All of those institutions support the .BZH project (see question 20 f).

= When the community was established. =

The Breton community refers first to Brittany which is a territory known since antiquity and politically organized since the Middle-Ages in kingdom (9th century), duchy (10th century) and province (1532). Since the creation of French administrative regions in the 20th century, Brittany extends over the administrative French region of Brittany (80% of historical Brittany) and the ‘département’ of Loire-Atlantique.
Breton community is considering a .BZH gTLD for several years. The idea was launched in 2004 by French deputy Christian Ménard. The project was structured in 2008 around an association, www.bzh, merging all people involved in the .bzh project. This association has developed actions of communication and promotion on the gTLD geared towards the Breton community. All these efforts have raised the community’s awareness of the project. Evidence of genuine popular support, the petition to support online the gTLD has collected more than 20,000 signatures to date.

= The current estimated size of the community. =

The community is comprised of:
* Individuals and organizations located in Brittany, a western region of France (13,136 sq. miles) : the cultural and linguistic area hosts 4,481,000 inhabitants and more than 213,000 companies.
* Individuals and organizations around the world that wish to display their attachment to Brittany, its culture and languages. Figures are high and include in addition to the residents and the 500,000 speakers of the Breton languages:
* The diaspora, i.e. people of Breton descent around the world, estimated at between 4 and 6 million people.
* Tourists. Regular stays in Brittany are also a sign of attachment: Brittany is the 4th French region for tourism (97 million nights a year).

Table of contents

1 - Eligibility
2 - Name selection
3 - Content⁄Use

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1 - Eligibility

= Who is eligible to register a second-level name in the gTLD, and how will eligibility be determined. =

Only the community members will be eligible to register a second-level domain name in the applied-for gTLD. Eligibility will be based on two cumulative criteria:
* Membership of the community
* Compliance with a fair use.

= 1st condition =

The .BZH community brings together individuals and organizations that wish to display their attachment to Brittany, its languages and its culture.

The community is made up of individuals and organizations that can justify membership by
* A geographic place of residence, headquarters or office in Brittany (Côtes d’Armor, Ille-et-Vilaine, Finistère, Morbihan, Loire-Atlantique)
OR
* A significant and original content of the website devoted to Brittany and the Breton culture
OR
* A significant and original part of the website in Breton or Gallo
OR
* Membership of the association www.bzh that gathers representatives of the linguistic and cultural community.

= 2nd condition =

This fair use will suppose among other things on notions such as legitimate interest and bona fide for registration of domain names, that the registrant must be able to justify in case of a challenge related to the domain name use.

In particular, it is thus forbidden to
* Obtain or request registration of a name mainly in order to sell it, rent it or transfer it in any way whatsoever to the owner of a same or similar name upon which a right is established, instead of actually use it
* Obtain or request registration of a name mainly in order to harm the reputation of the owner of a legitimate interest or established right on this name or a related name, or to a product or service assimilated with this name by consumers
* Obtain or request registration of a name mainly in order to take advantage of the fame of the owner of a legitimate interest or established right on this name or a related name, or of a product or service assimilated with this name by consumers

These conditions must always be fulfilled.

During the launch phase (Sunrise and Landrush), registrants will have to:
* Provide a mail address in the Breton cultural and linguistic area (Côtes dʹArmor, Finistère, Morbihan, Ille-et-Vilaine, Loire-Atlantique). The contact data of the administrative contact person declared will be automatically verified (in particular through the zip code) in a first step, and by the registry staff in a second step. The administrative contact person declared must fulfill the conditions and can be a registrar.
OR
* Propose an original and significant cultural website content. Registrants are invited to state the use of the registered domain name. This condition must be fulfilled at the latest 6 months after registration of the domain name. The registration staff will complete a prior check about the stated content and a systematic subsequent check after that period. A false statement is against the bona fide condition required for the domain name use and can lead to a suspension.
OR
* Propose an original and significant linguistic website content. Registrants are invited to state the use of the registered domain name. This condition must be fulfilled at the latest 6 months after registration of the domain name. The registration staff will complete a prior check about the stated content and a systematic subsequent check after that period. A false statement is against the bona fide condition required for the domain name use and can lead to a suspension.
OR
* Belong to the association www.bzh. The registry staff will check the membership of the domain name registrant and deliver a specific authorization code.

After the launch phase (general availability), registration rules will remain the same, automatic checks will be pursued and a random manual check of 50 sites per week will be completed subsequently. These checks will be complemented by follow-ups on complaints made by internet users.

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2 - Name selection

= What types of second-level names may be registered in the gTLD =

Names registered during the phase of pioneer names will be subject to particular attention in order to protect the reputation of the community.

A list of words with particular importance or significance will be established. These words will require prior agreement.

Registered domain names should not inherently harm the image of Brittany and the community. Non-compliance will lead to suspension or termination of the domain name.

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3 - Content⁄Use

= What restrictions, if any, the registry operator will impose on how a registrant may use its registered name =

Registrants must continuously comply with eligibility criteria. Registration implies compliance with .BZH registration rules that only allows a use harmless to the image of Brittany and the community. Non-compliance will result in suspension or termination of the domain name.

This fair use will suppose among other things on notions such as legitimate interest and bona fide for registration (and renewal) of domain names, that the registrant must be able to justify in case of a challenge related to the domain name use.

Compliance with these good practices is assessed by the registry staff within the permanent checks program.

Given that the proposed gTLD is directly dealing with the community attached to Brittany, in particular in the cultural and economic areas, its reputation is extremely important. This reputation will be guaranteed by the enforcement of adapted eligibility criteria that allows a use that does not harm the image of the Breton community and the consistency of the gTLD. The applicant will thoroughly work to prevent any misuse or malicious behavior.

The program is based on random checks and follow-up of complaints made by Internet users.

Possible complaints will be processed by the registry staff, in particular the person in charge of legal issues, supported by members of the board and members of the association if needed.

Inquiry practices will be proportionate to violations as defined by registration rules.

Other violations of public record (such as UDRP or URS cases) will also be taken into account.

An existing registration will be suspended if:
* The use of the domain name has been diverted. The registrant does not comply in good faith with the registration rules defined beforehand
* The content of the website is no longer compliant with the registration rules.

If the use of the domain name is inappropriate or deemed harmful to the image of Brittany and the community, the registration is turned down.

A registrar that would repeatedly condone violations to the .BZH registrations rules through carelessness or would not submit to checks implemented by the registry could be penalized for the registration of new domain names and in parallel domain names registered through its services will be submitted to more stringent checks.

An appeal process is available for all administrative measures taken within the framework of the enforcement program. The first level of the appeal process will be directly handled by the registry. The second and last level will be dealt with by an independent and experienced Mediation and Arbitration Authority.

Table of Contents

1 - Rules applicable to the protection of geographic names at the second and other levels in the applied-for gTLD
2 - Technical implementation of the protection of geographic names
2.1 - Technical protection of terms
2.2 - Unblocking a reserved term through an authorization code mechanism

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1 - Rules applicable to the protection of geographic names at the second and other levels in the applied-for gTLD :

In accordance with GAC advice on geographic names at the second level, the registry operator will put the following names on the reserved list :

* The short form (in English) of all country and territory names contained on the ISO 3166-1 list, including the European Union, which is exceptionally reserved on the ISO 3166-1 List, and its scope extended in August 1999 to any application needing to represent the name European Union :
See attached document Q22_ISO - Maintenance Agency for ISO 3166 country codes - ISO 3166-1 decoding table.pdf

* The United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardization of Geographical Names, Part III Names of Countries of the World. This lists the names of 193 independent States generally recognized by the international community in the language or languages used in an official capacity within each country and is current as of August 2006 :
See attached document Q22_UNGEGN tech ref manual_m87_combined.pdf

* List of UN member states in 6 official UN languages prepared by the Working Group on Country Names of the United Nations Conference on the standardization of Geographical Names :
See attached document Q22_9th_UNCSGN_e-conf-98-89-add1.pdf

However, the registry operator recognises that there may be cases where a request to register and use a geographic name at the second level should be considered valid :

* The Association www.bzh itself may wish to register a “geographic-name.bzh” domain for its own use as part of an official event organised by the Breton community and referencing the geographic region in said domain name. For example, Brittany is often host to celebrations of the culture and language of another country.

* Cultural centers located in Brittany may wish to highlight their links to the geographic region they represent (e.g.: the Chinese cultural center in Rennes, Brittany).

* The geographic regionʹs public authority wishes to register the domain name for its own use.

In all cases, whether it is the registry operator wishing to register a geographical name for official or public service use, or whether it is an individual applicant, the Association www.bzh is committed to obtaining the approval of the relevant authority.

For registration requests from the relevant public authority, the registry operator will put in place the procedure agreed between the GAC and Afilias for the Dot INFO gTLD as referenced in the letter written by Mohamed Sharil Tarmizi, GAC Chair, on Sept 9, 2003.

For any other request to register a geographic name, the applicant will need to provide registry operator with proof of non-objection or support from the relevant public authority. Once this has been submitted and verified, requests of this kind will be handled on a case-by-case basis only by registry operator.

Registry operator does plan to monitor use of geographic names below the second level (i.e. subdomain used by a .BZH domain name registrant), as the procedures that would be needed to monitor this are considered too complex and expensive. Traditional dispute resolution procedures or legal procedures exist to address such cases.

During the sunrise phase, priority will be given to institutions that are representative of the linguistic and cultural community i.e. Public institutions and Cultural and linguistic associations.
Municipalities of the 5 “départements” composing the territory of Brittany will then be allowed to register their names as domain names (See attachement Q22_BZH - Liste EPCI Bretagne B5 and Q22_BZH-Liste communes Bretagne B5).

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2 - Technical implementation of the protection of geographic names

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2.1 - Technical protection of terms

The registry uses its own reserved terms database. The purpose of this database, in addition to protect the defined set of terms, is to allow actions (creations, updates, deletions), user rights (consult or edit) and traceability (history of actions) for each terms it contains.

During the registration of a domain name, the checker placed on the Shared Registry System (SRS) uses two types of checks on the requested terms. The first type of checks is based on syntax, the second one, is based on semantics. The reserved terms database is part of the second type of tests, based on semantics.

The reserved terms database is used in the Shared Registry System (SRS) during its semantics checks only if the domain name request has successfully passed the syntax checks.

The database table allows to classify the terms is contains by categories. The categories allow the registry to identify different types of terms (geographic names, religious terms, cultural...). In the case of geographic names the categories in the database allow subclassifications such as country names or city names.

The checker placed on the SRS applies the semantics checks to a domain name request using the registry’s policies translated into technical rules. The SRS checker uses the reserved terms database to verify the presence or not of the term in its table and acts accordingly. If the term and its category are present in the database the SRS checker will apply the registry’s policy of blocking the registration unless a valid authorization code is presented.

E.g : If “france” is requested by a registrar for registration without a valid authorization code the SRS checker will verify if the term and its category are present in the reserved terms database. The database will indicate that “france” is present in its tables under the “country” category. The SRS checker will then reject the creation request.

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2.2 - Unblocking a reserved term through an authorization code mechanism

In order to create a domain name containing a reserved term for a registrant, registrars must fill out an online form protected by a captcha code. This form requires the registrar to fill out the requested domain name, the registrant information (nic-handle) and the reason or legitimate interest within a maximum of 4000 characters.

The reserved term request will automatically be sent to the registry’s back office into a queue for human validation by one of the registry’s validation agents. If the legitimate interest of the domain registrant is enough evidence that the domain creation complies with the registry’s policies the validation agent will generate an authorization code that will be sent by email to the registrar that made the request.

For security reasons the registrar’s email address on which the authorization code is sent to is the one defined as the NOC email address.
For additional security reasons the registry has decided that this authorization code is valid on the SRS for a maximum of 15 days. After 15 days the authorization code will expire and a new request will be necessary to retrieve a new authorization code.
The code generated by the registry’s validation agent can only be used for a domain name creation of the requested term for the requested registrant by the requesting registrar. Meaning that an authorization code cannot be used by another registrar or for another holder (identified by its nic-handle).

In case the request does not comply with the registry’s policies or if the given information is not sufficient to generate an authorization code, the validation agent will ask the registrar for complementary information. The registrar has 15 days to answer and provide sufficient information and or complementary documentation to the registry’s validation agent. After 15 days without sufficient information or documents, the authorization code request is abandoned.

Once the registrar receives an authorization code from the registry’s validation agent, the registrar has 15 days to initiate a creation operation on the requested reserved term. This authorization code is fully compatible to the registry’s EPP interface and is used during a creation operation as the auth_info code (see question 24 on EPP).

When the domain name creation operation with the valid authorization code is initiated by the registrar the SRS checker will automatically verify the code, the holder and the requesting registrar with the information contained in the registry’s back office. If the data is correct the creation operation will be processed like any regular domain name creation.

Table of Contents :

1 - Receipt of data from registrars concerning registration of domain names and nameservers : Shared Registration System (SRS)
2 - Operation of the Registry zone servers
3 - Provision to registrars of status information relating to the zone servers for the TLD
3.1 - Standard DNS related status information
3.2 - Emergency DNS related status information
4 - Dissemination of TLD zone files.
4.1 - Incremental updates every 10 minutes
4.2 - Complete publication of the zone
4.3 - Propagation mechanism
4.4 - Zone File Access⁄Distribution
5 - Dissemination of contact or other information concerning domain name registrations (Whois service)
6 - Internationalized Domain Names
7 - DNS Security Extensions (DNSSEC)
7.1 - Registrar Services
7.2 - Signing Activity
8 - Other relevant services
8.1 - Security and Redundancy
8.2 - Consensus Policy Compliance

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1 - Receipt of data from registrars concerning registration of domain names and nameservers : Shared Registration System (SRS)

Operated by AFNIC, the .BZH TLD will adapt a domain shared registration system used in production by AFNIC to operate .fr zone and which has been fully functional for the past 15 years. This Extensible Provisioning Protocol (EPP) based Shared Registration System (SRS) has exhibited the ability to meet stringent SLAs as well as to scale from the operational management of an initial thousands of domain names to over 2 million in late 2011.

The SRS exists to interact with the Registrar’s systems, who are responsible for the provisioning of a registrant’s domain name with the .BZH TLD registry. Registrars interact with the registry through two primary mechanisms :
* Communication machine to machine via an EPP client (Registrar) to an EPP Server API (Registry).
* A Web Portal Interface that expresses the functionality of the EPP API. The Web Portal also provides access to user configuration and other back-office functions such as report and invoice retrieval.

SRS functionality includes standard functions and features such as :

* Domain Registration : The AFNIC SRS supports synchronous registrations (creations) of domain names through the EPP domain create command. It supports updates of associative status, DNS and DNSSEC delegation information and EPP contact objects with a domain and the deletion of existing domains. This allows Registrars to create domain registrations, modify them and ultimately delete them.

* Domain Renewal : The AFNIC SRS allows registrars to renew sponsored domains using the EPP renew command. The SRS automatically renews domain names upon expiry.

* Transfer : The AFNIC SRS supports the transfer of a given domain between two Registrars in a secure fashion by requiring two party confirmations and the exchange of a token (the EPP authinfo code) associated with the domain.

* Contact Objects : The AFNIC SRS supports the creation, update, association to domain objects, and deletion of EPP contact objects. This functionality supports the required information to supply contact data displayed in Registration Data Directory Services (RDDS) (Whois) systems.

* Hosts : A subordinate object of the domain object in an EPP based SRS, internal hosts are supported in the AFNIC SRS. These hosts cannot be removed when other 2nd level domains within the .BZH TLD zone are delegated to these nameservers. Delegation must be removed prior to the removal of the child hosts and a parent domain name to a given host in turn cannot be removed prior to the deletion of the related child host.

* Redemption Grace Period (RGP) & Restoring deleted domain name registrations : AFNIC SRS supports the RGP for the purpose of retrieving erroneously deleted domain names prior to being made available again for public registration.

Other features include :

* Additional EPP commands in order to manage and update both domain and contact objects in the registry which are EPP info, check, delete and update commands.

* An inline billing system which is synchronised with the SRS. Actions can be taken daily from simple alerts to concrete account blocking.

* Grace Periods and Refunds : the AFNIC SRS will support standard grace periods such as Add, Renew, Autorenew, Transfer and RGP grace periods. Refunds issued will reflect actual values deducted from registrar’s balance in consideration of any rebates issued conjunctively or separately for the relevant domain registration.

* The capacity to deal with reserved domain name registration. Reserved names are stored in a specific back office tool. Specific authorisations codes can be delivered out of band by support team to “unlock” creation of these reserved names. SRS uses standard EPP auth_info field in conformity with EPP RFCs to prevent or allow the registration of the domain name.

[see attached diagram Q23_1_authorisation_code_workflow.pdf]
Diagram : Reserved names unlock
Description : This diagram illustrates process to unlock registration of reserved names. An out of band email process is used to deliver a specific authorisation_code, that can be used in EPP or through the web interface to register the domain name.

SRS EPP functions are compatible with the following list of RFCs :
RFCs 5910, 5730, 5731, 5732, 5733 and 5734. Since AFNIC will implement the Registry Grace Period (RGP), it will comply with RFC 3915 and the successors of the aforementioned RFCs.

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2 - Operation of the Registry zone servers

The DNS resolution service is a core business of the Registry Operator. It is an essential function that must be provided with a very high level of service quality to satisfy queries concerning a zone 100% of the time with a response time as short as possible.

As the registry back-end service provider for the .BZH TLD, AFNIC has a set of sites, distributed internationally, to answer these queries. The high availability of responses is ensured by the number of servers that host the zone information; the response time is in turn linked to the geographical location of the servers (as near as possible to the exchange points and as a result to users).

To ensure a very high level of availability of information and a response time as short as possible to a DNS query for a given zone, AFNIC has chosen to deploy its own DNS architecture, operated by our teams, while also relying on a set of internationally recognized service providers in order to significantly increase the number of servers hosting the zone to be published.

The AFNIC DNS service is based on the standards of RFCs (RFCs 1034, 1035, 1982, 2181, 2182, 2671, 3226, 3596, 3597, 4343, and 5966 and any future successors), related to the Internet, and the DNS in particular.

In addition, special attention has been paid to the security component of the DNS servers and services in order to maintain a very high level of availability of the information, for example in the event of attacks or the denial of services. At present, a series of national and international servers are deployed as close as possible to the exchange points to ensure the DNS resolution service. To ensure a high level of availability, Anycast technology is applied to overcome the issues involved in the geographical location of sensitive servers. Through an effective pooling of DNS server resources, it ensures better resistance to denial of service attacks as the number of physical servers to attack is very high, and the geographical attraction of traffic by each server is very strong. Maintenance of the nodes is also improved since interventions on a given server have no effect on the visibility of the Anycast cloud for users.
As explained in the answer to Question 34 (Geographic Diversity), the registry also relies on two operators of Anycast clouds to expand the international coverage of the DNS nodes which must respond to queries for the domain extensions hosted on them. The two operators are Netnod Autonomica and PCH (Packet Clearing House) who are both known for their high quality services; in addition, Netnod Autonomica hosts one the root server i.root-servers.net.

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3 - Provision to registrars of status information relating to the zone servers for the TLD

Registrars interactions with the Registry Systems in two states in regards to the state of the TLD zone servers :
* an operational state where normal registry transactions and operational policies⁄practices result in a cause and effect in resolution of relevant domains AND
* an emergency state where resolution could be threatened by operational problems due to either internal or external factors to the DNS services.

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3.1 - Standard DNS related status information

The SRS supports related updates to domain objects that allow a Registrar to populate internal (glue record) and or external DNS hosts associated with the domain. External hosts result in the correct associated NS records being inserted into the current TLD zone file, this in turns results in DNS resolution being delegated to the identified external hosts. The SRS expresses this status to the Registrar as “Active” in both the EPP API and the SRS Web Portal. The registrar may suspend the NS records associated with the external hosts by applying an EPP client HOLD in the system, which will also be displayed as a status in the same manner. This holds true of the Registry when it applied “Server Hold”. Internal hosts follow the same behaviour with one exception, IP addresses must also be provided to the SRS by the registrar for Internal hosts, resulting in A records or⁄and AAAA records for IPv6 (also known as glue records) being added to the zone file.

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3.2 - Emergency DNS related status information

AFNIC registry services maintain emergency Network Operation Center (NOC) and Customer Service personnel on a 24⁄7⁄365 basis to address escalation and customer issue management. Part of these teams responsibility is to maintain contact lists for technical notification of regular or emergency situations including email lists, names and contact numbers. In the unlikely event that DNS resolution or DNS updates were or were expected to fall out of ICANN mandated SLAs, registrars will be contacted proactively by their email lists, status alerts will be posted to the Registry Operator’s Registrar Relations Web Portals and Customer Service personnel will be prepared to take and address calls on the current DNS status.

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4 - Dissemination of TLD zone files.

Publication of DNS resolution data to the TLD DNS nodes serving resolution :
One of the main challenges of DNS resolution is to provide updated information about the resources associated with a registered domain name. As soon as information is updated by a registrar on behalf of a customer, the latter expects the server to be accessible to its users as soon as possible.
For this reason, updates of DNS resolution data (publication) are entered into the AFNIC SRS, subsequently generated into incremented zone files, and are distributed to the authoritative DNS servers using the two following methods :
* Incremental updates every 10 minutes
and
* Complete publication of the zone.

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4.1 - Incremental updates every 10 minutes

The principle of publication by Dynamic Update (RFC 2136 and 2137) is designed to publish only the changes to the zone that have occurred since the last update. At the registry level, we have opted to propagate every 10 minutes the changes made during the last 10 minutes on all the zones managed. In this way, any changes made will naturally be published in the next 10 minutes.

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4.2 - Complete publication of the zone

In addition to the publication described above, the registry’s DNS operations team produces a complete publication of all the data for all the zones once a week by running a series of computer scripts which regenerates zonefile from database, through the same validation and integrity mechanisms as dynamic publication. This is used as a training for eventual recovery measures to be triggered.

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4.3 - Propagation mechanism

Whether during the publication by Dynamic Update or complete publication, the propagation mechanism is the same. The process involving the generation of the various zone files is triggered, without blocking any operation on the registration system.
These zone files are then transmitted in full to the authoritative server, via the AXFR protocol in conformance with RFC 5936. Once received and processed by the authoritative server, notifications are sent to secondary servers that will retrieve the changes in the different zones via the IXFR protocol in conformity with RFC 1995. The choice of an incremental (rather than complete) update of the zone files to the secondary servers during the dissemination process has been made to avoid sending large amounts of data to remote sites.

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4.4 - Zone File Access⁄Distribution

In compliance with Specification 4, Section 2, AFNIC registry services will offer a subscription service for qualifying applicants to download a stateful copy of the TLD zone file no more than once per 24 hours period. Distribution of the zone file will occur through the ICANN authorized Centralized Zone Data Access Provider.

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5 - Dissemination of contact or other information concerning domain name registrations (Whois service)

The AFNIC RDDS (Whois) service is in direct connection with the database of the Shared Registration System and offers access to the public administrative and technical data of the TLD. Contact data associated with registrations in the SRS is accessible both on port 43 (following specifications of RFC 3912) and through web access.

Data that can be accessed through the RDDS include:
* contact data : registrant, administrative, technical, billing
* domain data : domain name, status
* host data : name servers, IP addresses
* ephemeris : creation, expiration dates
* registrar data
These data elements are fully compliant to the mapping of RFCs 5730 to 5734.

Both web and port 43 RDDS offer natively compliance with privacy law with a “restricted diffusion” flag. This option is activated through EPP (see Question 25 (EPP)) while creating or updating a contact and automatically understood by the Whois server to anonymize the data. The choice to activate restricted diffusion is made in compliance with the policy and the local rules of the TLD.

This service is accessible both in IPv4 and IPv6. The AFNIC RDDS service access is rate limited to ensure performance in the event of extreme query volumes generated in the cases of distributed denial of service (DDOS) and⁄or RDDS data-mining activities.

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6 - Internationalized Domain Names

Based on AFNIC’s Back-end registry’s operation experience, the .BZH TLD will allow registration of IDN domain names in full compliance with RFCs 5890 to 5893 and based on the character set described in detail in our answer to Question 44 (IDN). This feature will not be available upon launch of the TLD and shall be implemented in the future following the policies presented in detail in our answer to Question 44 (IDN). For the purpose of clarity, a brief summary of this information is presented below.

The list of characters includes the French language as well as several other regional languages in use in France : Occitan, Breton, Frankish, Reunion Creole, Catalan, Corsican and Guadeloupe Creole. The list consists of some of the characters of the Latin1 standard (ISO-8859-1) and the Latin9 standard (ISO-8859-15), respectively in Unicode Latin-1 Supplement and additional Latin Extended-A and Latin Extended-D blocks.

Each domain name registration is autonomous : the registration of an ASCII domain name and the registration of one of its diacritic variants are independent. The actual registered domain name is the only one to be effectively registered and published by the Whois and DNS Services.

However, the registration of a given ASCII or IDN domain name leads to a default preference to its registrant (original registrant) for the subsequent registration of any of its diacritics variants. Any of these variants can be registered normally by the original registrant at any time. Other registrants are required to request a specific authorization code delivered by the Registry Operator before they can proceed to the registration of such names. This policy applies whether the original registrant initially applies for an ASCII domain name or a diacritic variant of that ASCII domain name. In the latter case, the ASCII name is subject to the same preference policy than the other diacritic variants of the domain name.

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7 - DNS Security Extensions (DNSSEC).

AFNIC registry services fully support DNSSEC and will sign the .BZH TLD zone from initiation into the root servers.

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7.1 - Registrar Services

Operations are available for registrars through EPP with the SecDNS EPP extension version 1.1 exclusively (as defined in RFC 5910) or through registrars extranet (with a web form). Among the two interfaces defined in the RFC 5910, AFNIC chose the “dsData” interface : domain names keys are solely under registrars management and are not exchanged, only the keys hashes (DS records) are sent by the registrars to the registry back-end service provider. Each domain name can be associated to 6 distinct key materials at most.

Zonecheck : A complementary monitoring and validation service.
AFNIC notes that “Zonecheck” is a DNS monitoring and validation service that is outside standard registry services and could be offered by third parties other than a Registry Operator. In respect of DNSSEC monitoring, each change of DS data related to a domain name is verified by the AFNIC ZoneCheck tool, out of band of standard EPP registry functions. Registrar are notified via email of detected errors. This helps Registrars ensure the DNSSEC validation will operate correctly, for example by avoiding the “Security Lameness” scenario outlined in section 4.4.3 of RFC 4641.

Registrar transfer by default removes DS data from the zonefile. This is done to cover cases when a current signed domain names goes from a DNSSEC enabled registrar to another registrar that is not yet prepared to handle DNSSEC materials (the registrar can also be the DNS hoster or not, but in both cases DS data of the domain name has to flow from the registrar to the registry, hence the registrar must have the technical capabilities to do so).

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7.2 - Signing Activity

Each public-facing DNS server operated by AFNIC or through its anycast providers is fully DNSSEC enabled through RFC 4033, 4034, and 4035 by virtue of using standard open source software (BIND & NSD) that are developed according to these RFCs.

Each zone uses a standard Key Signing Key (KSK)⁄Zone Signing Key (ZSK) split (as defined in RFC 4641, section 3.1), which enables longer KSKs and frequent re-signing of zone content to deter DNSSEC-related brute force attacks and to make sure that keys rollovers are part of registry staff operational habits. All keys are created using RSA algorithms, as defined in RFC 4641 section 3.4 : KSKs are 2048 bits long (as recommended for “high value domains” in section 3.5 of RFC 4641), and ZSKs are 1024 bits. Algorithm SHA-256 (as defined in RFC 4509) is used for DS generations. Signatures of zone resources records are done using SHA-2 and more specifically RSA⁄SHA-256 as defined by RFC 5702.

Each zone has its set of dedicated KSKs and ZSKs: one of each is active at all time, while a second of each is ready to be used at next rollover. A third ZSK may be kept in the zone after being inactive (not used any more for signing) to ease transitions and make sure DNS caches can still use it to verify old resource records signatures. Following recommendations in section 4.1.1 “Time considerations” of RFC 4641, with a zone maximum TTL being 2 days and a zone minimum TTL of 1.5 hour, ZSK rollovers are done each 2 months, KSK rollovers are done each 2 years. Their expirations are monitored. Rollovers are operated according to the “Pre-Publish Key Rollover” procedure detailed in section 4.2.1.1 of RFC 4641.

1 year worth of key materials is generated in advance. Encrypted backup of keys is made on Hardware Security Module (HSM) cards (Storage Master Key), which are securely stored physically.

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8 - Other relevant services

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8.1 - Security and Redundancy

AFNIC maintains primary and secondary datacenter locations as well as redundant key personal operating locations. High availability of AFNIC Registry infrastructure is provided through the implementation of either load‐balancing, or fail‐over capacity in various layers of the architecture. It also enables fast scalability through expertise in virtualization technologies. AFNIC’s infrastructure is globally virtualized apart from services requiring very high performance rate and⁄or specific access to dedicated CPU for demanding computation such as DNSSEC zone signing or databases.
AFNIC maintains robust secure policies, protocols and third party testing and certification of security measures and practises. Systems involved in the AFNIC registry services used standard multi-factor authentication, high encryption transmission of data and are kept current with industry advancement in security technologies and best practices in prevention of data breaches. Registry systems follow standard EPP practices including required passphrases associated with each domain object and the use of those passphrases to successfully negotiate and verify domain transfers. Registrars are networked source restricted (2 IP addresses authorized by registrar) for SRS access in addition to the use of digital certificates and contact to Customer Service is restricted to registered Registrar personnel only (identified by personal passphrases⁄credentials listed on file).

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8.2 - Consensus Policy Compliance

AFNIC registry services will fully comply with Specification 1 of the Application Guidebook, below is a list of current consensus policies that have cause and effect on the systems of a registry operator. This list will be updated from time to time as per the ICANN process and the AFNIC registry services will be adjusted to maintain and support full compliance.

* Uniform Domain Name Dispute Resolution Policy (adopted by ICANN Board 26 August 1999; form of implementation documents approved 24 October 1999).
* Inter-Registrar Transfer Policy (effective on 12 November 2004, adopted by ICANN Board 25 April 2003; implementation documents issued 13 July 2004).
* Registry Services Evaluation Policy (effective on 15 August 2006, adopted by ICANN Board 8 November 2005; implementation documents posted 25 July 2006)
* AGP Limits Policy (effective on 1 April 2009, adopted by ICANN Board on 26 June 2008; implementation documents posted 17 December 2008)

Table of Contents

1 - Global description
2 - Shared Registration System (SRS) architecture
3 - SRS architecture diagram
4 - Detailed infrastructure
5 - Rate limitation
6 - Interconnectivity and synchronization with other systems
7 - Performance and scalability
8 - Resources
8.1 - Initial implementation
8.2 - On-going maintenance

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1 - Global description

As one of the critical registry functions, the SRS is part of the core of AFNIC back-end registry solution as deployed to fit the needs of the .BZH TLD.
It both provides services for registrars and generates the data used for DNS publication and resolution service. In that aspect, it is responsible for most of the SLA’s to be respected. The following description will provide full and detailed description of the architecture of the SRS both from an application and from an infrastructure point of view.
This architecture is the same as the one used in production by AFNIC to operate .fr zone and has been fully functional for the last 15 years, with the ability to meet stringent SLAs as well as to scale from the management of a few thousands domain names in operations to over 2 million in late 2011.

------------------------
2 - Shared Registration System (SRS) architecture

AFNIC SRS is based on a three-layer architecture : front-end, business logic, middleware.
These three layers are supported by the data layer which is described in detail in Question 33 (Database Capabilities).

= Front end : Extensible Provisioning Protocol (EPP) and extranet =

The automated front-end of the SRS is EPP.
The EPP interface and implementation complies with RFCs 3735 and 5730-5734. It is itself described in detail in Question 25 (EPP).
An extranet web interface also offers the same functions as the EPP interface.
Both theses interfaces are supported by the same middleware layer.

= Business logic : flexible policies =

The Business logic enables configurability in order to allow for the adjustment of registry systems to the chosen registry policies. Various policy-related parameters such as delay for redemption, access rate-limiting and penalties can be configured in this layer.
The Business logic also incorporates a scheduler which provides for semi-automated processes with human validation in order to address specific policy needs which cannot or should not be fully automated.

= Middleware : a guaranty for evolution and scalability =

The Middleware layer guarantees a consistent and registry oriented access for all the TLD data. All registry applications operate through this layer in order to centralize object management rules. It enables access through different programming languages (Java, php and Perl in AFNIC solution) with same rules and ease of switching from one language to another in case of application refactoring or migration.

= Data =

The Data layer is the structured data repository for domain, contact, operations, historization of transactions, as well as registrars and contracts data. It provides all the necessary resilient mechanisms to ensure 100% uptime and full recovery and backup.
It also provides a complete toolbox for the fine tuning of the various applications. This layer is described in more details in Question 33 (Database capacities).

------------------------
3 - SRS architecture diagram

[see attached diagram Q24_3_SRS_architecture_diagram.pdf]
Diagram : SRS architecture diagram
Description : This diagram shows global interaction between Internet, DMZ (Demilitarized Zone) and private network zones. Topology of network and servers is illustrated including dedicated IP address scheme and network flows.

This diagram does not shows additional sandbox and preproduction services. These services are offered respectively for registrars and back-end developer team to stabilize developments before production delivery. They are fully iso-functional to the SRS description above.

= SRS logical diagram =

Our robust infrastructure shows dual Internet Service Provider (ISP) connectivity both in IPv4 and IPv6 (Jaguar and RENATER), redundant firewall and switching infrastructure. This part of the architecture is mutualised for all TLDs hosted.

The networking architecture dedicates LAN for administration, backup and production.

Servers are hosted on different network zones : database for database, private for servers not visible on the internet and public for external servers visible on the DMZ. Dedicated zones are also set up for monitoring servers, administration servers or desktop and backup servers.
Each server is load balanced and the service is not impacted by the loss of one server, the capacity of each server being sized to be able to host the whole traffic.

Servers are fully dedicated to the .BZH TLD, based on a virtualized hardware infrastructure shared among up to an estimated number of 5 TLDs of comparable scale and use case.

= SRS physical diagram =

The IP scheme used is the following :

2001:67c:2218:1::4:0⁄64 for IPv6 Internet homing
192.134.4.0⁄24 for Ipv4 Internet homing

= Production LAN =

192.134.4.0⁄24 for public network IP range
10.1.50.0⁄24, 10.1.30.0⁄24 for private network IP ranges distributed on the zones described above.

= Backup LAN =

172.x.y.0⁄24 : x is different on each network zone. y is fixed to the value of the associated production LAN in the same zone (for example Private zone production LAN being 10.1.”50”.0⁄24, Private zone backup LAN is 172.16.”50”.0⁄24)

= Administration LAN =

172.z.y.0⁄24 : z is the value of x+1, x being the digit chosen for the corresponding Backup LAN in the same zone. y is fixed to the value of the associated production LAN in the same zone (for example Private zone production LAN being 10.1.”50”.0⁄24, Private zone administration LAN is 172.17.”50”.0⁄24).

Hot standby of the production database is automatically taken into account by the SRS Oracle Transparent Network Substrate configuration. Therefore if the database are migrated in hot standby due to failure of part of the system, the SRS access is automatically swapped to the new base.

------------------------
4 - Detailed infrastructure

The SRS modules play a central role in the back-end registry infrastructure. This is highlighted in terms of capacity expenditures (CAPEX) by the fact that SRS modules account for approximately 30% of the global CAPEX of the solution.

In the following description “server” will refer to either a physical or a virtual server.
Due to very fast growth of performance in storage and processors technologies, the infrastructure described below could be replaced by more powerful one available at the time of the set up for the same cost.

It is important to note that at the applicative and system level, AFNIC’s SRS is fully dedicated to the .BZH TLD

AFNIC has invested in very efficient VMWare Vsphere virtualization infrastructure. It provides a flexible approach to recovery both through quick activation of a new fresh server in case of local failure (cold standby) and through global failover to a mirrored infrastructure on another site.
This comes in addition to natural redundancy provided by the load balanced servers.

Nevertheless, internal protocols and best practices for server virtualization have shown that very high I⁄O-intensive (Input⁄Output) application servers are not good clients for virtualization. The SRS is therefore hosted on virtualized infrastructure to the exception of the database, which presents very high rate of I⁄O, and is hosted on a dedicated physical infrastructure.

The whole SRS service is located in the primary datacenter used by AFNIC in production, the secondary datacenter serves as failover capacity.

The Front end is hosted on two load balanced virtual servers and two load balanced reverse proxies ensuring authentication of registrars.

The Business logic is hosted on two load balanced dedicated virtual servers. Scalability of these servers is ensured by quick resizing offered by virtualization technology if needed.

The Middleware is hosted on two load balanced dedicated virtual servers. It can be extended to any amount of servers needed to ensure performance commensurate with the amount of traffic expected. The dual use of Apache HAproxy and of a centralized lock mechanism ensure good queuing of each request in the system despite heavy load and parallelized middleware data access.

Scalability of all these servers are ensured by quick resizing offered by virtualization technology if needed.

All databases are based on Oracle technologies. The main database is replicated logically on two sites. Full local recovery processes are in place in case of loss of integrity through the Oracle redolog functions which provides full recovery by replay of historized logged requests.

The whole SRS service is located in the primary Tier 3 datacenter used by AFNIC in production, the secondary datacenter serves as failover capacity. Continuity mechanisms at a datacenter level are described in Questions 34 (Geographic Diversity), 39 (Registry Continuity) and 41 (Failover testing).

The detailed list of infrastructures involved can be described as follows :

This infrastructure is designed to host up to an estimated number of 5 TLDs of comparable scale and use case.

= Virtual servers =

EPP proxy : 2 servers
* Processor: 1 bi-core CPU
* Main memory: 8 GB of RAM
* Operating system: RedHat RHEL 6
* Disk space: 500 GB

EPP service : 2 servers
* Processor: 1 quad-core CPU
* Main memory: 16 GB of RAM
* Operating system: RedHat RHEL 6
* Disk space: 1 TB

Business logic : 2 servers
* Processor: 1 bi-core CPU
* Main memory: 16 GB of RAM
* Operating system: RedHat RHEL 6
* Disk space: 500 GB

Data Gateway : 2 servers
* Processor: 1 quad-core CPU
* Main memory: 16 GB of RAM
* Operating system: RedHat RHEL 6
* Disk space: 1 TB

= Data storage : see Question 33 (Database Capabilities) =

= Physical server =

Rate limiting database : 1 server
* Processor: 1 bi-core CPU
* Main memory: 8 GB of RAM
* Operating system: RedHat RHEL 6
* Disk space: 500 GB

Back up servers, backup libraries, Web whois server : mutualized with the global registry service provider infrastructure

= Additionnal infrastructure =

Failover infrastructure : 6 servers
* 1 bi-core CPU, 8 GB of RAM, RedHat RHEL 6, 500 GB

Sandbox infrastructure : 6 servers
* 1 bi-core CPU, 8 GB of RAM, RedHat RHEL 6, 500 GB

Preproduction infrastructure : 1 server
* 1 quad-core CPU, 16 GB of RAM, RedHat RHEL 6, 1 TB

------------------------
5 - Rate limitation

To ensure resiliency of the SRS a rate limitation and penalty mechanisms are in place.
Rate limitation and penalties are directly implemented on the front end server.

Access is rate limited through token-bucket algorithms with rate-limiting IP data stored on a dedicated database.
Penalties are applied as follow :
* Any command that follows a login command is immediately executed but the next one is only taken into account 2 seconds later. The following commands are not penalized (unless they do not follow one of the limitation rules).
* For the same domain name, the domain:check commands will not be able to follow themselves more than 2 times every 4 seconds. Beyond this rate, a 2 second penalty will be applied on the following domain:check commands (for the same domain name). For instance, it is possible to have a domain:check follow a domain:create command that already followed a first domain:check on a same domain name without any penalty.
* On the other hand, a customer making several domain:check commands on a same domain name will need to respect a 4 second delay between the first and the third call if he wishes not to be penalized.
* Any domain:create command on an already existing domain name induce an additional 2 seconds in the answer time of this command.
* Any domain:info command on a domain name that is not in your portfolio and for which you do not indicate the auth_info induce an additional 1 second in the answer time of this command.

------------------------
6 - Interconnectivity and synchronization with other systems

= Whois (RDDS) =

The whois service will be described in detail in Question 26 ( Whois). It is hosted on two servers directly connected to the main production database through read only API. Data updated by the SRS are immediately visible in the Whois with no further synchronisation needed. Rate limitation is applied on RDDS service to avoid any load on the database due to Whois direct access. Hot standby of the production database is automatically taken into account by the Whois Oracle Transparent Network Substrate configuration. Therefore if SRS and database are migrated in hot standby due to failure of part of the system, the Whois service is automatically swapped to the new architecture.

= Back office⁄billing⁄Escrow =

Back-office, escrow and billing system is hosted on mutualized server. It operates directly on production data through the middleware layer to ensure integrity of data. These can be considered as fully synchronous applications. Hot standby of the production database is automatically taken into account by the Middleware layer Transparent Network Substrate configuration. Therefore if SRS and database are migrated in hot standby due to failure of part of the system, the back office and billing service are automatically swapped to the new architecture.

= Monitoring =

Monitoring is operated through probes and agents scanning systems with a 5 minutes period. The monitoring system gets snmp data from all servers described in the SRS architecture and also from dedicated Oracle monitoring agent for the database. A specific prove for EPP simulating a full domain creation is also activated, still with the 5 minutes period.

= Dispute resolution =

Any operation on domain names triggered in the context of a dispute resolution is made through a back-office tool (see Back office)

= DNS publication =

DNS publication relies on a specific table of the production database hosted on the same oracle instance. These data are directly generated by the SRS system. Dynamic Update batches are generated at each operation. The use of theses batches for DNS Dynamic update or of the whole data for full zonefile generation are made directly from these production data. No further synchronization is needed. The detail of frequency and workflow for dns publication is described in Question 35 (DNS) and Question 32 (Architecture). Hot standby of the production database is automatically taken into account by the DNS publication Transparent Network Substrate configuration. Therefore if SRS and database are migrated in hot standby due to failure of part of the system, the dns publication is automatically swapped to the new architecture.

------------------------
7 - Performance and scalability

The Registry’s SRS offers high level production SLAs and derives from the branch of systems that have evolved over the last 15 years to successfully operate a set of french ccTLDs.

The Registry’s SRS is used to operate .fr, .re, .yt, .pm, .tf, .wf TLDs. It is used by more than 800 registrars in parallel managing more than 2 millions domain names.

AFNIC’s SRS is designed to meet ICANN’s Service-level requirements as specified in Specification 10 (SLA Matrix) attached to the Registry Agreement.

Actual and current average performance of AFNIC’s SRS is :
* SRS availability : 99,4%
* SRS session-command RTT : 400ms for 99,4% of requests
* SRS query command RTT : 500ms
* SRS transform command RTT : 1,4 s on availability period
* SRS max downtime : 2 hours⁄month

As described in Question 31 (Technical Overview) in relation to each of the phases of the TLD’s operations, the following transaction loads are expected on the SRS :
* launch phase : up to 300 requests⁄minute
* routine ongoing operations : up to 16,300 requests⁄day

The system is designed to handle up to 400,000 domain names and up to 10 requests per second.

The targeted TLD size being approximatly 17,000 domain names after 3 years of operations and the expected peak transaction rate being 300 requests per minute during the launch phase, this ensures that enough capacity is available to handle the launch phase, unexpected demand peaks, as well as rapid scalability needs.

Capacity planning indicators are set up to anticipate exceptional growth of the TLD.
Technologies used enables quick upgrade on all fields :
* Servers : virtual resizing to add CPUs or disk space if resource is available on the production ESX servers. If not, 2 spare additional ESX servers can be brought live if additional performance is needed.
* Database : database capacity has been greatly oversized to avoid need of replacement of this physical highly capable server. Precise capacity planning will ensure that sufficient delay will be available to acquire new server if needed. A threshold of 40% of CPU use or total storage capacity triggers alert for acquisition.

------------------------
8 - Resources

Four categories of profiles are needed to run the Registry’s Technical Operations : Registry Operations Specialists (I), Registry Systems Administrators (II), Registry Software Developer (III) and Registry Expert Engineers (IV). These categories, skillset and global availability of resources have been detailed in Question 31 (Technical Overview of Proposed Registry) including specific resources set and organisation to provide 24⁄7 coverage and maintenance capacity.
Specific workload for SRS management is detailed below.

------------------------
8.1 - Initial implementation

The set up is operated on the pre-installed virtualization infrastructure. It implies actions by system, database and network administrators to create the virtual servers and install the applicative packages.

Then, developers, assisted by a team of experts and senior staff members apply proper configuration for the given TLD. Specific policy rules are configured and tested.

The initial implementation effort is estimated as follows :

Database Administrator 0.10 man.day
Network Administrator 0.10 man.day
System Administrator 0.10 man.day
Software Developer 0.40 man.day
Database Engineer 0.40 man.day
Software Engineer 0.80 man.day
DNS Expert Engineer 0.40 man.day

------------------------
8.2 - On-going maintenance

On-going maintenance on the SRS includes integration of new policy rules, evolution of technology, bug fixing, infrastructure evolution, failover testing.

Although all the defined technical profiles are needed for such on-going maintenance operations, on a regular basis, it is mainly a workload handled by monitoring and development teams for alert management and new functional developments, respectively.

The on-going maintenance effort per year is estimated as follows, on a yearly basis :

Operations Specialist 1.60 man.day
Database Administrator 0.40 man.day
Network Administrator 0.40 man.day
System Administrator 0.40 man.day
Software Developer 2.40 man.day
Database Engineer 0.20 man.day
Network Engineer 0.20 man.day
System Engineer 0.20 man.day
Software Engineer 0.20 man.day

Table of Contents

1 - Global description
2 - Description of commands
2.1 - Introduction
2.2 - Global commands
2.2.1 - session management commands ‘greeting’, ‘hello’, ‘login’, ‘logout’
2.2.2 - poll command ‘poll’
2.3 - domain commands
2.3.1 - query commands ‘check’, ‘info’
2.3.2 - transform commands
2.4 - contact command
2.5 - Return Codes
3 - Compliance to RFCs
3.1 - Delivery process
3.2 - XML validation
3.3 - Cross checking
4 - Specific extensions
4.1 - Specific extension : DNSSEC
4.2 - Specific extension : IDN
4.3 - Specific extension : Sunrise period
4.3.1 - New objects
4.3.2 - Command extensions
4.3.2.1 - EPP Query Commands
4.3.2.2 - EPP Transform Commands
4.3.2.2.1 - EPP ʹcreateʹ Command
4.3.2.2.2 - EPP ʹupdateʹ Command
4.3.2.2.3 - EPP ʹdeleteʹ Command
5 - Resources
5.1 - Initial implementation
5.2 - On-going maintenance

------------------------
1 - Global description

The main service of the Shared Registration System (SRS) for its registrars is the Extensible Provisioning Protocol (EPP) interface. The interface has been developed and is maintained in full compliance with the relevant standards RFCs 5730-5732 and with RFCs 5910 and 3735 for the standard registration interface. Contacts are handled as described in RFC 5733. Transport is guaranteed according to RFC 5734. In addition, AFNIC’s EPP implementation is also compliant with RFCs 4034, 5730 and 5731 for DNSSEC support and with RFCs 5890 and 5891 for Internationalized Domain Name (IDN) support.

The EPP service is available through IPv4 and IPv6, based on a SSL certificate authentication.
No specific extension is used.

Note : Throughout the document we write the XML markups describing the EPP requests between the two characters ʹ and ʹ.

For contact management, the registry service provider uses a dedicated “Repository Identifier” for each TLD, this Repository identifier being declared to IANA prior to the launch of the TLD. It is also used as a post-extension to contact nic-handles, each contact for a given TLD being then identified by a unique code XX1234-REPID. An example of this declaration can be found for .fr extension (2008-05-10) at IANA epp repository identifier’s page :

[...]
NORID, #x004E #x004F #x0052 #x0049 #x0044 UNINETT Norid AS 2007-12-10 info&norid.no
FRNIC, #x0046 #x0052 #x004e #x0049 #x0043 AFNIC 2008-05-29 tld-tech&afnic.fr
CIRA, #x0043 #x0049 #x0052 #x0041 Canadian Internet Registration Authority 2009-07-22 info&cira.ca
[...]

------------------------
2 - Description of commands

------------------------
2.1 - Introduction

The EPP interface, based on a double system of real-time answer by the server and asynchronous notifications, implements all standard operations : ‘domain:create’ (1 to 10 years), ‘domain:info’, ‘domain:checkʹ, ‘domain:transfer’, ‘domain:update’, ‘domain:renew’. Similar commands are available concerning contact objects.
The registry’s EPP server implement name servers management as domain name attributes in conformity with RFC 5732.

[see attached diagram Q25_2.1_EPP_xsd_main_schema.pdf]
Diagram : EPP xsd main schema
Description : Registry service provider SRS EPP interface is based on standard xsd schema as defined in RFC 5730.

In the following description of the commands, an example of client command and server answer has been added only for the create command as an example. All other commands work in the same way in full compliance with descriptions and schema of RFCs 5730-5734 and same examples can be found in the RFCs text.

------------------------
2.2 - Global commands

------------------------
2.2.1 - session management commands ‘greeting’, ‘hello’, ‘login’, ‘logout’

As all of these commands are basic and totally compliant with the IETF’s STD69 (RFCs 5730 to 5734), they have not be described again here.

Focus points are :
* Enforcing a limit of 2 simultaneous connection per registrar (checked at login), ensuring equitable access for all registrars.
* List of namespaces announced in ʹgreetingʹ is strictly checked in registrar ʹloginʹ command.
* ʹhelloʹ can be used by registrars as a keepalive command, otherwise inactive sessions are closed by server after 20 minutes.

------------------------
2.2.2 - poll command ʹpollʹ

For some operation on objects, notifications are added in a queue that can be read by using the ʹpollʹ command. The use of the ʹpollʹ command will retrieve the oldest message in the queue. The number of messages awaiting in the queue is indicated at each command answer with the ʹmsgQʹ element. To delete a message from the queue, the ʹpollʹ command should be used with the message number as indicated in RFC 5730.

------------------------
2.3 - domain commands

------------------------
2.3.1 - query commands ʹcheckʹ, ʹinfoʹ

ʹcheckʹ command allows the client to check if a domain object is available.
ʹinfoʹ command allows the client to retrieve information on any objects (domain names or contacts) that are indicated in the command. Registrars can only use this command for objects they already manage in their portfolio. This command can also be used for domain names outside the registrar’s portfolio if the ʹauth_infoʹ code that protects the domain is given as well.

------------------------
2.3.2 - transform commands

In compliance with RFCs 5730 (commands presentation), 5731 (domain objects), 5732 (contact objects) and 5910 (DNSSEC specifications) AFNIC’s Registry solution use the following commands that allow for objects updates :

= ʹcreateʹ =

The EPP protocol (RFC 5730) allows domain name creation (RFC 5731). The registry service provider allows two types of creations: direct domain creations (with auth_info freely determined by the registrar) and domain names creation “with authorization code” (the correct auth_info value must be sent for the creation to succeed)

Both are standard domain:create command as defined in the RFCs.

[see attached diagram Q25_2.3.2_EPP_create_command_example.pdf]
Diagram : EPP client create command and server answer example
Description : This is a standard EPP client create command following RFC 5731. Parameters sent in the following example are domain name, period of registration, registrant identifier, administrative, technical and billing identifier, and auth_info password followed by standard EPP server create command answer compliant with RFC 5731. Parameters sent in the answer are result code, message, creation and expiry date, and client and server transaction ID.

Creation “with authorization code” enables the registry service provider to manage protected names or names under specific registration conditions. An authorization code is associated to three items (the registrar, the domain name and the holder nic-handle ) and is delivered outside the automated process through a manual process defined by a specific policy rule. The registry-generated authorization code must be present in the ʹdomain:authInfoʹ item of the creation request. No registrar-computed value is permitted.
In every case, domain creation proceeds through standard EPP command.

[see attached diagram Q25_2.3.2_SRS_authorisation_code.pdf]
Diagram : SRS authorisation code
Description : The EPP auth_info field that can usually be freely filled in by the registrar has a specific use for registration of reserved names : an authorisation_code is delivered through an out of band process and must be used in the create command for the answer to be successful.

= ʹupdateʹ =

The registry offers EPP ʹdomain:updateʹ command to :
* update the administrative, technical, registrant contacts of a domain name
* update the DNS and DNSsec configuration of a domain name
* update the status of a domain name or its auth_info

This command is also used to add or delete signed delegations (DS records), through a ʹsecDNS:updateʹ extension if DNSSEC operations are wanted and if the secDNS extension was chosen by the client at login.

When requested the status of domain name is changed to “pendingUpdate”.

= ʹdeleteʹ =

The whole deletion process (including redemption grace period and pending delete) of a domain name comes with a restoration mechanism (restore). This mechanism, based on RFC 3915, is applied to the deletion operation only.

The status of the domain name is switched to ʺpendingDeleteʺ for the total duration of the ʺredemption grace periodʺ and as long as the domain is not restored or totally deleted.

= ʹtransferʹ =

The registry offers standard EPP ʹdomain:transferʹ command to allow a change of registrar to the registrant.

A transfer can be initiated only by an incoming registrar and using the auth_info that the registrant has given him. This standard mechanism acts as a security and associates the triggering of transfer to the acceptance of the owner of the domain.
The transfer operation can be triggered only if the domain is not protected by a clientTransferProhibited lock.

The transfer implementation follows RFC 5730 section 2.9.3.4 and its lifecycle follow the inter registrar transfer policy as revised by the ICANN in 2008.

------------------------
2.4 - contact command

Postal addresses are managed as indicated in RFC 5731 with the following specific rules : only the type “loc” for postal addresses is accepted and only one element of type ʹcontact:postalInfoʹ can be indicated for the contact .

ʹdiscloseʹ parameters is implemented and enables to activate restricted publication in the RDDS.
The choice to activate restricted diffusion is made in compliance with the policy and the local rules of the TLD towards privacy law.

------------------------
2.5 - Return Codes

Some operations under normal working conditions of the SRS will answer with a 1000 return code. Otherwise, two different levels of return codes have been chosen according to the two different types of problems that can happen on the SRS :
* minor problems answer with Return code 1001 : Minor problems do not affect requests reception. This code indicates the command was taken into account but that its complete execution is delayed. The final result will be known later on and will be sent in a message placed in the notification queue of the concerned registrar(s).
* blocking problems answer with Return code 2400 “command failed” : no operations that transform a domain name can be taken into account.

------------------------
3 - Compliance to RFCs

The system has been launched compliant with RFCs. Mechanisms are in place to ensure that ongoing maintenance and new functional delivery stay compliant with RFCs.

------------------------
3.1 - Delivery process

The SRS evolutions are developed on the development environment.
The development process implies strict coding rules and use of shared best practices. Pair programming is standard practice. Unit test are developed prior to function development to ensure resiliency of the produced code.

Delivery process take place in four steps :
* 1st step : XML validation and RFC compliance is checked through automated tools. A 100% compliance signal must be received to be able to proceed to second step.
* 2nd step : delivery to the pre-production environment. The development is delivered on the preproduction environment. This environment is available for internal testing team. They proceed through a standard Operational Test which goes through a full lifecycle of a domain name. Specific tests are made on new functions in any.
* 3rd step : delivery to the sandbox environment. This sandbox environment is opened for registrar where they have two accounts to validate their clients before production activation.
* 4th step : the new release is delivered in production.

------------------------
3.2 - XML validation

EPP RFC compliance is reached through three mechanisms :
* a batch of unitary tests on each operation, each answer of the server being validated through the XSD schema.
* XML validation through perl XML::LibXML::Schema library
* fuzzy testing, by sending garbage input and checking error return codes.

------------------------
3.3 - Cross checking

EPP cross checking partnership is established with .at Registry operator to validate in sandbox environment prior to delivery in production through mutual agreement.

------------------------
4 - Specific extensions

------------------------
4.1 - Specific extension : DNSSEC

The EPP server provides the secDNS-1-1 extension as described in RFC 5910. Implementation specifications are as follows :
* The server only supports “the DS data interface” (ʹsecDNS:dsDataʹ); section 4.1 of RFC 5910, without information on the associated key (the ʹsecDNS:keyDataʹ element is not included); if information on the key is indicated the server will answer with a 2102 error code.
* DNSSEC elements are only accepted during an update operation request. If included during a create operation the server will answer with a 2103 error code.
* Each domain name can have up to 6 associated DS records : the number of elements ʹsecDNS:dsDataʹ present in the ʹsecDNS:addʹ section during an update operation is therefore limited in order to have the domain name’s final status with no more than 6 DS records.
* The maxSigLife attribute is not supported, its presence inside a client request will generate a 2102 error code.
* The urgent attribute is not supported, its presence inside a client request will generate a 2102 error code.

[see attached diagram Q25_4.1_EPP_xsd_dnssec_extension_schema.pdf]
Diagram : EPP xsd dnssec extension schema
Description : Registry service provider DNSsec EPP secDNS-1-1 extension is based on standard xsd schema as defined in RFC 5910.

------------------------
4.2 - Specific extension : IDN

No specific IDN extension has been used. The script used for the TLD is declared in the greetings and no further indication is needed in the following transaction. Usage is in full compliance with RFCs 5890, 5891, 5892, 5893, and 5894. This may be a pending situation : if a standard IDN extension was to be produced in the months to come it would be added to the EPP schema in order to deal more precisely with each specific language management policies.

----------------------
4.3. Specific extension : Sunrise period

Sunrise period is managed through a specific EPP extension. The sunrise registration workflow is described in Question 29 (Right Protection Mechanism).

The extension used is described below but will follow work in progress at the IETF initiated by Cloud Registry (draft-tan-epp-launchphase-01.txt). The xsd schema has been designed by AFNIC’s partner CORE and is fully in accordance with the draft. It could be modified before the launch if the IETF draft was to be accepted as an RFC with modifications.

AFNIC Registry extension is fully compatible with extension mechanism described in RFC 5730. It offers trademark holders a specific mapping to provide information related to trademarks. It also enables query function to keep the sunrise process transparent to everybody.

For illustration and further information purposes, please refer to the Q25_4.3_EPP_xsd_sunrise_extension_schema.pdf file attached (EPP XSD sunrise extension schema) which describes the registry back-end services provider’s EPP extension XSD schema used to deal with sunrise period. This schema is designed based on the work in progress at IETF, as initiated by Cloud Registry (draft-tan-epp-launchphase-01.txt). This extension is fully compatible with extension mechanism described in RFC 5730.

----------------------
4.3.1 New objects

application : to deal with multiple demands on same domain name. The server creates an application object corresponding to the request and assigns an identifier for the application and returns it to the client. This mapping defines an ʹlp:applicationIDʹ element which is used to specify an ID to this object.

phase : optional element ʹlp:phaseʹ to be used in case of multiple sunrise phases.

status : status of each application in link with internal state of the process of the application. The ʹlp:statusʹ values that can be used in order to process the applications are pending, invalid, validated, allocated, rejected. These statuses have to be mapped with the sunrise workflow described in Question 29 (Right Protection Mechanism).

claim : claim object contains the details needed to applicantʹs prior right to the domain name.

The ʹlp:claimʹ element has the boolean ʺpreValidatedʺ attribute, which indicates whether a third party validation agency has already validated the claim in case of inter connection with the IP clearing house.

Several child elements of the ʹlp:claimʹ element are defined :
* ʹlp:pvrcʹ, the Pre-Validation Result Code, is a string issued by a third-party validation agent.
* ʹlp:claimIssuerʹ contains the ID of a contact object (as described in RFC 5733) identifying the contact information of the authority which issued the right (for example, a trade mark office or company registration bureau).
* ʹlp:claimNameʹ identifies the text string in which the applicant is claiming a prior right.
* ʹlp:claimNumberʹ contains the registration number of the right (i.e. trademark number or company registration number).
* ʹlp:claimTypeʹ indicates the type of claim being made (e.g. trademark, symbol, combined mark,
company name).
* ʹlp:claimEntitlementʹ indicates the applicantʹs entitlement to the claim (i.e. owner or licensee).
* ʹlp:claimRegDateʹ contains the date of registration of the claim.
* ʹlp:claimExDateʹ contains the date of expiration of the claim.
* ʹlp:claimCountryʹ indicates the country in which the claim is valid.
* ʹlp:claimRegionʹ indicates the name of a city, state, province or other geographic region in which the claim is valid. This may be a two-character code from WIPO standard ST.3.

----------------------
4.3.2 command extensions

----------------------
4.3.2.1 EPP Query Commands

ʹinfoʹ command is the only extended query command.

In order to indicate that the query is meant for an application object, an ʹlp:infoʹ element is sent along with the regular ʹinfoʹ domain command.

The ʹlp:infoʹ element contains the following child elements :
* ʹlp:applicationIDʹ, the application identifier for which the client wishes to query, and ʹlp:phaseʹ (optional), the phase the application is associated with.
If the query was successful, the server replies with an ʹlp:infDataʹ element along with the regular EPP ʹresDataʹ. The ʹlp:infData contains the following child elements:
* ʹlp:applicationIDʹ the application identifier of the returned application.
* ʹlp:phaseʹ (optional) the phase during which the application was submitted or is associated with.
* ʹlp:statusʹ (optional) status of the application.
* ʹlp:claimʹ (optional) one or more ʹlp:claimʹ elements.
If present, the ʹlp:claimʹ elements may contain the child elements as described above in the claim object description.

----------------------
4.3.2.2 EPP Transform Commands

There are three extended EPP transform commands : ʹcreateʹ, ʹdeleteʹ and ʹrenewʹ

----------------------
4.3.2.2.1 EPP ʹcreateʹ Command

The EPP ʹcreateʹ command is used to create an application. Additional information is required to submit a domain name application during a launch phase :
* ʹlp:phaseʹ (optional), the phase the application should be associated with
* ʹlp:claimʹ (optional) elements to substantiate the prior rights of the applicant.

When such a ʹcreateʹ command has been processed successfully, the EPP ʹextensionʹ element in the response contains a child ʹlp:creDataʹ element that identifies the registry launchphase namespace and the location of the registry launchphase schema. The ʹlp:creDataʹ element contains a child ʹlp:applicationIDʹ element, which informs the registrar about the application ID the server has assigned.

----------------------
4.3.2.2.2 EPP ʹupdateʹ Command

This extension defines additional elements to extend the EPP ʹupdateʹ command to be used in conjunction with the domain name mapping.
Registry policies permitting, clients may update an application object by submitting an EPP ʹupdateʹ command along with an ʹlp:updateʹ element to indicate the application object to be updated.
The ʹlp:updateʹ element contains the following child elements:
* ʹlp:applicationIDʹ the application identifier for which the client wishes to update.
* ʹlp:phaseʹ (optional) the phase during which the application was submitted or is associated with.

----------------------
4.3.2.2.3 EPP ʹdeleteʹ Command

Registry policies permitting, clients may withdraw an application by submitting an EPP ʹdeleteʹ command along with an ʹlp:deleteʹ element to indicate the application object to be deleted. The ʹlp:deleteʹ element contains the following child elements:
* ʹlp:applicationIDʹ the application identifier for which the client wishes to delete.
* ʹlp:phaseʹ (optional) the phase during which the application was submitted or is associated with.

------------------------
5 - Resources

Four categories of profiles are needed to run the Registry’s Technical Operations : Registry Operations Specialists (I), Registry Systems Administrators (II), Registry Software Developer (III) and Registry Expert Engineers (IV). These categories, skill set and global availability of resources have been detailed in Question 31 (Technical Overview of Proposed Registry) including specific resources set and organisation to provide 24⁄7 coverage and maintenance capacity.
Specific workload for EPP management is detailed below.

------------------------
5.1 - Initial implementation

Then, developers, assisted by a senior staff member expert in internet technologies and RFCs apply proper configuration for the given TLD. Compliance is strictly tested.

The initial implementation effort is estimated as follows :

Database Administrator 0.10 man.day
Network Administrator 0.10 man.day
System Administrator 0.10 man.day
Software Developer 0.40 man.day
Software Engineer 0.80 man.day

------------------------
5.2 - On-going maintenance

On-going maintenance on the SRS includes integration of new policy rules, evolution of technology, bug fixing, infrastructure evolution, failover testing.

The on-going maintenance effort per year is estimated as follows, on a yearly basis :

Operations Specialist 0.80 man.day
System Administrator 0.40 man.day
Software Developer 1.60 man.day
Software Engineer 0.40 man.day

Table of Contents

1 - General description
2 - Data access
2.1 Typology of accessible data
2.2 Profiles for data access control
3 - RDDS architecture
4 - RDDS infrastructure
5 - Rate limitation
6 - Reverse lookups
7 - Interconnectivity and synchronization with other systems
8 - Performance and scalability
9 - ICANN Bulk access compliance
10 - RFC compliance
11 - Resources
11.1 - Initial implementation
11.2 - On-going maintenance

------------------------
1 - General description

Registration Data Directory Service (RDDS) is one of the five vital functions of the Registry.
It is in direct connection with the database of the Shared Registration System and offers access to the public administrative and technical data of the registry.
The registry back-end solution implements data access through various interfaces that will be described below as well as their data access policies.

The main focus will be made on Whois on port 43 following RFC 3912 which is the main point of access.
The web Whois offers similar functionalities, is based on the same architecture and will be presented through screenshots.

The following description will provide full and detailed description of the architecture of the RDDS both from an application and from an infrastructure point of view.
This architecture is the same as the one used in production by AFNIC for .FR zone and has been fully functional for the last 15 years, with the ability to meet stringent SLAs as well as to scale from the management of a few thousands domain names in operations to over 2 million in late 2011.

------------------------
2 - Data access

When considering the data access services, we must address :
* the typology of accessible data
* access control : who can access what kind of data
* performance : guarantee of availability and performance for requesting data

Potential limitations to the systems will also be described.
To be able to maintain a good access to everybody (registrar, registrants, outside world), our back-end solution provides multiple access with consistent role and access policies.

------------------------
2.1 Typology of accessible data

Data that can be accessed through the RDDS are mainly :
* contact data : registrant, administrative, technical, billing
* domain data : domain name, status
* host data : name servers, IP addresses
* ephemeris : creation, expiration dates
* registrar data

These data are all described in the RFCs and fully compliant to the mapping of RFCs 5730 to 5734.

------------------------
2.2 Profiles for data access control

= Whois for registrars =

The main registrar access tool is our RDDS service accessible both on port 43 following specifications of RFC 3912 and through web access.
Both web and port 43 RDDS offer natively compliance with privacy law with a “restricted disclosure” flag if needed by the TLD. This option is activated through Extensible Provisioning Protocol (EPP) standard ʹdiscloseʹ parameters while creating or updating a contact and automatically understood by the whois server to anonymize the data.
This service is accessible both in IPv4 and IPv6.
RDDS access for registrar is rate limited to ensure performance. (see performance)

= Public whois =

RDDS access is also available on port 43 to everybody through a rate limited access to ensure performance. (see performance)

= Legal requirements =

AFNIC back end solution implements by default French privacy laws with opt-out holder personal data privacy.
This option can be deactivated if necessary to be compliant with the policy of the TLD.

------------------------
3 - RDDS architecture

= RDDS architecture =

RDDS is running on two load balanced front virtual servers directly connected to two databases : the production database for data access, and a rate-limiting service database which applies rate-limiting policies and store IP involved. This server implements token bucket algorithm to flatten traffic on the server.

The two front servers are load balanced using classical round robin implementation.

The network infrastructure is the same as described in the global architecture (referred to below) and no specific dedicated switch or router is to be considered as the rate limiting tool is an applicative one. A global description of the network infrastructure (switch and routers involved) can be found in answers to Question 32 (Architecture).

[see attached diagram Q26_3_RDDS_architecture_diagram.pdf]
Diagram : RDDS architecture diagram
Description : This diagram shows global interaction between Internet, DMZ and private network zones. Topology of network and servers is illustrated including dedicated IP address scheme and network flows.

= RDDS logical diagram =

Our robust infrastructure shows dual Internet Service Provider (ISP) connectivity both in Ipv4 and Ipv6 (Jaguar and RENATER), redundant firewall and switching infrastructure. This part of the architecture is mutualized for all TLDs hosted.

The networking architecture dedicates LAN for administration, backup and production.

Servers are hosted on different network zones : database for database, private for servers not visible on the internet and public for external servers visible on the DMZ. Dedicated zones are also set up for monitoring servers, administration servers or desktop and backup servers.
RDDS servers are directly on the public zone.
Each server is load balanced and the service is not impacted by the loss of one server, the capacity of each server being sized to be able to host the whole traffic.

Servers are fully dedicated to the .BZH TLD, based on a virtualized hardware infrastructure shared among up to an estimated number of 5 TLDs of comparable scale and use case.

= RDDS physical diagram =

The IP scheme used is the following :

2001:67c:2218:1::4:0⁄64 for IPv6 Internet homing
192.134.4.0⁄24 for Ipv4 Internet homing

Production LAN
192.134.4.0⁄24 for public network IP range
10.1.50.0⁄24, 10.1.30.0⁄24 for private network IP ranges distributed on the zones described above.

Backup LAN
172.x.y.0⁄24 : x is a different on each network zone. y is fixed to the value of the associated production LAN in the same zone (for example Private zone production LAN being 10.1.”50”.0⁄24, Private zone backup LAN is 172.16.”50”.0⁄24)

Administration LAN
172.z.y.0⁄24 : z is the value of x+1, x being the digit chosen for the corresponding Backup LAN in the same zone. y is fixed to the value of the associated production LAN in the same zone (for example Private zone production LAN being 10.1.”50”.0⁄24, Private zone administration LAN is 172.17.”50”.0⁄24)

Hot standby of the production database is automatically taken into account by the RDDS Oracle Transparent Network Substrate configuration. Therefore if the database are migrated in hot standby due to failure of part of the system, the Registration Data Directory Services (RDDS) access is automatically swapped to the new base.

------------------------
4 - RDDS infrastructure

It is important to note that at the applicative and system level, AFNIC’s SRS is fully dedicated to the .BZH TLD.

The RDDS is therefore hosted on virtualized infrastructure on the public zone (Demilitarized Zone - MZ) to the exception of the database, which presents very high rate of I⁄O (Input⁄Output), and is hosted on a dedicated physical infrastructure on the private zone.

The rate limiting database is hosted on one physical dedicated physical server. This server represents no failure point as a failure of the rate limiting system doesn’t affect the service (a standard uniform limitation is then applied instead of intelligent rate limiting).
The main database is the production database also used by the SRS and other registry vital functions and is described more in detail in Question 33 (Database Capabilities).

Databases are based on Oracle technologies. The main database is replicated logically on two sites. Full local recovery processes are in place in case of loss of integrity through the Oracle redolog functions which provides full recovery by replay of historized logged requests.

The whole RDDS service is located in the primary Tier 3 datacenter used by AFNIC in production, the secondary datacenter serves as failover capacity. Continuity mechanisms at a datacenter level are described in Questions 34 (Geographic Diversity), 39 (Registry Continuity) and 41 (Failover testing).

The detailed list of infrastructures involved can be described as follows :

This infrastructure is designed to host up to an estimated number of 5 TLDs of comparable scale and use case.

= Virtual servers =

RDDS server : 2 servers
* Processor: 1 bi-core CPU
* Main memory: 16 GB of RAM
* Operating system: RedHat RHEL 6
* Disk space: 500 GB

= Data storage : see Question 33 (Database Capabilities) =

= Physical server =

Rate limiting database : 1 server
* Processor: 1 bi-core CPU
* Main memory: 8 GB of RAM
* Operating system: RedHat RHEL 6
* Disk space: 500 GB

Back up servers, backup libraries, Web whois server : mutualized with the global registry service provider infrastructure

= Additionnal infrastructure =

Failover, sandbox, preproduction infrastructure : 3 servers
* 1 bi-core CPU, 16 GB of RAM, RedHat RHEL 6, 500 GB

------------------------
5 - Rate limitation

To ensure resiliency of the RDDS a rate limitation mechanism is in place.
RDDS is largely used by various public users and registrars, some of them for domain name drop catching. Potentiality of heavy load on this service is very high.
Therefore a rate limitation is applied with threshold calculated from the level of activity expected in order not to penalize normal use of the service. A double level mechanism enables different threshold for identified IP (white list) from registrar and for the public access.

Rate limitation is directly implemented on the front end server.

Access is rate limited through token-bucket algorithms with rate-limiting IP data stored on a dedicated database.
Penalties are applied as follow :
* any IP : 7,200 request ⁄ 24 hour ⁄ IP.
* white listed IP for registrars : 86,400 requests ⁄ 24 hour ⁄IP.

------------------------
6 - Reverse lookups

The web RDDS access offers advanced searchability capacities.
The following functions are available :

= Direct queries =

* Partial match query on domain name, administrative, technical, and billing contact name and address, registrant name and address, registrar name including all the sub-fields described in EPP (e.g., street, city, state or province, etc.).
* Exact match query on registrar id, name server name, and name server’s IP glue records
The result of direct queries is the object queried (contact, domain, ...)

= Reverse queries =

* Partial match query on domain name, administrative, technical, and billing contact name and address, registrant name and address, registrar name including all the sub-fields described in EPP (e.g., street, city, state or province, etc.).
* Exact match query on registrar id, name server name, and name server’s IP glue records including IPv6 queries.
The result of reverse queries is the list of objects of a given type linked with the result object (list of domains with a given contact result, or name server result,...)

This powerful tool is limited in access :
* Captcha system avoids scripting of the interface.
* Direct queries are open to every user but the number of result objects is limited to 1,000 answers for 1 query.
* Reverse queries can only be done by registrars on the extranet interface, and the number of result objects is limited to 10,000 answers for 1 query. The interface cannot be used more than 100 times a day.

------------------------
7 - Interconnectivity and synchronization with other systems

= SRS =

Data updated by the SRS are immediately visible in the RDDS with no further synchronisation needed. Rate limitation is applied both on SRS and RDDS service to avoid any load on the database. SRS and RDDS are partly in the same network zone, both RDDS servers and EPP SSL reverse proxies being in the public network zone (DMZ).

= Main database =

Hot standby of the production database is automatically taken into account by the RDDS Oracle Transparent Network Substrate configuration. Therefore if database are migrated in hot standby due to failure of part of the system, the RDDS service is automatically swapped to the new architecture.

= Rate limiting database =

No standby is implemented on the rate-limiting database. In case of failure, a standard global limitation is applied while, replacement of the database is operated.

= Monitoring =

Monitoring is operated through probes and agents scanning systems with a 5 minutes period. The monitoring system gets snmp data from all servers described in the RDDS architecture and also from dedicated Oracle monitoring agent for the database.
Hot standby is not implemented on monitoring agents.

------------------------
8 - Performance and scalability

The Registry’s RDDS offers high level production SLAs and derives from the branch of systems that have evolved over the last 12 years to successfully operate a set of french ccTLDs.

The Registry’s RDDS is used to publish .fr, .re, .yt, .pm, .tf, .wf TLDs information. It is used by more than 800 registrars in parallel managing more than 2 millions domain names and by a large user community.

AFNIC’s RDDS is designed to meet ICANN’s Service-level requirements as specified in Specification 10 (SLA Matrix) attached to the Registry Agreement.

As described in Question 31 (Technical Overview) in relation to each of the phases of the TLD’s operations, the following transaction loads are expected on the WHOIS servers :
* launch phase (including sunrise if applicable) : up to 540 requests⁄minute peak
* routine on going operations : up to 30,000 requests⁄day

It can serve up to 10,000 requests⁄min on load balanced service to be compatible with the launch and growth scenario described in Question 31 (Technical Overview).

The targeted TLD objective being around 17,000 domain names with a provision for up to 540 requests per minutes during the launch phase, this ensures that enough capacity is available to handle the launching period, as well as demand peaks and unexpected overhead.

Capacity planning indicators are set up to anticipate exceptional growth of the TLD.
Technologies used enables quick upgrade on all fields :
* Servers : virtual resizing to add CPUs or disk space if resource is available on the production ESX servers. If not, 2 spare additional ESX servers can be brought live if additional performance is needed.
* Servers (alternate) : additional servers can be added and taken into account immediately through dns round robin algorithm.
* Database : database capacity has been greatly oversized to avoid need of replacement of this physical powerful server. Precise capacity planning will ensure that sufficient delay will be available to acquire new server if needed. A threshold of 40% of CPU use or total storage capacity triggers alert for acquisition.

------------------------
9 - ICANN Bulk access compliance

The Registry Operator will provide both data escrow and ICANN bulk access in a same process.
Data escrow generates data on a daily basis. One file per week is kept for ICANN access to bulk data.

------------------------
10 - RFC compliance

The system has been launched compliant with RFCs. Mechanisms are in place to ensure that on going maintenance and new functional delivery stay compliant with RFCs.

= Delivery process =

The RDDS evolutions are developed on the development environment.
The development process implies strict coding rules and use of shared best practices. Pair programming is standard practice. Unit test are developed prior to function development to ensure resiliency of the produced code.

Delivery process take place in four steps :
* 1st step : RDDS validation and RFC compliance is checked through automated tools. A 100% compliance signal must be received to be able to proceed to second step.
* 2nd step : delivery to the pre-production environment. The development is delivered on the preproduction environment. This environment is available for internal testing team.
* 3rd step : delivery to the sandbox environment. This sandbox environment is opened for registrar where they have two accounts to validate their clients before production activation.
* 4th step : the new release is delivered in production.

= Format validation =

RDDS rfc compliance is reached through a specific RDDS checker which is use for non-regression test before each new release.

= Cross checking =

Whois cross checking partnership is established with .at Registry operator to validate in sandbox environment prior to delivery in production through mutual agreement.

= Whois Output =

Output of a whois query is 100% similar to the whois query example available in RFC 3912.

------------------------
11 - Resources

------------------------
11.1 - Initial implementation

The initial implementation effort is estimated as follows :

Database Administrator 0.10 man.day
Network Administrator 0.10 man.day
System Administrator 0.10 man.day
Software Developer 0.40 man.day
Software Engineer 0.20 man.day

------------------------
11.2 - On-going maintenance

On-going maintenance on the RDDS module includes mainly integration of new policy rules, privacy law evolutions, evolution of contracts, infrastructure evolution, failover testing.

The on-going maintenance effort per year is estimated as follows, on a yearly basis :

Operations Specialist 0.60 man.day
System Administrator 0.20 man.day
Software Developer 0.80 man.day
Software Engineer 0.40 man.day

Table of Contents

1 - Global description
2 - Data associated with a domain name
2.1 - Technical data
2.2 - Administrative data
3 - Full domain name lifecycle overview
4 - Basic create⁄update⁄delete life cycle
4.1 - create
4.2 - update
4.2.1 - technical update
4.2.2 - administrative update
4.2.3 - context update
4.3 - delete⁄restore
5 - Transfer
6 - Renewal and auto-renewal
7 - Grace period and refund
8 - Resources allocated
8.1 - Initial implementation
8.2 - On-going maintenance

------------------------
1 - Global description

Domain names represents the core technical part of the Domain Name System. The lifecycle of a domain name can have both technical impacts, when it relates to technical data associated with the domain name, and administrative impact when related to the registrant of the domain name.

The following diagrams and descriptions will bring detailed answers to the question of the lifecycle of the domain name in regards to both these aspects

------------------------
2 - Data associated with a domain name

To clearly understand the lifecycle of the domain name, we must first give an exhaustive description of the data involved in the various operations to be made.

------------------------
2.1 - Technical data

A domain name is a technical label used for Domain name resolution. To be effective, it is associated with nameservers -server hosting the configuration of the domain name -, IPv4 and IPv6 addresses - to identify on the network servers independently of the DNS, DNSsec signature information - delegation signer and cryptographic algorithm used-.
Less directly related to the technical basic configuration are :
* = clientHold = label : relates to the DNS or not DNS-publication status of the domain name.
* = auth_info = : a protection code linked with the domain and used by the owner to unlock some operations
* = client*Prohibited = : a list of status activated by the registrar to lock the domain name and prevent some operations
* = server*Prohibited = : a list of status activated by the registry service provider to lock the domain name and prevent some operations

------------------------
2.2 - Administrative data

A domain name has to be managed by his owner. Therefore it comes associated with a list of operational and administrative contacts that can be used to get in relation with the domain name owner or technical staff. The most important are administrative contact, technical contact, billing contact, and of course registrant contact. The last contact object is the registrar object which shows which registrar is in charge of domain name operations at the registry level.

Both these administrative and technical data are modified and used in the lifecycle and we will now describe this in detail.

------------------------
3 - Full domain name lifecycle overview

We have chosen to illustrate the registration lifecycle through a state diagram
This state diagram is joined as a separate file.

[see attached diagram Q27_3_global_lifecycle.pdf]
Diagram : Global Lifecycle
Description : Considering the wide range of the states and transition, the choice has been made to present a linear scenario going through all available operations. In this scenario, impact on registrar objects, registrant objects, domain objects, host objects are described at each step. Also statuses and forbidden operations at each step are indicated.
The following domain states have been introduced to describe the lifecycle major steps :
* registered : the domain name is registered, published in the Registration Data Directory Services (RDDS) but not in the DNS (clientHold label is set or there is no host information)
* active : the domain name is registered, published in the RDDS and in the DNS
* redemption : the domain name is registered, published in the RDDS but not in the DNS. It will be - deleted if no action is taken by the registrar.
* locked : specific operations as transfer or delete have been forbidden by the registrar.
Impact on expiry dates has also been indicated though adequate formulas.

All aspects of the registration lifecycle are covered by standard Extensible Provisioning Protocol (EPP) RFCs and the EPP implementation is described in Question 25 (EPP).

------------------------
4 - Basic create⁄update⁄delete life cycle

The basic life cycle is described below without explanation of add grace period. The behavior of add grace period is described in chapter 7.

------------------------
4.1 - create

A domain name is created through a standard EPP domain:create command.
Administrative data linked with the creation are registrant contact, admin contact and technical contact, period before renewal.
Technical data linked with the creation are nameservers host objects, IP address for glue records, auth_info code.
The state of the domain name is REGISTERED if no host objects have been filled.
The state of the domain name is ACTIVE if host objects have been filled.
The state of the domain name can exceptionally be PENDING during the operation if a technical issue makes it asynchronous.
Otherwise this operation is real time and there is no delay elements to be considered.

Elements needed to create a domain are contacts (mandatory), host objects (optional) and auth_code (mandatory).
It can then be managed through domain:update commands.

------------------------
4.2 - update

domain:update commands enables a wide range of fields updates

------------------------
4.2.1 - technical update

Part of the fields of the update enables to update technical configuration. It enables nameserver, IP address, and dnssec options management. It is also used to remove a technical configuration..

The state of the domain name is REGISTERED if no host objects have been filled or have been removed.
The state of the domain name is ACTIVE if host objects have been filled.
The state of the domain name can exceptionally be PENDING during the operation if a technical issue makes it asynchronous.

------------------------
4.2.2 - administrative update

It is used to freely modify the various contacts linked with the domain name : administrative, technical, billing, and registrant contact.
The state of the domain name is not modified if only these fields are used.
The state of the domain name can exceptionally be PENDING during the operation if a technical issue makes it asynchronous.

------------------------
4.2.3 - context update

It is used by the client to modify status of the domain name and⁄or to modify the auth-info code linked with the domain name.
The status that can be changed are the following : clientHold, clientTransferProhibited, clientUpdateProhibited, clientDeleteProhibited, clientRenewProhibited.
The clientHold flag enables to remove the domain name from publication temporarily without deleting its technical configuration.
The other client*Prohibited statuses prevent the corresponding operation to be used.
The state of the domain name is REGISTERED if status is updated to clientHOLD.
The state of the domain name is LOCKED if status is updated to clientTransferProhibited.
The state of the domain name can exceptionally be PENDING during the operation if a technical issue makes it asynchronous.

------------------------
4.3 - delete⁄restore

Deletion can be used only by the registrar in charge of the domain name. It brings the domain name in Redemption grace period for a period of 30 days. It can be restored at any time during this period without any changes to the data. Deletion remove the domain name from the DNS publication service.
The state of the domain name is DELETED during redemption period.
The redemption period lasts 30 days. The domain is destroyed at the end of this period and a notification is sent.

------------------------
5 - Transfer

The transfer is described below without explanation of transfer grace period. The behavior of transfer grace period is described in chapter 7.

A transfer can be initiated only by an incoming registrar and using the auth_info that the owner has given him. This standard mechanism acts as a security and associates the triggering of transfer to the acceptance of the owner of the domain.
The transfer operation can be triggered only if the domain is not protected by a clientTransferProhibited lock.

[see attached diagram Q27_5_transfer_lifecycle.pdf]
Diagram : Transfer lifecycle
Description : Transfer operation includes various steps with impact on both outgoing and incoming registrars.

The outgoing registrar receive a transfer notification and can technically accept or reject the registrar change. Rejection can only be done in specific cases described in ICANN consensus policies.
If the outgoing registrar accepts the transfer, the operation is accepted immediately.
If the outgoing registrar does not validate the transfer, the operation is automatically accepted after 5 days.
If the outgoing registrar rejects the transfer, the operation is automatically cancelled and both registrars are notified of the rejection.
When the transfer succeeds, both registrars are notified through their EPP notification queue.

A reverse transfer can be asked by the losing registrar. The documents and cases where this cancellation of the transfer can be asked follow ICANN consensus policies on transfers. In case of disputes, the ICANN TDRP (Registrar Transfer Dispute Resolution Policy) is followed.

The state of the domain name is PENDING during the operation.

------------------------
6 - Renewal and auto-renewal

Domain:renew command is used by the registrar to increase the period of registration. If a domain name is registered for less than 10 years it can be renewed for a period up to 10 years at any time. The expiry date is updated.
The domain:renew command can be sent at any phase of the lifecycle (exception of add grace period is described in next chapter).

The registry lifecycle works with auto-renewal mechanisms. If a registrar do not renew or delete the name when it reaches the expiration date, a one year auto-renew period is added. As for other commands, a grace period is linked with this action (see chapter 7)

[see attached diagram Q27_6_grace_period_renew_autorenew_lifecycle.pdf]
Diagram : Grace Period renew⁄autorenew lifecycle
Description : This renew⁄autorenew lifecycle sum up impact of operations on domain name availability and statuses.

------------------------
7 - Grace period and refund

= Grace period =

The Grace Period mechanism refers to a specified period following an operation or change of status in which the operation may be reversed and a credit may be issued to the Registrar.

= Redemption Grace Period =

The Redemption Grace Period has been described in the delete⁄restore chapter.
During this period, domain name is still registered and can be reactivated through domain:restore command. No specific refund is linked with this period.

= Create - Add Grace Period (AGP) =

The implemented AGP is a five-day period following the domain:create command of a domain name.
The Registrar may delete the domain name at any time during this period and receive a full credit for the registration fee from the Operator. Once a domain name is deleted by the registry at this stage, it is immediately available for registration by any registrant through any Registrar.

= Auto-renew Grace Period =

The auto-renew add grace period is implemented. If during this 45 days period the domain is deleted by the incoming registrar, the ʹdomain:renewʹ command is refunded.

= Renew Grace Period =

The renew grace period is implemented. If during the 5 days period following explicit renew bye the registrar, the domain name is deleted, the renew is then refunded.

= Transfer Grace Period =

The transfer grace period is implemented. If during the 5 days period following a transfer the domain is deleted, the transfer is then refunded.

= AGP Limits Policy =

If too many deletions take place during the AGP from a given registrars, a financial penalty is applied.
The Add Grace Period Limits Policy allows a registrarʹs account to be debited each month for all AGP deletions that exceed the greater of either:
* 50 domain names, or
* 10% of net new adds for the previous month

------------------------
8 - Resources allocated

Four categories of profiles are needed to run the Registry’s Technical Operations : Registry Operations Specialists (I), Registry Systems Administrators (II), Registry Software Developer (III) and Registry Expert Engineers (IV). These categories, skillset and global availability of resources have been detailed in Question 31 (Technical Overview of Proposed Registry). Specific workload for this question is detailed below.

------------------------
8.1 - Initial implementation

The set up of a precise lifecycle implies actions by developers, assisted by a senior staff member expert in internet technologies and RFCs to apply proper configuration for the given TLD. Compliance is strictly tested.

The initial implementation effort is estimated as follows :

Software Developer 1.00 man.day
Software Engineer 1.00 man.day

------------------------
8.2 - On-going maintenance

On-going maintenance on the lifecycle includes mainly integration of new policy rules.
The on-going maintenance effort per year is estimated as follows, on a yearly basis :

Software Developer 1.00 man.day
Software Engineer 1.00 man.day

Table of Contents

1 - Rapid Takedown Policy for Cases of General Malicious Activity
2 - Rapid Takedown Policy for Cases of Phishing
3 - Abuse Single Point of Contact
4 - Prevention of Domain Name Tasting or Domain Name Front Running
5 - Prevention of Domain Name Sniping (Grabbing)
6 - Prevention of Orphaned Glue Records
7 - Preventing Use of Reserved, Invalid, Illegal or Otherwise Unsuitable .BZH Names
    7.1 - Rule Engine
8 - Domain Data Access Control
     8.1 - Prevention of Whois Data Mining
     8.2 - Prevention of Unauthorized Data Modifications
9 - Whois Accuracy
10 - Resourcing plans


The .BZH Registry will establish thorough and effective methods to prevent abuse of .BZH domain names, .BZH registrant data or the associated infrastructure, as well as to mitigate any impact from such abuse (should it occur despite the preventive measures). In order to achieve this, the .BZH Registry is committed to deploy extensive organizational and technical measures. The most salient examples of these measures are described below.


------------------------
1 - Rapid Takedown Policy for Cases of General Malicious Activity

The .BZH Registry is committed to closely collaborate with law enforcement authorities and security agencies in order to take quick action in case a .BZH name is reported to be involved in malicious activity. For this purpose, a ʺRapid Takedown Policyʺ is established that :

 * identifies cases of malicious activity,
 * defines ways for the registry to be notified of such activity (e.g. via a dedicated web site, e-mail address or phone hotline),
 * defines clear and consistent procedures to quickly stop the malicious activity (after the activity was confirmed and impact of the measures has been assessed),
 * defines related service levels (e.g. with respect to the maximum time the registry may take to respond to takedown requests). This time limits will never exceed 14 business days in the case of less urgent cases, and not exceed 24 hours in the most urgent cases such as phishing.
 * defines rules regarding the notification of involved parties (registrant, administrative contact, technical contact, registrar, informant),
 * defines ways to appeal against any measures taken (through the general Eligibility Restrictions Dispute Resolution Procedure as is the case for all appeals against Registry decisions, but with panelists that are specialized in Security and Malicious Conducts).
 * defines how cases covered by the policy need to be documented and reported.  In this context, cases of malicious activity may include (but are not limited to) :
    * wrong, invalid or harmful DNS setup (e.g. pointers to false IP addresses),
    * use of trademarked or otherwise reserved names without proper rights,
    *  use of the domain in actions that affect the stability and security of the Internet (e.g. in Denial of Service (DoS), Distributed Denial of Service (DDoS) attacks or botnets)
    *  use of the domain for the distribution of malware (such as computer viruses, worms, Trojan horses, spyware or rootkits)
    * use of the domain for phishing or spamming
    * use of the domain for spamming (affecting e-mail or other forms of electronic messaging)

Where applicable, the policy includes metrics and thresholds for finding quantitative indications of malicious conduct.

Procedures to stop malicious activity may include (but are not limited to) :

 * notifying the domainʹs sponsoring registrar, specifying a deadline until which the activity needs to be ceased,
 * notifying the domainʹs registrant, administrative or technical contact directly (again specifying a deadline until which the activity needs to have ceased),
 * locking the domain and putting it on hold in order to prevent changes to the domain and to remove it from the .BZH zone (ʺtakedownʺ)
 * deleting the domain name and blocking it from further registration if need be.  Escalation rules (defining which steps are to be taken in which order and conditions for moving on to the next, more drastic measure) are part of the policy.  

Since removing a domain name from the .BZH zone usually has serious consequences (such as rendering web sites and e-mail addresses utilizing the domain name unusable), the .BZH Registry will, in accordance with the policy, exercise extreme caution with regard to any takedown decision.

At the same time, the .BZH Registry is aware that malicious activity potentially affects a large number of Internet users, which sometimes warrants drastic measures. The Rapid Takedown Policy aims at finding appropriate measures, taking the interests of all involved parties into consideration.  The Rapid Takedown Policy will be announced to both .BZH registrars and .BZH registrants and be part of the Registry-Registrar Agreement (RRA) and the .BZH registration terms.


------------------------
2 - Rapid Takedown Policy for Cases of Phishing

The .BZH Registry will work closely with French-based CERTs to develop an Anti-Phishing-specific simplified procedure. The goals will be to :

 * get all 7 French CERTs (at least, but open to other CERTs) accredited as Authorized Intervenors
 * develop criteria and checklist for domain names eligible for Rapid Suspension
 * develop secured communications method between Authorized Intervenor and Registry, including Affidavit form

Names reported by Authorized Intervenors will be suspended in less than 4 hours. This system should expand to a global Authorized Intervenors list. In this regard, the .BZH Registry will work with the Antiphishing Working Group in order to develop and complete their proposed Accelerated Take Down proposal, which is still in beta stage.


------------------------
3 - Abuse Single Point of Contact  

To ensure that the .BZH Registry gets notified of any cases of abuse as quickly and as easily as possible, an area of the public web site operated by the .BZH Registry for the .BZH TLD will be dedicated to the reporting of such cases.

The respective web pages establish a single point of contact where abuse cases can be reported via a simple web form. An e-mail address and a phone number will also be provided as alternative means of communication.  

Every case reported will raise a high-priority ticket within the .BZH support staffʹs ticket system, examined immediately and treated in accordance with the Rapid Takedown Policy (and the other Compliance Procedures related to Eligibitly and Use, and IP Claims).


------------------------
4 - Prevention of Domain Name Tasting or Domain Name Front Running

The life cycle of a .BZH domain name includes a 5-day Add Grace Period (AGP) during which a newly created domain name may be deleted with a refund of the domain fee. This is common practice and corresponds to the policies of almost all existing generic top level domains.

However, in the past the Add Grace Period has been abused for practices such as domain name tasting and domain name front running.

Domain name tasting means that domains were created simply for the purpose of testing whether revenue can be generated by e.g. creating a web page with advertisements for the domain; if this was found feasible within the first few days, the domain was retained, otherwise it was deleted within the add grace period for a full refund, i.e. the domain was ʺtastedʺ for potential revenue without any payment to the registry.

Domain name front running refers to the practice of pre-registering domain names somebody has merely expressed interest in (e.g. by searching for them on the Whois web frontend of a registrar) with the purpose of reselling the domain to that person (at an inflated price) afterwards; again, the Add Grace Period has been abused for this purpose since a registrar could do that without any cost (if the unsold domain was deleted before the end of the add grace period).

In 2008, ICANN introduced the so-called ʺAGP Limits Policyʺ (http:⁄⁄ www.icann.org⁄en⁄tlds⁄agp-policy-17dec08-en.htm) which addresses these and other issues resulting from the Add Grace Period. The .BZH TLD, will fully implement this policy by restricting Add Grace Period refunds to registrars according to the limits specified by the policy. At the end of every month, the registration systemʹs billing module will determine every registrarʹs net domain adds and check whether the add grace period refunds granted during that month exceed the permissible number according to the policy; if this is the case, additional charges to the registrarʹs account will be initiated to effectively revert the excessive refunds.

Any exemption requests by registrars, whether they were granted (as permitted by the policy) or rejected, are documented, and such documentation will be maintained and made available for review by ICANN on request. The registryʹs monthly report to ICANN will contain per-registrar information on the granted add-deletes, as well as additional columns regarding the exemption requests.

The related report columns are (with column header names in parentheses):

 * number of AGP deletes (ʺdomains-deleted-graceʺ)
 * number of exemption requests (ʺagp-exemption-requestsʺ)
 * number of exemptions granted (ʺagp-exemptions-grantedʺ)
 * number of names affected by granted exemption request (ʺagp- exempted-domainsʺ)
 

------------------------
5 - Prevention of Domain Name Sniping (Grabbing)

Domain name sniping (also known as ʺgrabbingʺ) is another common abuse pattern; the name refers to the practice of trying to re-register potentially interesting domain names immediately after they are deleted (sometimes by accident, or because a registrant failed to renew the domain with his registrar in time).

Starting in 2002, registries have started to implement an ICANN proposal, the so-called ʺRedemption Grace Periodʺ (RGP, http:⁄⁄www.icann.org⁄en⁄registrars⁄redemption-proposal-14feb02.htm). The proposal recommends to introduce a 30-day period after a nameʹs deletion during which the name is removed from the TLD zone (in order to give the registrant the chance to take notice
of his nameʹs deletion) but is still eligible for being restored by the previous registrar⁄registrant.

Supporting the RGP significantly reduces chances for domain grabbers to obtain inadvertently deleted domains, since a registrant gets 30 days to notice the mistake and restore the domain before it becomes available for re-registration.

The .BZH Registry supports the Redemption Grace Period as proposed by ICANN and implements it in full compliance with RFC 3915 (ʺDomain Registry Grace Period Mapping for the Extensible Provisioning Protocol (EPP)ʺ).

------------------------
6 - Prevention of Orphaned Glue Records

According to the definition found in the ʺSSAC Comment on the Orphan Glue Records in the Draft Applicant Guidebookʺ (http:⁄⁄www.icann.org⁄en⁄ committees⁄security⁄sac048.pdf), a glue record becomes an ʺorphanʺ when the delegation point NS record (the ʺparent NS recordʺ) that references it is removed while retaining the glue record itself in the zone. Consequently, the glue record becomes ʺorphanedʺ since it no longer has a parent NS record. In such a situation, registrars and registrants usually lose administrative control over the record, and the recordʹs attribution to a certain registrar may become unclear, which makes it a potential vector for abuse.

The glue record policy in effect for the .BZH TLD avoids this situation entirely by disallowing orphan glue records altogether. This corresponds to policy #3 mentioned in section 4.3 (page 6) of the SSAC document mentioned above. The technical implementation within the Registry and its associated zone generation process ensures this by the following measures:

 * A host object within the .BZH TLD (like e.g. ʺns.example.BZHʺ) cannot exist without its parent domain (ʺexample.BZHʺ). Any attempt to create the host ʺns.example.BZHʺ will be rejected by the SRS if the domain ʺexample.BZHʺ doesnʹt already exist or isnʹt sponsored by the registrar creating the host. Likewise, the domain ʺexample.BZHʺ cannot be deleted by the registrar if subordinate hosts like ʺns.example.BZHʺ still exist. These subordinate hosts have to be deleted before the domain may be deleted; if such hosts are used in delegations for other .BZH names, these delegations in turn have to be removed before the host may be deleted.
 * If a domain name is put on hold (e.g. as a consequence of the Rapid Takedown Policy described above), this not only means that the delegation for the name itself is removed from the zone; it also means that any occurrences of NS records referencing a name server that is subordinate to the domain are also removed from other .BZH domains, along with any accompanying glue records. The same of course holds true should the domain name have to be deleted entirely by the registry.

Consequently, no glue records can exist for a certain domain in the .BZH zone after that domain is put on hold or deleted as part of abuse prevention or mitigation procedures.

It should be noted that this policy may lead to other domains (not directly involved in the abuse case) being affected by the takedown if they were delegated to a name server subordinate to the offending domain. Depending on their overall DNS architecture, such domains may become unreachable or less reachable after the delegation point is removed. While this could in theory be avoided by a less rigid orphan glue record policy, the overall benefit of adopting the strict policy described above is deemed higher than the potential damage to domains using an DNS infrastructure depending on an offending domain name.


------------------------
7 - Preventing Use of Reserved, Invalid, Illegal or Otherwise Unsuitable .BZH Names

As laid out in the answer to Question 29 (Rights Protection Mechanisms), the .BZH Registry takes extensive measures to protect the legal rights of others (such as trademark holders) with regard to .BZH domain names.

In addition, the .BZH Registration System provides general means to make sure that no .BZH names are registered which are for other reasons deemed invalid, reserved, illegal, offensive or unsuitable.


     ------------------------
     7.1 - Rule Engine

For the most part, this is achieved by the deployment of a complex rule engine that checks each registered name at the time of registration for compliance with a configurable set of rules. Among other things, these rules will include :

= Standard EPP checks =

a first set of tests is implemented in compliance with standards

 * RFC 5733, the Extensible Provisioning Protocol (EPP) Contact Mapping, requires contact data to contain a name, a city, a country code and an e-mail address in order to allow or perform a syntactically complete EPP request
 * RFC 5731, the Extensible Provisioning Protocol (EPP) requires domain object to have at least one associated status value, Date and time attribute values to be represented in Universal Coordinated Time (UTC) using the Gregorian calendar and Validity periods to be measured in years or months with the appropriates units specified using the ʺunitʺ attribute.
 * RFC 5732, the Extensible Provisioning Protocol (EPP) requires host object to have at least one associated status value

= Additional checks =

the following syntactic checks are implemented

 * a test to ensure that the domain name has the proper number of labels (which is two for a traditional registry that allows only second level domains to be registered),
 * a test to ensure that no hyphens occur in position 3 and 4 of any of the domainʹs U-labels (to protect ʺxn--ʺ and future ACE prefixes),
 * a test to disallow hyphens at the beginning or end of the name,
 * a test to find ASCII characters which are neither a letter, nor a digit or a hyphen,
 * a test to find invalid IDN characters, i.e. characters not contained in any of the support IDN character tables
 * a test to validate IP address format using the following scheme :
    * 〈ipv4-addr〉        [1-255](\.[0-255]){3,3}
    * 〈ipv6-addr〉        [a-fA-F0-9:]+(:〈ipv4-addr〉)?
 * a test to validate telephone and mail format using the following scheme (with specific tests for fr numbers):
    * 〈num tel〉        \+[1-9][0-9]{0,3}〈sp〉[1-9]([〈sp〉\.-]?[0-9])+
    * 〈num tel fr〉        \+33〈sp〉[1-9]([〈sp〉\.-]?[0-9]){8}
 * 〈e-mail〉 (([^\s\(\)\[\]\.\\〉〈,;:ʺ@]+(\.[^\s\(\)\[\]\.\\〉〈,;:ʺ@]+)*)|(ʺ[^ʺ@\\\r\n]+ʺ))@〈label〉(\.〈label〉)*

= Additional checks =

the following semantic checks are implemented

 * a test to disallow reserved names if authorisation code is not present
 * a test to disallow registry reserved names if authorisation code is not present
 * a test to disallow ICANN reserved names
 * a test to disallow otherwise reserved or unsuitable names
 * a test to ensure that at least one address element is given

For the tests checking for reserved names, custom lists of labels can be conveniently maintained by the registry to define the disallowed names for each category.  


------------------------
8 - Domain Data Access Control  

One important point of attack that may lead to abuse of .BZH domains and their associated data is the unauthorized or excessive access to data stored within the .BZH repository. This applies to both read access (e.g. via public interfaces such as the port 43⁄port 80 Whois) and write access (such as registrar interfaces like EPP or the web-based Control Panel). The measures taken in the .BZH TLD to properly restrict access are laid out in the following sub-sections.

     ------------------------
     8.1 - Prevention of Whois Data Mining

The port 43⁄port 80 Whois interfaces grant public access to domain, host and contact data. As such they are a potential target for data mining, i.e. the retrieval of large amounts of postal or e-mail addresses for e.g. the purpose of advertising.

As explained in detail in the answer to question 26 (Whois), the Whois implementation provided by the .BZH Registration System prevents such data mining attempts, most importantly by :

 * rate-limiting access to all Whois interfaces (for machines not whitelisted for unlimited access),
 * requiring web interface users to pass a CAPTCHA before access is granted and
 * providing full support for contact disclosure flags as specified in RFC 5733, the Extensible Provisioning Protocol (EPP) Contact Mapping, giving registrants control over the contact fields they want to disclose in the Whois. In this respect, the system is configurable and allows restricting the use of EPP contact disclosure settings via rules defined by specific registry policies or legal requirements.

     ------------------------
     8.2 - Prevention of Unauthorized Data Modifications

Domain data within the .BZH Registry is exclusively provisioned by registrars, i.e. registrants have no direct write access to their data within the repository; all their modifications have to be done via the registrar sponsoring the respective domain. In this constellation, registrants needs to trust their registrar and will expect that the management of domain is conducted in a diligent and correct manner.  This means that the registryʹs interfaces used by registrars need to be secured in order to only allow the sponsoring registrar of a domain (and nobody else) to modify domain data.

The EPP interface provided by the .BZH Registration System does this by :
 * requiring SSL⁄TLS on the transport layer,
 * requiring a strong EPP password (minimum length, mandatory digits and non-alphanumerical characters),
 * requiring changing the EPP password on a regular basis,
 * requiring registrars to supply lists of IP addresses or subnets from which exclusive access will be granted,  
 * requiring registrars to use SSL client certificates known to and trusted by the registry, thus providing an additional means of authentication beyond the EPP password.

Likewise, the web-based Control Panel :

 * requires SSL⁄TLS on the transport layer,
 * requires registrars to log in with a user name and password (for which the same rules regarding minimum length, mandatory digits and non- alphanumerical characters apply),
 * requires changing the password on a regular basis,
 * requires registrars to supply lists of IP addresses or subnets from which exclusive access will be granted,
 * requires registrars to install SSL client certificates known to and trusted by the registry in their web browsers, thus providing an additional means of authentication beyond the web password.  

------------------------
9 - Whois Accuracy  

Since .BZH is operated as a so-called ʺthick registryʺ, the .BZH Whois displays information about the registrant, as well as the administrative, technical and billing contacts of every .BZH domain. In cases of malicious or abusive activity involving a .BZH domain, this Whois contact information usually is the first and most important source of information, e.g. for law enforcement authorities, to determine the people or organizations responsible for the domain in a timely manner. Consequently, it is deemed very important to maximize the accuracy of contact information stored in the registry repository.  


The .BZH Registry is therefore committed to take diligent measures to promote Whois accuracy, including (but not limited to) the following:

 * Contact data completeness policy: While RFC 5733, the Extensible Provisioning Protocol (EPP) Contact Mapping, merely requires contact data to contain a name, a city, a country code and an e-mail address for a syntactically complete EPP request, the .BZH TLD policy for contact data mandates the specification of at least one address line (street), a voice phone number and a postal code in addition. This means that, in addition to the XML schema validation conducted by the .BZH SRS for every EPP request received from the registrar (which ensures the presence of all RFC-mandated contact data), the SRS also requires these essential fields to be present and will reject requests lacking them with a ʺparameter value policy errorʺ message. The validation done by the SRS also goes beyond validating against the EPP XSDs with respect to field content. For instance, contact e-mail addresses are required to contain an ʹ@ʹ character and a valid domain name; this is not mandated by the XSDs specified in RFC 5733.

 * WDRP auditing: In 2003, ICANN adopted the so-called ʺWhois Data Reminder Policyʺ (WDRP, http:⁄⁄www.icann.org⁄en⁄registrars⁄wdrp.htm) which obliges ICANN-accredited registrars to send yearly Whois data reminder notices to registrants. These notices contain the Whois data currently on file for the respective domain, as well as instructions  for the registrant about ways to correct the data if required. While the .BZH Registry does not intend to replicate this reminder procedure on the registry level, it will establish an auditing process that monitors the WDRP activities of .BZH registrars to make sure that WDRP responsibilities are honoured.


------------------------
10 - Resourcing plans


The .BZH  back-end registry services provider (AFNIC), provides the following resources:

= Initial Implementation =

Thanks to the experience and prior investment by its Registry Back-end Service Provider (AFNIC), the .BZH Registry already supports the above mentioned technical abuse prevention and mitigation measures. No additional engineering is required for these, nor are additional development resources needed.

= Ongoing maintenance = 

In support of the Registry Operator’s staff allocated to this function, AFNIC will have specially trained support staff available to assist in the implementation of potential verifications and takedown procedure for the prevention and resolution of potential abuse. Given the scale of the .BZH, we estimate that this would require no more than 10 man days per year of AFNIC anti-abuse support staff.


Table of Contents

1 - Support and interaction with the Trademark Clearinghouse
2 - Sunrise: Criteria; Conflict Resolution; Mechanisms
3 - Compliance Mechanisms. Ongoing Registrations
4 - Dispute Resolution (and Prevention) Mechanisms involving Rights Protection
     4.1 - Trademark Post-Delegation Dispute Resolution Procedure (PDDRP)
     4.2 - Registration Restrictions Dispute Resolution Procedure (RRDRP) 
     4.3 - Uniform Domain Name Dispute Resolution Policy (UDRP)
     4.4 - Uniform Rapid Suspension System (URS)
     4.5 - Trademark Claims
5 - Technical Implementation details
     5.1 - Sunrise
          5.1.1 - Sunrise EPP Extension Support
          5.1.2 - Sunrise Registration Life Cycle Support
          5.1.3 - Trademark Clearinghouse Support
          5.1.4 - Support for Multiple Applications for the Same Domain Name
          5.1.5 - Issue System
     5.2 - Trademark Claims
6 - Resourcing Plan
     6.1 - Initial Implementation
     6.2 - Ongoing maintenance



The .BZH registry is committed to ensure that it fully complies and meets or exceeds the requirements of ICANN in terms of security, stability and resiliency, malicious abuse issues, and rights protection in relation to the expansion of the generic Top Level Domain name space by devising and implementing mechanisms in line with ICANN’s Consensus Policies and Temporary Policies.  The Registry will provide for an environment for .BZH where opportunities for abuse and malevolent conduct will be significantly reduced.  To this end, the .BZH registry will, inter alia, implement and adhere to all rights protection mechanisms that may be mandated from time to time by ICANN, pursuant to Specification 7 of the Draft New gTLD Agreement.

The .BZH back-end registry service provider, AFNIC, has extensive knowledge, awareness and understanding of existing rights protection mechanisms designed by ICANN and it is a core objective of the .BZH registry to guarantee effective and timely implementation of said mechanisms. The registry will implement mechanisms designed to prevent abusive registrations, and  identify and address the abusive use of registered domain names on an on-going basis.

The Registry Operator has closely followed ICANNʹs policy development in relation to the adequate and effective protection of the legal rights of trade mark owners in the new gTLD environment including the work of the Implementation Recommendation Team (ʺIRTʺ) formed by ICANNʹs Intellectual Property Constituency in accordance with the 6 March 2009 ICANN Board resolution at the request of the community seeking solutions for potential risks to trade mark holders in the implementation of new gTLDs.

As the .BZH registry back-end service provider, AFNIC is at the forefront of innovation in the domain name industry and has appointed for that purpose a committee of industry experts and academics (the Scientific Council) to help AFNIC to carry out its mission of innovation, security and high levels of service.  AFNIC has contributed to the creation and the implementation of dedicated rights protection mechanisms for the ccTLDs AFNIC is responsible for and has a dedicated Legal and Registration Policy Department with pertinent skills and experience in the field of rights protection mechanisms to prevent abusive registrations and identify and address the abusive use of registered names on an on-going basis.

AFNIC will seek to deploy this experience in the .BZH with a view to ensuring effective, timely and sufficient protection of the rights of others.

------------------------
1 - Support and interaction with the Trademark Clearinghouse

The .BZH registry will ensure that it fully supports and interacts with the Trademark Clearinghouse, a central repository for information to be authenticated, stored, and disseminated, pertaining to the rights of trade mark holders.

The Registry Operator will use the Trademark Clearinghouse to support its initial launch period rights protection mechanisms which will consist of, at a minimum, a Sunrise process and a Trademark Claims service.  


------------------------
2 - Sunrise: Criteria; Conflict Resolution; Mechanisms

The .BZH registry will implement a Sunrise process for registration under .BZH for a period of 3 months subject to the .BZH sunrise eligibility requirements (SERs) . The Sunrise Registration Process will incorporate a Sunrise Dispute Resolution Policy (SDRP).

The Sunrise phase will take prior rights into account. A priority order will be given in case of multiple requests, taking into account the interests of the community:
 * Institutions that are representative of the linguistic and cultural community
    * Public institutions
    * Cultural and linguistic associations
 * Prior rights related to intellectual property
    * Trademarks with legal value in Brittany
    * Other registred distinctive signs with legal value in Brittany
 * Individual members of the cultural and linguistic community (booking of family name) who are also members of the association www.bzh.

These registrants will be allowed to apply for domain names directly related to their prior rights.

The application procedure will be automated to ensure a secure and transparent procedure. A WHOIS will be set up during the sunrise phase to allow participants to keep track of applications and enforce their prior rights in the event.

Each application will be individually validated against both the general requirements of .BZH registration policies and the specific requirements of each Category or Sub-Category. Priority will be differentiated by Category (and Sub-category) each one having absolute priority over the next one.

Within each Category (and Sub-category) all validated applications will be deemed to carry the same rights.

Priorities should solve most of multiple applications. In case priorities cannot provide a resolution, the following procedures will be applied (in that order): agreement between registrants, random selection, mediation, arbitration, auction.

An agreement between registrants means that one registrant will keep the domain name while the other or others will withdraw their application (and get a refund accordingly).

Random selection is optional: the contenders must unanimously accept to use the procedure.

In case of disagreement, mediation then arbitration would then be implemented at the expense of registrants. The registry will charge any cost borne by the procedure.
Mediation will be directly handled by the Registry. Arbitration will be carried out by an independent and experienced Mediation and Arbitration Authority. In that case, no application for the same name from the same or lower rank in Sunrise priority will be approved, pending the decision.

An auction will be made if all others means of resolution have failed.

The landrush phase will be running in parallel during the Sunrise and will be open to all eligible applicants (see question 20) for domain names not subject to prior rights, on a first-come, first-served basis. The domain names registered during this period will be activated at the end of the 3-month phase.

The registry will also offer the Trademark Claims mechanism as provided by the Trademark Clearinghouse. This service will be provided not just for the Sunrise period, but also afterwards, during the Ongoing Registration Phase.


------------------------
3 - Compliance Mechanisms. Ongoing Registrations

Once in Ongoing (live) Registration mode, the .BZH Registry will perform ex-post validation based on Whois data and use of the domain name against the Registrations Policies.

Checks will be performed by the registry staff, in particular the person in charge of legal issues, both based on complaints and ex-officio, on statistically targeted random checks. Registry will start with 50 such random cases per week, and will adapt the practices according to the experience gained (it is expected that the number will decrease over time, as reputation and enforcement will make compliance easier over time).

Checks will be carried both on compliance with .BZH policy and at the same time on registrant data accuracy.

In case the registry staff discover a problem, either on policy compliance or on data accuracy, they will escalate the issue to the members of the board and the registrant will be contacted to clarify⁄correct the situation. If not solved in due time (30 days), the name will be put on registry hold for 30 additional days. Unless the situation is corrected by this deadline, the name will be removed.


------------------------
4 - Dispute Resolution (and Prevention) Mechanisms involving Rights Protection

     ------------------------
     4.1 - Trademark Post-Delegation Dispute Resolution Procedure (PDDRP)

The .BZH registry is committed to prevent the occurrence of the type of circumstances the PDDRP is designed to address.  The registry completely understands the PDDRP mechanism and its rationale. and is fully committed to comply with the PDDRP and to implement decisions rendered under the PDDRP on an on-going basis and to fully cooperate in this respect.

     ------------------------
     4.2 - Registration Restrictions Dispute Resolution Procedure (RRDRP) 

The .BZH registry is committed to prevent the occurrence of the type of circumstances the RRDRP is designed to address.  The registry completely understands the RRDRP mechanism and its rationale. and is fully committed to comply with the RRDRP and to implement decisions rendered under the RRDRP on an on-going basis and to fully cooperate in this respect.

     ------------------------
     4.3 - Uniform Domain Name Dispute Resolution Policy (UDRP)

Whilst the role of registry operators is rather limited under the UDRP as responsibility for implementation is primarily placed on registrars, the .BZH registry is committed to fully cooperate so as to ensure the implementation of all UDRP decisions.

The UDRP was adopted in 1999 by ICANN as a means of providing trade mark owners with a relatively fast and cheap alternative dispute resolution mechanism to tackle cases of abusive use of their trade marks in a domain name.  The Registry Operator will monitor and maintain a record of all UDRP decisions involving a domain name registered under the .BZH.

As the .BZH registry back-end registry service provider, AFNIC has implemented alternative dispute resolution procedures similar to the UDRP, including the so-called SYRELI procedure (Système de Résolution des Litiges), introduced on 21 October 2011 which applies to disputes involving domain names registered within the ccTLDs under the responsibility of AFNIC.  This procedure is administered by AFNIC itself and illustrates how the .BZH registry back-end service provider is at the forefront of the protection of rights of third parties in the domain name space.

While compliance with the UDRP as it is now lies on registrars’ side, .BZH is not willing to accept non-compliant registrars preventing its implementation.  In addition to ICANN-applied sanctions, .BZH will suspend the ability to register new domain names under .BZH for those registrars failing to implement UDRP decisions.

In order to do this, .BZH will implement a specific complaints form for successful UDRP complainants facing non-cooperative registrars for .BZH names. Upon evidence of non-compliance the offending registrar would be prevented from registering any new .BZH name for three months after effective compliance the first time, and six months in case of repeated failures to comply. This measure is more effective and less harmful for the end users than termination, and will be included in the .BZH RRA.

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     4.4 - Uniform Rapid Suspension System (URS)

In light of the anticipated expansion of the Domain Name System with the future delegation of new Top Level Domains, The IRT proposed in its Final Report of 29 May 2009 a new mechanism to tackle those ʺcases in which there is no genuine contestable issue as to the infringement and abuse that is taking placeʺ.  This new rights protection mechanism was retained by ICANN and the .BZH registry is fully aware of all requirements of the URS and will implement decisions under the URS on an on-going basis and in a timely fashion.

Within 24 hours of receipt of the Notice of Complaint from the URS Provider by email, the .BZH registry will lock the disputed domain name thereby restricting all changes to the registration data, including transfer and deletion of the disputed domain name. In such instance, the disputed domain name will continue to resolve. Upon locking the disputed domain name, the Registry Operator will immediately send a Notice of Lock to the URS Provider.

The obligations placed on registry operators by the URS also include an obligation to suspend a disputed domain name immediately upon receipt of a determination in favour of a complainant, so that the disputed domain name remains suspended for the reminder of the registration period and does not resolve to the original website.

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     4.5 -Trademark Claims Service

As the .BZH registry back-end registry service provider, AFNIC has experience of similar mechanisms through its use of the Clearing House for Intellectual Property (CHIP) which it appointed to manage the Claims Mechanisms for several of its ccTLDs (.pm, .re, .tf, .wf and .yt).  When a domain name is registered in one of said ccTLDs that corresponds to a trade mark in the CHIP database, an automatic notification is sent to the trade mark owner registered in the CHIP and, provided that the email address of the domain name registrant or administrative contact is available, an additional notification will be sent to these email addresses as well.

This experience will prove very pertinent in the implementation of the Trademark Claims service for .BZH.

As noted above, .BZH intends to extend the Trademark Claims services beyond the mandatory Sunrise period, and into the Ongoing Registration phase. The purpose of this service is to provide clear notice to a prospective registrant of the scope of a particular trade mark ownerʹs rights in order to minimize the chilling effect on registrants (Trademark Claims Notice).

The .BZH registry will comply with all requirements set out by ICANN in relation to the Trademark Claims service and described in clause 6.1 of the Schedule relating to the Trademark Clearinghouse of the New gTLD Applicant Guidebook in its version of 11 January 2012 or in any subsequent version published by ICANN.


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5 - Technical Implementation details

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     5.1 - Sunrise

The .BZH Shared Registration System (SRS) fully supports the requirements of the above mentioned Sunrise policy and phases via features described in this section.

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          5.1.1 - Sunrise EPP Extension Support

The system supports an EPP extension for submission of trademark data along with domain applications during launch phases such as Sunrise. Please refer to the answer to question 25 (Extensible Provisioning Protocol) for more information about the extension.

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          5.1.2 - Trademark Clearinghouse Support

The .BZH Shared Registration System (SRS) is prepared for accessing APIs of the Trademark Clearinghouse in order to validate the trademark information submitted by the registrar during Sunrise. In addition, the system also contains provisions to make use of the Trademark Clearinghouse APIs for providing a Trademark Claims Service (see below for more information on this service).
Since Trademark Clearinghouse Service Providers have not been assigned by ICANN at the time of writing, the concrete technical specifications for these APIs are not yet known. While basic provisions have been made in the .BZH Shared Registration System (SRS), the details will therefore have to be finalised once the Service Providers have been announced. As described below, respective developer resources are allocated to perform this task.

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          5.1.3 - Support for Multiple Applications for the Same Domain Name

The .BZH Shared Registration System (SRS) is designed to maintain multiple domain objects representing the same domain name at a given point in time. This feature is required to store multiple applications for the same name during launch phases like Sunrise.
To distinguish between the various applications of the name in the database (as well as in external APIs), each application is assigned a unique domain ID. These domain IDs are returned to registrars in the responses to domain applications via EPP and may subsequently be used, among other things, to inquire an applicationʹs review status. Also, review results are reported back to registrars via poll messages carrying the unique domain ID. Registrars can utilize the ID to clearly associate results with their applications.

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          5.1.4 - Issue System

When manual review of Sunrise applications is required, this typically involves a specific support team workflow that, among other things, consists of
 * storing application data in a database,
 * making application data available to the support staff via a web interface back office tool (BO)
 * assigning the task of reviewing applications for a certain domain name to a specific support member (for the purpose of clear responsibilities),
 * having the application reviewed by the assigned person, who in the process may
 * request additional information or documentation from the registrant,
 * adds such documentation, as well as comments concerning the review, to the application,
 * make a decision about the applicationʹs outcome or
 * forward the task to a different support person with better insight or higher decision privileges (who may then make the final decision).

To support this workflow, the .BZH Shared Registration System (SRS) is equipped with a built-in Issue System integrated in its Back-Office (BO) that offers registry personnel a convenient web interface to review domain name applications and approve or reject them accordingly.

The Issue System
 * offers an SSL-secured web interface accessible by .BZH registry staff only;
 * allows searching for applications by various criteria (e.g. domain name or current workflow⁄approval state);
 * allows a registry support person to find newly submitted or otherwise unassigned applications and take responsibility for them;
 * offers a two-level review workflow that allows the delegation of preselection tasks to the first level support staff, after which a final decision - if still required - can be made by second level personnel;
 * conveniently displays all application details, including registrant information, the supplied trademark information, as well as the results of the verification of that trademark data with the Trademark Clearinghouse;
 * fully tracks and documents application status and history, allowing for a complete audit in case of legal inquiries and
 * is fully integrated with the registry backend, i.e. it automatically notifies the SRS about the reviewersʹ decisions and immediately activates the respective domain in case of an approval. The Issue System also triggers the creation of appropriate EPP poll message in order to keep registrars
informed about the outcome of their applications.

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     5.2 - Trademark Claims Service

As stated above, beyond the requirements set forth by ICANN in Specification 7 of the Registry Agreement, the .BZH Registry will implement a continuous Trademark Claims Service to ensure that even after Sunrise, registrants are notified whenever their registered domain name potentially violates a trademark holderʹs rights as stored in the Trademark Clearinghouse. Likewise, the service makes the trademark holder aware of any domain registrations that potentially infringe on his trademarks registered with the Trademark Clearinghouse.

For the purpose of implementing this service, the .BZH SRS will interconnect with the API provided by the Trademark Clearinghouse Service Provider once its details are developed and publicized by ICANN.

When a match of a registered name is found via the API provided by the Trademark Clearinghouse, the Trademark Claims Service is supposed to provide clear notice to a prospective registrant of the scope of the mark holderʹs rights. The registrant will in turn be required to provide statement that
 * he received notification that the mark is included in the Trademark Clearinghouse,
 * he received and understood the notice and,
 * his registration and use of the requested domain name will not infringe on the rights that are subject of the notice.

The registrant will be directed to the Trademark Clearinghouse Database information referenced in the Trademark Claims Notice to enhance understanding of the Trademark rights being claimed by the trademark holder. Also, if a domain name is registered in the Clearinghouse, the Registry will, through an interface with the Clearinghouse, promptly notify the mark holders(s) of the registration after it becomes effective.


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6 - Resourcing Plan
The .BZH registry, have an adequate level of resources on hand and committed to carry out the implementation of all rights protection mechanisms set out in this response to answer 29.

The .BZH registry back-end service provider, AFNIC, has a substantial knowledge, awareness and experience of targeted and pragmatic rights protection mechanisms and will deploy this experience to (1) prevent abusive registrations, and (2) identify and address the abusive use of registered domain names on an on-going basis.

The .BZH registry considers training to be a major focus of its human resources management policy. It therefore applies an ambitious training policy in line with its strategy, with developments in domain name services and with technology.  The Registry Operator  is committed to the development of the skills of its employees and the promotion of their efficiency and adaptability by providing training to its employees in order to ensure the most efficient implementation of all right protection mechanisms.

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     6.1 - Initial Implementation

Thanks to the experience and prior investment by its Registry Service Provider (AFNIC), the .BZH Registry already supports the above mentioned functions and their support systems.

One aspect to be considered for resource planning is the Registry systemʹs connection to the Trademark Clearinghouse; since the involved API isnʹt fully defined at the time of writing, some software development will have to be done in order to integrate the Clearinghouse into the sunrise workflow, as well as to incorporate it into the designated Trademark Claims Service. It is estimated that a Software Developer will be allocated to work 10 man.day on the development of this feature.

Staff that are already on hand will be assigned this work as soon as ICANN releases the relevant technical specifications.

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     6.2 - Ongoing maintenance

The operation of the above mentioned mechanisms will be ensured by a team of highly experienced individuals with a distinct track record in handling dispute and managing TLDs in a manner that very significantly minimize conflict. These individuals have learned directly for launch management and dispute resolution around the .FR TLD.

This team will be composed of administrative and expert-level staff for respectively handling and advising on issues and cases. Their skill set will primarily be made of administrative and legal training, as well as domain name policy expertise.

Two phases need to be distinguished in terms of resourcing plan :
 * for the first 3 months (duration of the Sunrise and Landrush period) we estimate that - exceptionally -  4 FTE   will be needed
 * after the finalization of the sunrise and for the longer term ongoing operations of the TLD, we estimate that the management of rights protection will require no more than 0.75 FTE. These resources will be committed by the Registry Operator.

Table of Contents

1 - Background
2 - Organization of security
2.1 - The place of Security in AFNIC’s processes:
2.2 - Security Coordination
2.3 - Assignment of responsibilities
2.3.1 - Organizational chain of responsibility
2.3.2 - Relations with the authorities and groups of specialists
2.4 - Independent security review
2.5 - Relations with third parties
2.5.1 - Risk Management
2.5.2 - Security of sensitive areas
2.5.3 - Sensitive external sites
2.5.4 - Security assurances for domain name registrants
3 - Registry Asset Management
3.1 - Responsibilities for Registry assets
3.1.1 - Inventory of assets
3.1.2 - Qualification of support assets
3.1.3 - Ownership of assets
3.1.4 - Good and fair use of assets
3.2 - Guidelines for the classification of information
4 - Security related to human resources
4.1 - Roles and Responsibilities
4.2 - Background checks conducted on security personnel
5 - Physical and environmental security
5.1 - Secure areas
5.2 - Hardware security
6 - Operations Management and Telecommunications
6.1 - Procedures and responsibilities related to operations
6.2 - Scheduling and acceptance testing of the system
6.3 - Protection against malicious and mobile code
6.4 - Back-up
6.5 - Security management of network services
6.6 - Monitoring operation of the System
7 - Access Control
7.1 - Business requirements for access control
7.2 - Control of network access
7.3 - Control of access to operating systems
8 - Acquisition, development and maintenance of information systems
8.1 - Cryptographic measures
8.2 - Management of technical vulnerabilities
9 - Managing incidents related to information security
9.1 - Managing improvement and incidents related to information security
10 - IT Disaster Recovery Plan
11 - Integrating audits of the information system

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1 - Background

The security policy is designed to ensure proper management of the risks that may significantly impact the services provided, the contexts in which they are implemented, and the key personnel involved in operating the Registry. It also defines security level for the scalability ⁄ responsiveness to security incidents, the Registry Data integrity and the confidentiality of personal data of domain name owners.

The Information Security Policy is reviewed at least once a year.

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2 - Organization of security

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2.1 - The place of Security in AFNIC’s processes:

AFNIC has set up a Quality Management System (QMS) following the European Framework for QUality Management (EFQM) excellence model. It describes AFNIC’s activities as a series of business processes. Security Process called “ENSURE SECURITY AND BUSINESS CONTINUITY” is one of the cross-business-processes supporting process. It is designed to be compliant with the ISO 27001 norm.
Ensuring security and business continuity mainly consists in defining and controlling how to :
* Supervise the governance of security,
* Apply security measures into the concerned operational fields,
* Manage the risks that could negatively impact the Registries operations.

The implementation of the AFNICʹs ISMS (Information Security Management System) is performed in the framework of the Security process with a view to obtaining ISO 27001 certification by 2014.

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2.2 - Security Coordination

The overall responsibility for security rests with the CEO. He is assisted in this role by the AFNIC Security Manager (ASM).

Strategic supervision is ensured in a concerted manner by the AFNIC Security Council (ASC) chaired by the AFNIC CEO. The purpose of the ASC is to assist and ensure that the conditions are conducive to attaining the security objectives that fall within the scope of the current strategy.

The ASC further supports the development of security practices at AFNIC through the supporting of operation business functions in implementing security policies, business continuity plans, and staff awareness activities. In carrying out its assignment, the ASC may refer at any time to the Executive Management for advice or a decision on the security of AFNIC and TLD.

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2.3 - Assignment of responsibilities

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2.3.1 - Organizational chain of responsibility

The application of security measures to the SRS, DNS, Whois, and other Information Systems is the responsibility of the CTO (head of the Information Systems Division).
The implementation of security measures for staff and premises is the responsibility of the CFO.
The implementation of security measures with respect to legal obligations and registry policies is the responsibility of the Registryʹs Legal Affairs and Policies Director.
The application of security measures relating to damage to the Registryʹs image is the responsibility of the Marketing and Innovation Director.
All the collaborators must be aware of their responsibility concerning the security of resources and information they are accessing, manipulating, publishing.

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2.3.2 - Relations with the authorities and groups of specialists

AFNIC has an agreement with the French National Agency for the Security of Information Systems (ANSSI). Against this background, the two structures cooperate on security issues that may affect AFNIC services related to its Internet business and risk management in this area.
They cooperate within the framework of two programs on the resilience of the Internet in France :
* Cooperation between the operators of vitals infrastructures in order to improve their capacity to respond to major crises affecting several operators at the same time: the Internet critical services (IP Routing and DNS) are now included in the nomenclature;
* Cooperation to assess the resilience of the French .fr TLD and more generally all the TLDs operated by AFNIC for use by the public.

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2.4 - Independent security review

Security audits must be conducted by independent organizations twice a year on global and ⁄ or specific issues related to security.

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2.5 - Relations with third parties

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2.5.1 - Risk Management

Risk studies are conducted using the EBIOS methodology (Expression of Business needs and Identification of Security Objectives, in French). This method was designed in 1995 by the French National Agency for Information Security. It is currently used to identify the worst-case scenarios that could affect registry activity. That leads Afnic to design and apply mitigation measures to enhance the protection against these worst-case scenarios.

The control of the effectiveness and efficiency of mitigation measures is performed by the AFNIC’s Security Council all along the year.

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2.5.2 - Security of sensitive areas

All sensitive areas are under control. That means that access must be controlled and could be restricted to authorized personnel only.
Co-contractors may be requested to sign a confidentiality agreement if required by the sensitivity of information and data they need to know and⁄or use. They only have access to critical technical facilities if accompanied, and never work on production systems.

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2.5.3 - Sensitive external sites

All security must be applied to protect AFNIC’s resources on external sites. That can be made by private zones and access control to them managed by AFNIC itself.

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2.5.4 - Security assurances for domain name registrants

The Registry guarantees the following for registrants :
* The continuous availability of operations on its portfolio of domain names, in accordance with the SLA on the SRS
* The continuous availability of information related to the domain, on condition that the registrant uses the services provided to carry out the operations in question,
* The confidentiality of the registrantsʹ personal data (except where other special conditions apply related to the policy of the registry)
* The confidentiality of non-public data relating to the domain and ⁄ or its portfolio of domain names,
* The confidentiality of the transactions with the Registryʹs system,
* The integrity of the information related to its domain name,and published in the WHOIS and the DNS.

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3 - Registry Asset Management

The security of the registryʹs assets is ensured by the staff assigned to the registryʹs production operations and management activities.
Considering the network connectivity provided by third party, AFNIC’s property begins at the service delivery point.

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3.1 - Responsibilities for Registry assets

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3.1.1 - Inventory of assets

Assets used in the run of critical services are identified, qualified, and managed under the guidance of the present policy. Assets considered are staff, infrastructure, software, connectivity, data and providers.

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3.1.2 - Qualification of support assets

The assets contributing to the Services are classified in 3 main categories :
* Computer Systems and Telecommunications : Hardware and Software; Communications Channels; Outsourced Services;
* Organizations : Staff; Corporate departments;
* Physical locations for business : Offices; Hosting Datacenters;

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3.1.3 - Ownership of assets

Registry data belong to the Registry owner. They are subject to the rules of the contract with ICANN, plus the applicable legal and ⁄ or legislative rules depending on the context in which the registry is implemented

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3.1.4 - Good and fair use of assets

All the registry operations and services must be used by third party in accordance with the contractual rules defined by the owner and the operator of the TLD.

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3.2 - Guidelines for the classification of information

The data used or produced in the context of the Registry are classified in the 3 following categories :

= Critical information = : it can⁄must be accessed⁄showed only by accredited persons. Disclosure or alteration may result in significant damage but repairable.

= Reserved information = : Information is limited to persons, entities or authorized partners. Disclosure or alteration may result in significant harm.

= Internal Information = : Information is available to staff of AFNIC and authorized partners. Disclosure or alteration may perturb the normal functioning of the company, without lasting consequence.

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4 - Security related to human resources

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4.1 - Roles and Responsibilities

There are 2 categories of staff :

* Technical staff : These personnel have access to resources according to defined rights.
* Administrators in charge of administering production resources. They can access all the production resources and data.
* Technicians in charge of the operation, maintenance and monitoring of the production system. They have limited rights of access to production resources. They can access certain resources on request and when accompanied by an administrator.
* Experts in charge of the design and development of production resources. They only have access to the production resources on request and when accompanied by a technician and ⁄ or an administrator.
* Non-technical staff :
* Administrative staff and managers (excluding production).

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4.2 - Background checks conducted on security personnel

French law applies to all staff. The contract they sign with their employer contains sufficient provisions in terms of professionalism and ethics for the activity involving the TLD. Same rules are applicable a Data Center level.

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5 - Physical and environmental security

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5.1 - Secure areas

AFNIC production sites are secured at the means of access to them. The DATA CENTER sites must meet the standards of industrial and environmental security compatible with the constraints implied by their activity. The layout of the premises must be such that access is restricted only to authorized personnel at entry points selected and controlled by AFNIC.

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5.2 - Hardware security

The Data centers that host AFNIC services ensure at least Tier 3 levels of resilience.

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6 - Operations Management and Telecommunications

AFNIC controls the operation of all the resources used to deliver essential services with the exception, of course, of outsourced services such as certain DNS servers.
AFNIC operates dark fiber connections between its sites. The terminals are owned by AFNIC. They are operated by AFNIC personnel.

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6.1 - Procedures and responsibilities related to operations

Operating procedures are documented and kept up to date on the intranet of the IT team.
Access to the applications, servers and databases must be defined and kept up to date for each staff member.
Access privileges are defined in order to respect the security rules associated with the classification of information.
Operations related to DNSSEC are subject to even more stringent security regulations and require respecting the DPS procedure.

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6.2 - Scheduling and acceptance testing of the system

The test, pre-production and production phases must be clearly specified. Any production launch must be announced to the registrars at least 2 month before it applies.

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6.3 - Protection against malicious and mobile code

All the entry points to the production servers are filtered by the firewall, which applies the filtering policy common to all the procedures, whether they involve a human operator or an automated process.

Each development must apply security rules and recommendations on the development of application.
The Web access must be protected against the most common (Script kiddies, SQL injection …)

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6.4 - Back-up

Registry data are stored and secured using the real-time replication mechanisms of the production Database Management System (production DBMS).
In addition, a physical backup of the entire database must be performed at the same time as the back-up of the other components of the SRS.
To be compliant with the ICANN requirements, a data escrow deposit must be performed every day between 0:00 am end 12:00pm

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6.5 - Security management of network services

A strict partitioning into zones must be implemented in order to avoid interconnections between the external production, administration and backup networks.

Any internal and external attempts to access production servers must pass through a Firewall. They are recorded in a log file for later analysis. The detection of malicious code based on a regularly updated list must be performed at this level.

An intrusion detections system must be installed and running between firewall and production servers.

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6.6 - Monitoring operation of the System

Automated monitoring must be implemented. It must cover the hardware, software systems and production applications.
Any failure must be subject to a specific alert sent to the staff:
* on duty during office hours;
* NOC staff outside office hours;

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7 - Access Control

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7.1 - Business requirements for access control

Access to the information system requires prior identification and authentication. The use of shared or anonymous accounts must be avoided. Mechanisms to limit the services, data, and privileges to which the users have access based on their role at AFNIC and the Registry must be implemented wherever possible.

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7.2 - Control of network access

The internal network must be partitioned to isolate the different services and applications and limit the impact of incidents. In particular it is highly desirable to isolate services visible from the outside in a semi-open zone (DMZ). Similarly, access to the wireless network must be controlled and the network must be subject to appropriate encryption.

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7.3 - Control of access to operating systems

The production servers must be confined in secure facilities. Access must be restricted to authorized personnel only. The personnel in question are the members of the operating teams and their managers, IT personnel and those of the Security Manager.

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8 - Acquisition, development and maintenance of information systems

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8.1 - Cryptographic measures

Cryptographic measures must be implemented to secure the exchanges :
* between the workstations of technical staff and the access proxies to production servers;
* between the Registrars and the EPP server;
* between the DNS master servers and the resolution servers;
* to upload the records of the Escrow Agent.

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8.2 - Management of technical vulnerabilities

The technical configuration of hardware and software used must be subject to up to date documentation.
The changes in technical configurations must be constantly monitored and documented.
Security alerts involving updates and ⁄ or patches to production systems must be constantly monitored.
Application procedures must be documented and updated based on the recommendations of the designers of a component.

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9 - Managing incidents related to information security

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9.1 - Managing improvement and incidents related to information security

The crisis management procedure serves to mobilize at a sufficiently high echelon, all the appropriate levels of responsibility for taking decisions on the actions required to resolve the crisis and return to normal.
Each security incident must be analyzed under the cover of the Security Council and the recommendations, if any, are applied, checked and evaluated as required by the QMS.

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10 - IT Disaster Recovery Plan

The risk analysis must produce some inputs for the elaboration of a disaster recovery plan. That plan has to be established and regularly tested in order to maintain or recover Registry activity and make critical services available at the required SLA after an interruption or a crash of critical services of the Registry.

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11 - Integrating audits of the information system

Security audits are performed annually. They are launched on the initiative of the CTO or upon request from the ASC. They are carried out by independent bodies and relate to one or more of the essentials services of the Registry.

The ASC and the ASM control the implementation and the efficiency of these measures in the framework of S3 process (see section 2.1).

Benoit Jaouen	Technical Advisor
Christian Demeure-Vallee	General Secretary
David Lesvenan	President
Frank Darcel	Board member
Jean-Francois Le Goff	Board member
Michel Bollore	Vice President
Michel Raoul Baudin	Treasurer

New gTLD Application Submitted to ICANN by: Association www.bzh

String: bzh

Originally Posted: 13 June 2012

Application ID: 1-989-18963

Applicant Information

1. Full legal name

2. Address of the principal place of business

3. Phone number

4. Fax number

5. If applicable, website or URL

Primary Contact

6(a). Name

6(b). Title

6(c). Address

6(d). Phone Number

6(e). Fax Number

6(f). Email Address

Secondary Contact

7(a). Name

7(b). Title

7(c). Address

7(d). Phone Number

7(e). Fax Number

7(f). Email Address

Proof of Legal Establishment

8(a). Legal form of the Applicant

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

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

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

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

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

Applicant Background

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

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

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

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

Applied-for gTLD string

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

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

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

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

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

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

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

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

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

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

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

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

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

Mission/Purpose

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

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

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

Community-based Designation

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

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

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

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

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

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

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

Geographic Names

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

Protection of Geographic Names

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

Registry Services

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

Demonstration of Technical & Operational Capability

24. Shared Registration System (SRS) Performance

25. Extensible Provisioning Protocol (EPP)

26. Whois

27. Registration Life Cycle

28. Abuse Prevention and Mitigation

29. Rights Protection Mechanisms

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

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