ICANN New gTLD Application

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

Specialty
 
Currently, there is no top-level domain dedicated to banking and financial services, and no top-level domain dedicated to Citigroup Inc.ʹs (ʺApplicantʺ) brand.  The goal of the TLD in terms of specialty, if displayed to the public, is for Applicant to securely and uniquely provide a top-level domain dedicated to providing banking and financial goods and services to Internet users and customers around the globe under its famous and trusted brand.  Allowing Applicant to control its own Internet space for its famous brand gives it the ability to customize its domain and website names and signal to the general population of Internet users that websites within the TLD will indeed be securely controlled by Applicant without having to incorporate a non-branded, non-industry-related term such as .com, .net, or .biz.  This specialty will benefit Internet users seeking secure online banking and financial services.    
 
This specialization simultaneously makes it easier for Internet users who are looking for Applicant-related information to locate this information more efficiently.  The appendage of the TLD indicates to users what they can expect to find at that website under the TLD, namely, premier and secure financial and banking goods and services offered solely by the famous and reputable Applicant.  It also has another added benefit in that web addresses will become shorter—one impact of a dearth of ‘good’ web addresses has been for them to get longer over time.  Using the TLD not only means Applicant’s sites can benefit from having an important keyword in their web address, but it will also be much faster to type in the address.  Built into a wider process of web optimization and marketing, the inclusion of the TLD as a keyword in every domain name will likely have positive implications for specialty, security, and global promotion purposes.  This will increase traffic to these websites, promote competition and innovation, and facilitate use and trust by banking and financial service consumers who prefer shorter domain names and want a trusted source of the specific services they seek.
 
Service Levels  
 
The goal of the TLD, if displayed to the public, will be to ensure the highest level of security, quality, and customer services levels are provided to Applicant’s customers and clients, for whom security is a high priority concern in connection with its banking and financial services.  Primarily, this entails ensuring that only Applicant’s authorized employees and affiliates are able to register and control the second-level domain names in the TLD.  Regarding security concerns, this entails contracting with and using proven industry experts to provide the highest possible quality in registry and registrar customer service so as not to compromise the security and stability of the highly confidential information that Applicant’s consumers will provide through the TLD.  

Applicant will further endeavor, as it does with its current websites, to provide customer service available by phone 24 hours per day, 7 days per week to instantly help any customer attempting to learn about or utilize Applicant’s goods and services on any outwardly-facing domain name and website in the TLD.  Similarly, Applicant will provide the highest level service to trademark and other legal rights owners by providing an easily accessible point-of-contact on any outwardly-facing domain names and websites.

By focusing on the end user, Applicant will ensure that it is providing the best specialized user experience possible.  To do this, Applicant will employ customer focused testing to determine what their expectations are for an Applicant-branded TLD experience and then tailoring the TLD to its end users.  For example, when designing its current websites or adding a new feature to its homepage, Applicant takes great care to ensure that they will ultimately serve the Internet user, rather than its own internal goals or bottom line.   Applicant’s homepage interface is thus clear and simple.  Information is provided through the most secure websites and networks.  Applicant will continue to operate under this principle when designing websites and providing banking, finance, and related goods and services in the TLD.

Reputation  

Applicant already has a reputation for excellence, superior quality, and the highest level of security in the banking and finance industry, including online through its current websites and domain names.  Indeed, as discussed above, Applicant already has an awarded-winning online track record and, if displayed to the public, intends to enhance its Web services with the new TLD.  As insurance and financial websites are among the most vulnerable to fraudulent online activity, Applicant seeks through the operation of the TLD to maintain a reputation for providing the most secure online environment in the industry for all Internet users to feel secure in providing highly sensitive personal information to Applicant.  Applicant also has a reputation of having enhanced technical capabilities and to be an early adopter of technical advancements in the banking and financial industry. The goal of the TLD, if made public, is to continue to promote Applicant’s reputation for excellence and high levels of security and advanced and enhanced technical capabilities.
 
The TLD will further strive to be known for ensuring only Applicant’s employees, agents, subsidiaries, affiliates, or related companies register domain names in the TLD, that those domain names are used for Applicant-related purposes, that the Whois is thick and reliable, and that the Registry is responsive to legal rights owners.  Indeed, when Internet users visit a website within the TLD, they should know that Applicant will be the entity providing its world-renowned services, and that they can expect the highest level of online service and security.  In all, Applicant will strive to be known as an exemplary and model domain name services citizen through the use of the TLD.
 
ii. What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

Competition

The TLD, if displayed to the public, will enhance competition to the current Internet space by allowing Applicant to control its own Internet space and to have the flexibility to innovate and create new online goods and services, and to connect with new geographic areas in a new way.  These innovations to how the Applicant will provide online banking and financial services will incentivize existing and new top-level domains and banking and financial service companies that operate on existing and new top-level domains to also improve the security and quality of the banking and financial goods and services they provide online and to accelerate the introduction of new goods and services in order to continue attracting new customers.  Thus, the entry of the TLD will benefit consumers by increasing the likelihood of the successful introduction of new and innovative online goods and services.

Differentiation

The TLD, if displayed to the public, will be differentiated from all other top-level domains currently available in the marketplace because its famous brand will be automatically affixed to all second-level domains as the TLD and immediately indicate to Internet users the source of the TLD.  Indeed, no other top-level domain is similar in appearance to the TLD, and none is used exclusively for banking and financial goods and services, and⁄or none exclusively serve Applicant’s users and customers.  In terms of differentiated uses it will have the flexibility to customize the second-level domains within the TLD so as to signify the service offered as well as the source of the service.  Finally, unlike in existing top-level domains, only Applicant’s employees and affiliated companies will be ever be allowed to register and⁄or operate domain names within the TLD, allowing the TLD to become unique in that its customers can reduce their concerns regarding corruption, security, spam, phishing or false or inaccurate information, and allowing Applicant to become an even more trusted provider of online banking and financial goods or services.      

Innovation

Applicant is already a recognized leader in online banking and financial innovation as demonstrated above.  Indeed, technology is at the forefront of Applicant’s online banking and financial presence.  One of the most crucial issues of importance to banking and finance customers and clients is security.  The TLD, if displayed to the public, will allow Applicant to provide information, goods and services to its clients and customers in a more secure and technologically advanced way and allow Applicant to implement technical advances that may not have been capable before in a less secure environment.  

Indeed, the TLD will allow Applicant to innovate and to continue to be a market leader in providing truly secure banking and financial websites.  With the TLD, Applicant can test the use of the TLD with consumers to facilitate their desired Web experience, and can test the use of the TLD to ensure it meet the highest possible security standard.  This innovation will promote competition in the Internet space and more likely provide higher levels of service to its users and customers.  Moreover, the TLD will be innovative in that it will allow more people to have greater access to a dedicated and secure banking and financial services top-level domain.  The TLD will also allow Applicant to expand its secure work in communities where access to financial services is limited by making it easier for these communities to access its banking and financial services in a trustworthy way.

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

Similarly to how it operates its award-winning domain names and websites in third-party top-level domains, Applicant will strive to test, develop, and implement the TLD and its websites to target its customer’s Web expectations in the most secure manner.  In doing so, Applicant will take great care to ensure that domain names in the TLD will ultimately serve the Internet user, rather than its own internal goal or bottom line.  Accordingly, Applicant will rely on its consumer and security-driven testing to provide a targeted user experience for those seeking robust, reliable, and secure online banking and financial goods and services around the globe.  Because users will know that all domain names in the TLD will be owned and operated by Applicant, Applicant anticipates that the TLD will eventually provide an enhanced and secure online technological experience for those interested in obtaining more information about and conducting online banking and finance transactions.  The TLD, if displayed to the public, will serve to differentiate Applicant from other banking and financial institutions and serve to create a more stable, competitive, and active marketplace.

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

In order to support the goals listed above, only Applicant through its authorized employees will be allowed to register domain names within the TLD for its own exclusive use.  Accordingly, it is Applicant’s intention that the general public will never be allowed to register, buy, or sell domain names in the TLD.  Applicant, however, reserves the right to sell, distribute, or transfer control or use of any registrations in the TLD to any third party that is an Affiliate of Applicant for the exclusive use of Applicant.  Affiliate will be defined for the purposes of this application as (i) a person or entity that, directly or indirectly, through one or more intermediaries, controls, is controlled by, or is under common control with, Applicant, and (ii) “control” (including the terms “controlled by” and “under common control with”) means the possession, directly or indirectly, of the power to direct or cause the direction of the management or policies of a person or entity regarding the use of a domain name within the TLD, whether through the ownership of securities, as trustee or executor, by serving as an employee or a member of a board of directors or equivalent governing body, by contract, by credit arrangement or otherwise.

As stated above, Applicant intends to operate a closed registry in order to continue to offer the high-quality online banking and financial goods and services it currently offers on its branded websites in existing top-level domains.  Accordingly, policies and decisions regarding the registration and use of domain names within the TLD will continue to be provided through an internal team consisting of Applicant’s existing business and marketing decision-making channels.

The TLD’s domain name policies will be of course be subject to its abuse prevention and rights protection policies discussed further herein, and Applicant will strive to avoid registering domain names that are confusingly similar to third-party’s trademarks and related rights. Obscene, explicit, and offensive domain names will not be entitled to registration.

v. 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.

Keeping information secure and private is of crucial importance to banking and financial institutions, whose websites are targets of online fraudsters.  Initially, Applicant intends to operate a registry with limited access so as to ensure the security and privacy of the information available.  As Applicant’s use may expand, Applicant will take all available steps to maintain the security and privacy of the information collected therein, and will remain in compliance with all confidentiality and security regulations in relevant jurisdictions.

For example, Applicant already takes the following steps to safeguard the financial information of its current online banking services customers and clients:

•	128-Bit Encryption;

•	Additional Authentication — asking users additional questions to verify identity;

•	Date⁄Time Stamp  to notify Applicant of unauthorized account access;

•	Extended Validation (EV) SSL Certificate — allows users to visually validate that the website being transacting with has undergone an extensive outside security audit; and 

•	Secure Firewalls — The computer servers which run Applicant’s websites are protected by numerous firewalls to help prevent unauthorized access to Applicant’s network, and Applicant constantly monitors these firewalls to prevent security breaches. 

If the TLD becomes public-facing such that external users are interacting with domains registered in the TLD, Applicant will, at a minimum, provide similar security measures.

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

Outreach and communication are among Applicant’s important goals in connection with the TLD.  For example, if the TLD is displayed to the public, it will provide better and more secure access to banking and financial information to consumers, institutions, and governments throughout the globe.  Applicant intends to institute marketing and outreach efforts to inform the public about the TLD and the information available there.

Applicant already uses a number of different outreach and communications methods and venues to get its mission and message out to the public, including but not limited to, press releases, featured videos posted on various Internet sites, social media, including but not limited to blogs, YouTube, Twitter, and Facebook, various mobile applications for iPads, iPhones, Android, and Kindle devices, various news feeds around the globe, and paid advertising, which includes television and radio commercials, magazine and newspaper print, billboards and posters in major markets, and a variety of digital media.  Applicant is able to incorporate the outreach and communication regarding the TLD into its current branding and marketing efforts to ensure that as many customers and users as possible understand the new resources available and how to interact with them to improve their consumer experience.

24.1 Introduction

Citigroup Inc. (ʺApplicantʺ) has partnered with NeuStar, Inc (ʺNeustarʺ), an experienced TLD registry operator, for the operation of the .CITI Registry. The applicant is confident that the plan in place for the operation of a robust and reliable Shared Registration System (SRS) as currently provided by Neustar will satisfy the criterion established by ICANN.

Neustar built its SRS from the ground up as an EPP based platform and has been operating it reliably and at scale since 2001. The software currently provides registry services to five TLDs (.BIZ, .US, TEL, .CO and .TRAVEL) and is used to provide gateway services to the .CN and .TW registries. Neustarʹs state of the art registry has a proven track record of being secure, stable, and robust. It manages more than 6 million domains, and has over 300 registrars connected today.
The following describes a detailed plan for a robust and reliable SRS that meets all ICANN requirements including compliance with Specifications 6 and 10.

24.2 The Plan for Operation of a Robust and Reliable SRS

24.2.1 High-level SRS System Description

The SRS to be used for .CITI will leverage a production-proven, standards-based, highly reliable and high-performance domain name registration and management system that fully meets or exceeds the requirements as identified in the new gTLD Application Guidebook.

The SRS is the central component of any registry implementation and its quality, reliability and capabilities are essential to the overall stability of the TLD. Neustar has a documented history of deploying SRS implementations with proven and verifiable performance, reliability and availability. The SRS adheres to all industry standards and protocols. By leveraging an existing SRS platform, Applicant is mitigating the significant risks and costs associated with the development of a new system. Highlights of the SRS include:

-State-of-the-art, production proven multi-layer design
-Ability to rapidly and easily scale from low to high volume as a TLD grows
-Fully redundant architecture at two sites
-Support for IDN registrations in compliance with all standards
-Use by over 300 Registrars
-EPP connectivity over IPv6
-Performance being measured using 100% of all production transactions (not sampling).

24.2.2 SRS Systems, Software, Hardware, and Interoperability

The systems and software that the registry operates on are a critical element to providing a high quality of service. If the systems are of poor quality, if they are difficult to maintain and operate, or if the registry personnel are unfamiliar with them, the registry will be prone to outages. Neustar has a decade of experience operating registry infrastructure to extremely high service level requirements. The infrastructure is designed using best of breed systems and software. Much of the application software that performs registry-specific operations was developed by the current engineering team and a result the team is intimately familiar with its operations.

The architecture is highly scalable and provides the same high level of availability and performance as volumes increase. It combines load balancing technology with scalable server technology to provide a cost effective and efficient method for scaling.

The Registry is able to limit the ability of any one registrar from adversely impacting other registrars by consuming too many resources due to excessive EPP transactions. The system uses network layer 2 level packet shaping to limit the number of simultaneous connections registrars can open to the protocol layer.

All interaction with the Registry is recorded in log files. Log files are generated at each layer of the system. These log files record at a minimum:

-The IP address of the client
-Timestamp
-Transaction Details
-Processing Time.

In addition to logging of each and every transaction with the SRS Neustar maintains audit records, in the database, of all transformational transactions. These audit records allow the Registry, in support of the applicant, to produce a complete history of changes for any domain name.

24.2.3 SRS Design

The SRS incorporates a multi-layer architecture that is designed to mitigate risks and easily scale as volumes increase. The three layers of the SRS are:

-Protocol Layer
-Business Policy Layer
-Database.

Each of the layers is described below.

24.2.4 Protocol Layer

The first layer is the protocol layer, which includes the EPP interface to registrars. It consists of a high availability farm of load-balanced EPP servers. The servers are designed to be fast processors of transactions. The servers perform basic validations and then feed information to the business policy engines as described below. The protocol layer is horizontally scalable as dictated by volume.

The EPP servers authenticate against a series of security controls before granting service, as follows:

-The registrarʹs host exchanges keys to initiates a TLS handshake session with the EPP server.
-The registrarʹs host must provide credentials to determine proper access levels.
-The registrarʹs IP address must be preregistered in the network firewalls and traffic-shapers.

24.2.5 Business Policy Layer

The Business Policy Layer is the brain of the registry system. Within this layer, the policy engine servers perform rules-based processing as defined through configurable attributes. This process takes individual transactions, applies various validation and policy rules, persists data and dispatches notification through the central database in order to publish to various external systems. External systems fed by the Business Policy Layer include backend processes such as dynamic update of DNS, WHOIS and Billing.

Similar to the EPP protocol farm, the SRS consists of a farm of application servers within this layer. This design ensures that there is sufficient capacity to process every transaction in a manner that meets or exceeds all service level requirements. Some registries couple the business logic layer directly in the protocol layer or within the database. This architecture limits the ability to scale the registry. Using a decoupled architecture enables the load to be distributed among farms of inexpensive servers that can be scaled up or down as demand changes.

The SRS today processes over 30 million EPP transactions daily.

24.2.6 Database

The database is the third core components of the SRS. The primary function of the SRS database is to provide highly reliable, persistent storage for all registry information required for domain registration services. The database is highly secure, with access limited to transactions from authenticated registrars, trusted application-server processes, and highly restricted access by the registry database administrators. A full description of the database can be found in response to Question 33.

Figure 24-1 attached depicts the overall SRS architecture including network components.

24.2.7 Number of Servers

As depicted in the SRS architecture diagram above Neustar operates a high availability architecture where at each level of the stack there are no single points of failures. Each of the network level devices run with dual pairs as do the databases. For the .CITI registry, the SRS will operate with 8 protocol servers and 6 policy engine servers. These expand horizontally as volume increases due to additional TLDs, increased load, and through organic growth. In addition to the SRS servers described above, there are multiple backend servers for services such as DNS and WHOIS. These are discussed in detail within those respective response sections.

24.2.8 Description of Interconnectivity with Other Registry Systems

The core SRS service interfaces with other external systems via Neustarʹs external systems layer. The services that the SRS interfaces with include:

-WHOIS
-DNS
-Billing
-Data Warehouse (Reporting and Data Escrow).

Other external interfaces may be deployed to meet the unique needs of a TLD. At this time there are no additional interfaces planned for .CITI.

The SRS includes an external notifier concept in its business policy engine as a message dispatcher. This design allows time-consuming backend processing to be decoupled from critical online registrar transactions. Using an external notifier solution, the registry can utilize control levers that allow it to tune or to disable processes to ensure optimal performance at all times. For example, during the early minutes of a TLD launch, when unusually high volumes of transactions are expected, the registry can elect to suspend processing of one or more back end systems in order to ensure that greater processing power is available to handle the increased load requirements. This proven architecture has been used with numerous TLD launches, some of which have involved the processing of over tens of millions of transactions in the opening hours. The following are the standard three external notifiers used the SRS:

24.2.9 WHOIS External Notifier

The WHOIS external notifier dispatches a work item for any EPP transaction that may potentially have an impact on WHOIS. It is important to note that, while the WHOIS external notifier feeds the WHOIS system, it intentionally does not have visibility into the actual contents of the WHOIS system. The WHOIS external notifier serves just as a tool to send a signal to the WHOIS system that a change is ready to occur. The WHOIS system possesses the intelligence and data visibility to know exactly what needs to change in WHOIS. See response to Question 26 for greater detail.

24.2.10 DNS External Notifier

The DNS external notifier dispatches a work item for any EPP transaction that may potentially have an impact on DNS. Like the WHOIS external notifier, the DNS external notifier does not have visibility into the actual contents of the DNS zones. The work items that are generated by the notifier indicate to the dynamic DNS update sub-system that a change occurred that may impact DNS. That DNS system has the ability to decide what actual changes must be propagated out to the DNS constellation. See response to Question 35 for greater detail.

24.2.11 Billing External Notifier

The billing external notifier is responsible for sending all billable transactions to the downstream financial systems for billing and collection. This external notifier contains the necessary logic to determine what types of transactions are billable. The financial systems use this information to apply appropriate debits and credits based on registrar.

24.2.12 Data Warehouse

The data warehouse is responsible for managing reporting services, including registrar reports, business intelligence dashboards, and the processing of data escrow files. The Reporting Database is used to create both internal and external reports, primarily to support registrar billing and contractual reporting requirement. The data warehouse databases are updated on a daily basis with full copies of the production SRS data.

24.2.13 Frequency of Synchronization between Servers

The external notifiers discussed above perform updates in near real-time, well within the prescribed service level requirements. As transactions from registrars update the core SRS, update notifications are pushed to the external systems such as DNS and WHOIS. These updates are typically live in the external system within 2-3 minutes.

24.2.14 Synchronization Scheme (e.g., hot standby, cold standby)

Neustar operates two hot databases within the data center that is operating in primary mode. These two databases are kept in sync via synchronous replication. Additionally, there are two databases in the secondary data center. These databases are updated real time through asynchronous replication. This model allows for high performance while also ensuring protection of data. See response to Question 33 for greater detail.

24.2.15 Compliance with Specification 6 Section 1.2

The SRS implementation for .CITI is fully compliant with Specification 6, including section 1.2. EPP Standards are described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. Extensible Provisioning Protocol or EPP is defined by a core set of RFCs that standardize the interface that make up the registry-registrar model. The SRS interface supports EPP 1.0 as defined in the following RFCs shown in Table 24-1 attached.

Additional information on the EPP implementation and compliance with RFCs can be found in the response to Question 25.

24.2.16 Compliance with Specification 10

Specification 10 of the New TLD Agreement defines the performance specifications of the TLD, including service level requirements related to DNS, RDDS (WHOIS), and EPP. The requirements include both availability and transaction response time measurements. As an experienced registry operator, Neustar has a long and verifiable track record of providing registry services that consistently exceed the performance specifications stipulated in ICANN agreements. This same high level of service will be provided for the .CITI Registry. The following section describes Neustarʹs experience and its capabilities to meet the requirements in the new agreement.

To properly measure the technical performance and progress of TLDs, Neustar collects data on key essential operating metrics. These measurements are key indicators of the performance and health of the registry. Neustarʹs current .biz SLA commitments are among the most stringent in the industry today, and exceed the requirements for new TLDs. Table 24-2 compares the current SRS performance levels compared to the requirements for new TLDs, and clearly demonstrates the ability of the SRS to exceed those requirements.

Their ability to commit and meet such high performance standards is a direct result of their philosophy towards operational excellence. See response to Question 31 for a full description of their philosophy for building and managing for performance.

24.3 Resourcing Plans

The development, customization, and on-going support of the SRS are the responsibility of a combination of technical and operational teams, including:

-Development⁄Engineering
-Database Administration
-Systems Administration
-Network Engineering.

Additionally, if customization or modifications are required, the Product Management and Quality Assurance teams will be involved in the design and testing. Finally, the Network Operations and Information Security play an important role in ensuring the systems involved are operating securely and reliably.

The necessary resources will be pulled from the pool of operational resources described in detail in the response to Question 31. Neustarʹs SRS implementation is very mature, and has been in production for over 10 years. As such, very little new development related to the SRS will be required for the implementation of the .CITI registry. The following resources are available from those teams:

-Development⁄Engineering 19 employees
-Database Administration- 10 employees
-Systems Administration 24 employees
-Network Engineering 5 employees

The resources are more than adequate to support the SRS needs of all the TLDs operated by Neustar, including the .CITI registry.

Citigroup Inc. (ʺApplicantʺ) recognizes the importance of an accurate, reliable, and up-to-date WHOIS database to governments, law enforcement, intellectual property holders, and the public as a whole and is firmly committed to complying with all of the applicable WHOIS specifications for data objects, bulk access, and lookups as defined in Specifications 4 and 10 to the Registry Agreement and relevant RFCs.

Applicant’s back-end registry services provider, Neustar, has extensive experience providing ICANN and RFC-compliant WHOIS services for each of the TLDs that it operates both as a Registry Operator for gTLDs, ccTLDs, and back-end registry services provider. As one of the first “thick” registry operators in the gTLD space, the WHOIS service provided by Applicant’s registry services operator has been designed from the ground up to display as much information as required by ICANN and respond to a very stringent availability and performance requirement.

Some of the key features of Applicant’s WHOIS services will include:

• Fully compliant with all relevant RFCs including 3912;
• Production proven, highly flexible, and scalable (applicant’s back-end registry services provider has a track record of 100% availability over the past 10 years);
• Exceeds current and proposed performance specifications;
• Supports dynamic updates with the capability of doing bulk updates;
• Geographically distributed sites to provide greater stability and performance; and
• Search capabilities (e.g., IDN, registrant data) that mitigate potential forms of abuse as discussed below.
Applicant’s registry services operator will provide thick WHOIS services that are fully compliant with RFC 3912 and with Specifications 4 and 10 of the Registry Agreement.

Applicant’s WHOIS service will support port 43 queries, and will be optimized for speed using an in-memory database and a master-slave architecture between SRS and WHOIS slaves. RFC 3912 is a simple text based protocol over TCP that describes the interaction between the server and client on port 43. Applicant’s registry services operator built a home-grown solution for this service. It currently processes millions of WHOIS queries per day.

In addition to the WHOIS Service on port 43, Applicant will provide a Web-based WHOIS application, which will be located at www.whois.citi. This WHOIS Web application will be an intuitive and easy to use application for the general public to use. The WHOIS Web application provides all of the features available in the port 43 WHOIS. This includes full and partial search on:

• Domain names
• Nameservers
• Registrant, Technical and Administrative Contacts
• Registrars

The WHOIS web application will also provide features not available on the port 43 service. These include:

• Extensive support for international domain names (IDN)
• Ability to perform WHOIS lookups on the actual Unicode IDN
• Display of the actual Unicode IDN in addition to the ACE-encoded name
• A Unicode to Punycode and Punycode to Unicode translator
• An extensive FAQ
• A list of upcoming domain deletions

Applicant will also provide a new web-based service to address the new search features based on requirements specified in Specification 4 Section 1.8. The application will enable users to search the WHOIS directory to find exact or partial matches using any one or more of the following fields:

• Domain name
• Contacts and registrant’s name
• Contact and registrant’s postal address, including all the sub-fields described in EPP (e.g., street, city, state or province, etc.)
• Registrar ID
• Name server name and IP address
• Internet Protocol addresses
• The system will also allow search using non-Latin character sets which are compliant with IDNA specification

The WHOIS user will be able to choose one or more search criteria, combine them by Boolean operators (AND, OR, NOT) and provide partial or exact match regular expressions for each of the criterion name-value pairs. The domain names matching the search criteria and their WHOIS information will quickly be returned to the user.

In order to reduce abuse for this feature, only authorized users will have access to the Whois search features after providing a username and password. Authorized users will at all times be designated Applicant employees.

Applicant will provide third party access to the bulk zone file in accordance with Specification 4, Section 2 of the Registry Agreement. Credentialing and dissemination of the zone files will be facilitated through the Central Zone Data Access Provider, which will make access to the zone files in bulk via FTP to any person or organization that signs and abides by a Zone File Access (ZFA) Agreement with the registry. Contracted gTLD registries will provide this access daily and at no charge.

Applicant will also provide ICANN and any emergency operators with up-to-date Registration Data on a weekly basis (the day to be designated by ICANN). Data will include data committed as of 00:00:00 UTC on the day previous to the one designated for retrieval by ICANN. The file(s) will be made available for download by SFTP, unless ICANN requests other means in the future.

Applicant’s Legal Team, which currently consists of four (4) lawyers, will regular monitor the registry service provider to ensure that they are providing the services as described above. This will entail random monthly testing of the WHOIS port 43 and Web-based services to ensure that they meet the ICANN Specifications and RFCs as outlined above, if not, to follow up with the registry services provider to ensure that they do. As the relevant WHOIS will only contain Applicant’s information, Applicant’s WHOIS services will necessarily be in compliance with any applicable privacy laws or policies.

26.2 Software Components

The WHOIS architecture comprises the following components:

-An in-memory database local to each WHOIS node: To provide for the performance needs, the WHOIS data is served from an in-memory database indexed by searchable keys.

-Redundant servers: To provide for redundancy, the WHOIS updates are propagated to a cluster of WHOIS servers that maintain an independent copy of the database.

-Attack resistant: To ensure that the WHOIS system cannot be abused using malicious queries or DOS attacks, the WHOIS server is only allowed to query the local database and rate limits on queries based on IPs and IP ranges can be readily applied.

-Accuracy auditor: To ensure the accuracy of the information served by the WHOIS servers, a daily audit is done between the SRS information and the WHOIS responses for the domain names which are updated during the last 24-hour period. Any discrepancies are resolved proactively.

-Modular design: The WHOIS system allows for filtering and translation of data elements between the SRS and the WHOIS database to allow for customizations.

-Scalable architecture: The WHOIS system is scalable and has a very small footprint. Depending on the query volume, the deployment size can grow and shrink quickly.

-Flexible: It is flexible enough to accommodate thin, thick, or modified thick models and can accommodate any future ICANN policy, such as different information display levels based on user categorization.

-SRS master database: The SRS database is the main persistent store of the Registry information. The Update Agent computes what WHOIS updates need to be pushed out. A publish-subscribe mechanism then takes these incremental updates and pushes to all the WHOIS slaves that answer queries.

26.3 Compliance with RFC and Specifications 4 and 10

Neustar has been running thick-WHOIS Services for over 10+ years in full compliance with RFC 3912 and with Specifications 4 and 10 of the Registry Agreement. RFC 3912 is a simple text based protocol over TCP that describes the interaction between the server and client on port 43. Neustar built a home-grown solution for this service. It processes millions of WHOIS queries per day.

Table 26-1 attached describes Neustarʹs compliance with Specifications 4 and 10.

Neustar ensures compliance with all RFCs through a variety of processes and procedures. Members from the engineering and standards teams actively monitor and participate in the
development of RFCs that impact the registry services, including those related to WHOIS. When new RFCs are introduced or existing ones are updated, the team performs a full compliance review of each system impacted by the change. Furthermore, all code releases include a full regression test that includes specific test cases to verify RFC compliance.

26.4 High-level WHOIS System Description

26.4.1 WHOIS Service (port 43)

The WHOIS service is responsible for handling port 43 queries. Our WHOIS is optimized for speed using an in-memory database and master-slave architecture between the SRS and WHOIS slaves.

The WHOIS service also has built-in support for IDN. If the domain name being queried is an IDN, the returned results include the language of the domain name, the domain nameʹs UTF-8 encoded representation along with the Unicode code page.

26.4.2 Web Page for WHOIS queries

In addition to the WHOIS Service on port 43, Neustar provides a web based WHOIS application (www.whois.TLD). It is an intuitive and easy to use application for the general public to use. WHOIS web application provides all of the features available in the port 43 WHOIS. This includes full and partial search on:

-Domain names

-Nameservers

-Registrant, Technical and Administrative Contacts

-Registrars

It also provides features not available on the port 43 service. These include:

1. Redemption Grace Period calculation: Based on the registryʹs policy, domains in pendingDelete can be restorable or scheduled for release depending on the date⁄time the domain went into pendingDelete. For these domains, the web based WHOIS displays Restorable or Scheduled for Release to clearly show this additional status to the user.

2. Extensive support for international domain names (IDN)

3. Ability to perform WHOIS lookups on the actual Unicode IDN

4. Display of the actual Unicode IDN in addition to the ACE-encoded name

5. A Unicode to Punycode and Punycode to Unicode translator

6. An extensive FAQ

7. A list of upcoming domain deletions

26.5 IT and Infrastructure Resources

As described above the WHOIS architecture uses a workflow that decouples the update process from the SRS. This ensures SRS performance is not adversely affected by the load requirements of dynamic updates. It is also decoupled from the WHOIS lookup agent to ensure the WHOIS service is always available and performing well for users. Each of Neustarʹs geographically diverse WHOIS sites use:

-Firewalls, to protect this sensitive data

-Dedicated servers for MQ Series, to ensure guaranteed delivery of WHOIS updates

-Packetshaper for source IP address-based bandwidth limiting

-Load balancers to distribute query load

-Multiple WHOIS servers for maximizing the performance of WHOIS service.

The WHOIS service uses HP BL 460C servers, each with 2 X Quad Core CPU and a 64GB of RAM. The existing infrastructure has 6 servers, but is designed to be easily scaled with additional servers should it be needed.

Figure 26-1 attached depicts the different components of the WHOIS architecture.

26.6 Interconnectivity with Other Registry System

As described in Question 24 about the SRS and further in response to Question 31, Technical Overview, when an update is made by a registrar that impacts WHOIS data, a trigger is sent to the WHOIS system by the external notifier layer. The update agent processes these updates, transforms the data if necessary and then uses messaging oriented middleware to publish all updates to each WHOIS slave. The local update agent accepts the update and applies it to the local in-memory database. A separate auditor compares the data in WHOIS and the SRS daily and monthly to ensure accuracy of the published data.

26.7 Frequency of Synchronization between Servers

Updates from the SRS, through the external notifiers, to the constellation of independent WHOIS slaves happens in real-time via an asynchronous publish⁄subscribe messaging architecture. The updates are guaranteed to be updated in each slave within the required SLA of 95%, less than or equal to 60 minutes. Please note that Neustarʹs current architecture is built towards the stricter SLAs (95%, less than or equal to 15 minutes) of .BIZ. The vast majority of updates tend to happen within 2-3 minutes.

26.8 Provision for Searchable WHOIS Capabilities

Neustar will create a new web-based service to address the new search features based on requirements specified in Specification 4 Section 1.8. The application will enable users to search the WHOIS directory using any one or more of the following fields:

-Domain name

-Registrar ID

-Contacts and registrantʹs name

-Contact and registrantʹs postal address, including all the sub-fields described in EPP (e.g., street, city, state or province, etc.)

-Name server name and name server IP address

-The system will also allow search using non-Latin character sets which are compliant with IDNA specification.

The user will choose one or more search criteria, combine them by Boolean operators (AND, OR, NOT) and provide partial or exact match regular expressions for each of the criterion name-value pairs. The domain names matching the search criteria will be returned to the user.

Figure 26-2 attached shows an architectural depiction of the new service.

To mitigate the risk of this powerful search service being abused by unscrupulous data miners, a layer of security will be built around the query engine which will allow the registry to identify rogue activities and then take appropriate measures. Potential abuses include, but are not limited to:

-Data Mining

-Unauthorized Access

-Excessive Querying

-Denial of Service Attacks

To mitigate the abuses noted above, Neustar will implement any or all of these mechanisms as appropriate:

-Username-password based authentication

-Certificate based authentication

-Data encryption

-CAPTCHA mechanism to prevent robo invocation of Web query

-Fee-based advanced query capabilities for premium customers.

The searchable WHOIS application will adhere to all privacy laws and policies of the TLD registry.

26.9 Resourcing Plans

As with the SRS, the development, customization, and on-going support of the WHOIS service is the responsibility of a combination of technical and operational teams. The primary groups responsible for managing the service include:

-Development⁄Engineering 19 employees

-Database Administration 10 employees

-Systems Administration 24 employees

-Network Engineering 5 employees

Additionally, if customization or modifications are required, the Product Management and Quality Assurance teams will also be involved. Finally, the Network Operations and Information Security play an important role in ensuring the systems involved are operating securely and reliably. The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31.Neustarʹs WHOIS implementation is very mature, and has been in production for over 10 years. As such, very little new development will be required to support the implementation of the TLD registry. The resources are more than adequate to support the WHOIS needs of all the TLDs operated by Neustar, including the TLD registry.

27.1 Registration Life Cycle

27.1.1 Introduction

.CITI will follow the lifecycle and business rules found in the majority of gTLDs today. Our back-end operator, Neustar, has over ten years of experience managing numerous TLDs that utilize standard and unique business rules and lifecycles. This section describes the business rules, registration states, and the overall domain lifecycle that will be used for .CITI.

27.1.2 Domain Lifecycle - Description

The registry will use the EPP 1.0 standard for provisioning domain names, contacts and hosts. Each domain record is comprised of three registry object types: domain, contacts, and hosts.

Domains, contacts and hosts may be assigned various EPP defined statuses indicating either a particular state or restriction placed on the object. Some statuses may be applied by the Registrar; other statuses may only be applied by the Registry. Statuses are an integral part of the domain lifecycle and serve the dual purpose of indicating the particular state of the domain and indicating any restrictions placed on the domain. The EPP standard defines 17 statuses, however only 14 of these statuses will be used in the .CITI registry per the defined .CITI business rules.

The following is a brief description of each of the statuses. Server statuses may only be applied by the Registry, and client statuses may be applied by the Registrar.

-OK Default status applied by the Registry.
-Inactive Default status applied by the Registry if the domain has less than 2 nameservers.
-PendingCreate Status applied by the Registry upon processing a successful Create command, and indicates further action is pending. This status will not be used in the .CITI registry.
-PendingTransfer Status applied by the Registry upon processing a successful Transfer request command, and indicates further action is pending.
-PendingDelete Status applied by the Registry upon processing a successful Delete command that does not result in the immediate deletion of the domain, and indicates further action is pending.
-PendingRenew Status applied by the Registry upon processing a successful Renew command that does not result in the immediate renewal of the domain, and indicates further action is pending. This status will not be used in the .CITI registry.
-PendingUpdate Status applied by the Registry if an additional action is expected to complete the update, and indicates further action is pending. This status will not be used in the .CITI registry.
-Hold Removes the domain from the DNS zone.
-UpdateProhibited Prevents the object from being modified by an Update command.
-TransferProhibited Prevents the object from being transferred to another Registrar by the Transfer command.
-RenewProhibited Prevents a domain from being renewed by a Renew command.
-DeleteProhibited Prevents the object from being deleted by a Delete command.

The lifecycle of a domain begins with the registration of the domain. All registrations must follow the EPP standard, as well as the specific business rules described in the response to Question 18 above. Upon registration a domain will either be in an active or inactive state. Domains in an active state are delegated and have their delegation information published to the zone. Inactive domains either have no delegation information or their delegation information in not published in the zone. Following the initial registration of a domain, one of five actions may occur during its lifecycle:

-Domain may be updated
-Domain may be deleted, either within or after the add-grace period
-Domain may be renewed at anytime during the term
-Domain may be auto-renewed by the Registry
-Domain may be transferred to another registrar.

Each of these actions may result in a change in domain state. This is described in more detail in the following section. Every domain must eventually be renewed, auto-renewed, transferred, or deleted. A registrar may apply EPP statuses described above to prevent specific actions such as updates, renewals, transfers, or deletions.

27.2 Registration States

27.2.1 Domain Lifecycle Registration States

As described above the .CITI registry will implement a standard domain lifecycle found in most gTLD registries today. There are five possible domain states:

-Active
-Inactive
-Locked
-Pending Transfer
-Pending Delete.

All domains are always in either an Active or Inactive state, and throughout the course of the lifecycle may also be in a Locked, Pending Transfer, and Pending Delete state. Specific conditions such as applied EPP policies and registry business rules will determine whether a domain can be transitioned between states. Additionally, within each state, domains may be subject to various timed events such as grace periods, and notification periods.

27.2.2 Active State

The active state is the normal state of a domain and indicates that delegation data has been provided and the delegation information is published in the zone. A domain in an Active state may also be in the Locked or Pending Transfer states.

27.2.3 Inactive State

The Inactive state indicates that a domain has not been delegated or that the delegation data has not been published to the zone. A domain in an Inactive state may also be in the Locked or Pending Transfer states. By default all domain in the Pending Delete state are also in the Inactive state.

27.2.4 Locked State

The Locked state indicates that certain specified EPP transactions may not be performed to the domain. A domain is considered to be in a Locked state if at least one restriction has been placed on the domain; however up to eight restrictions may be applied simultaneously. Domains in the Locked state will also be in the Active or Inactive, and under certain conditions may also be in the Pending Transfer or Pending Delete states.

27.2.5 Pending Transfer State

The Pending Transfer state indicates a condition in which there has been a request to transfer the domain from one registrar to another. The domain is placed in the Pending Transfer state for a period of time to allow the current (losing) registrar to approve (ack) or reject (nack) the transfer request. Registrars may only nack requests for reasons specified in the Inter-Registrar Transfer Policy.

27.2.6 Pending Delete State

The Pending Delete State occurs when a Delete command has been sent to the Registry after the first 5 days (120 hours) of registration. The Pending Delete period is 35-days during which the first 30-days the name enters the Redemption Grace Period (RGP) and the last 5-days guarantee that the domain will be purged from the Registry Database and available to public pool for registration on a first come, first serve basis.

27.3 Typical Registration Lifecycle Activities

27.3.1 Domain Creation Process

The creation (registration) of domain names is the fundamental registry operation. All other operations are designed to support or compliment a domain creation. The following steps occur when a domain is created.

1. Contact objects are created in the SRS database. The same contact object may be used for each contact type, or they may all be different. If the contacts already exist in the database this step may be skipped.

2. Nameservers are created in the SRS database. Nameservers are not required to complete the registration process; however any domain with less than 2 name servers will not be resolvable.

3. The domain is created using the each of the objects created in the previous steps. In addition, the term and any client statuses may be assigned at the time of creation.

The actual number of EPP transactions needed to complete the registration of a domain name can be as few as one and as many as 40. The latter assumes seven distinct contacts and 13 nameservers, with Check and Create commands submitted for each object.

27.3.2 Update Process

Registry objects may be updated (modified) using the EPP Modify operation. The Update transaction updates the attributes of the object.

For example, the Update operation on a domain name will only allow the following attributes to be updated:

-Domain statuses
-Registrant ID
-Administrative Contact ID
-Billing Contact ID
-Technical Contact ID
-Nameservers
-AuthInfo
-Additional Registrar provided fields.

The Update operation will not modify the details of the contacts. Rather it may be used to associate a different contact object (using the Contact ID) to the domain name. To update the details of the contact object the Update transaction must be applied to the contact itself. For example, if an existing registrant wished to update the postal address, the Registrar would use the Update command to modify the contact object, and not the domain object.

27.3.4 Renew Process

The term of a domain may be extended using the EPP Renew operation. ICANN policy general establishes the maximum term of a domain name to be 10 years, and Neustar recommends not deviating from this policy. A domain may be renewed⁄extended at any point time, even immediately following the initial registration. The only stipulation is that the overall term of the domain name may not exceed 10 years. If a Renew operation is performed with a term value will extend the domain beyond the 10 year limit, the Registry will reject the transaction entirely.

27.3.5 Transfer Process

The EPP Transfer command is used for several domain transfer related operations:

-Initiate a domain transfer
-Cancel a domain transfer
-Approve a domain transfer
- Reject a domain transfer.

To transfer a domain from one Registrar to another the following process is followed:

1. The gaining (new) Registrar submits a Transfer command, which includes the AuthInfo code of the domain name.

2. If the AuthInfo code is valid and the domain is not in a status that does not allow transfers the domain is placed into pendingTransfer status

3. A poll message notifying the losing Registrar of the pending transfer is sent to the Registrarʹs message queue

4. The domain remains in pendingTransfer status for up to 120 hours, or until the losing (current) Registrar Acks (approves) or Nack (rejects) the transfer request

5. If the losing Registrar has not Acked or Nacked the transfer request within the 120 hour timeframe, the Registry auto-approves the transfer

6. The requesting Registrar may cancel the original request up until the transfer has been completed.

A transfer adds an additional year to the term of the domain. In the event that a transfer will cause the domain to exceed the 10 year maximum term, the Registry will add a partial term up to the 10 year limit. Unlike with the Renew operation, the Registry will not reject a transfer operation.

27.3.6 Deletion Process

A domain may be deleted from the SRS using the EPP Delete operation. The Delete operation will result in either the domain being immediately removed from the database or the domain being placed in pendingDelete status. The outcome is dependent on when the domain is deleted. If the domain is deleted within the first five days (120 hours) of registration, the domain is immediately removed from the database. A deletion at any other time will result in the domain being placed in pendingDelete status and entering the Redemption Grace Period (RGP). Additionally, domains that are deleted within five days (120) hours of any billable (add, renew, transfer) transaction may be deleted for credit.

27.4 Applicable Time Elements

The following section explains the time elements that are involved.

27.4.1 Grace Periods

There are six grace periods:

-Add-Delete Grace Period (AGP)
-Renew-Delete Grace Period
-Transfer-Delete Grace Period
-Auto-Renew-Delete Grace Period
-Auto-Renew Grace Period
-Redemption Grace Period (RGP).

The first four grace periods listed above are designed to provide the Registrar with the ability to cancel a revenue transaction (add, renew, or transfer) within a certain period of time and receive a credit for the original transaction.
The following describes each of these grace periods in detail.

27.4.2 Add-Delete Grace Period

The APG is associated with the date the Domain was registered. Domains may be deleted for credit during the initial 120 hours of a registration, and the Registrar will receive a billing credit for the original registration. If the domain is deleted during the Add Grace Period, the domain is dropped from the database immediately and a credit is applied to the Registrarʹs billing account.

27.4.3 Renew-Delete Grace Period

The Renew-Delete Grace Period is associated with the date the Domain was renewed. Domains may be deleted for credit during the 120 hours after a renewal. The grace period is intended to allow Registrars to correct domains that were mistakenly renewed. It should be noted that domains that are deleted during the renew grace period will be placed into pendingDelete and will enter the RGP (see below).

27.4.4 Transfer-Delete Grace Period

The Transfer-Delete Grace Period is associated with the date the Domain was transferred to another Registrar. Domains may be deleted for credit during the 120 hours after a transfer. It should be noted that domains that are deleted during the renew grace period will be placed into pendingDelete and will enter the RGP. A deletion of domain after a transfer is not the method used to correct a transfer mistake. Domains that have been erroneously transferred or hijacked by another party can be transferred back to the original registrar through various means including contacting the Registry.

27.4.5 Auto-Renew-Delete Grace Period

The Auto-Renew-Delete Grace Period is associated with the date the Domain was auto-renewed. Domains may be deleted for credit during the 120 hours after an auto-renewal. The grace period is intended to allow Registrars to correct domains that were mistakenly auto-renewed. It should be noted that domains that are deleted during the auto-renew delete grace period will be placed into pendingDelete and will enter the RGP.

27.4.6 Auto-Renew Grace Period

The Auto-Renew Grace Period is a special grace period intended to provide registrants with an extra amount of time, beyond the expiration date, to renew their domain name. The grace period lasts for 45 days from the expiration date of the domain name. Registrars are not required to provide registrants with the full 45 days of the period.

27.4.7 Redemption Grace Period

The RGP is a special grace period that enables Registrars to restore domains that have been inadvertently deleted but are still in pendingDelete status within the Redemption Grace Period. All domains enter the RGP except those deleted during the AGP.

The RGP period is 30 days, during which time the domain may be restored using the EPP RenewDomain command as described below. Following the 30day RGP period the domain will remain in pendingDelete status for an additional five days, during which time the domain may NOT be restored. The domain is released from the SRS, at the end of the 5 day non-restore period. A restore fee applies and is detailed in the Billing Section. A renewal fee will be automatically applied for any domain past expiration.

Neustar has created a unique restoration process that uses the EPP Renew transaction to restore the domain and fulfill all the reporting obligations required under ICANN policy. The following describes the restoration process.

27.5 State Diagram

Figure 27-1 attached provides a description of the registration lifecycle.

The different states of the lifecycle are active, inactive, locked, pending transfer, and pending delete.Please refer to section 27.2 for detailed descriptions of each of these states. The lines between the states represent triggers that transition a domain from one state to another.

The details of each trigger are described below:

-Create:Registry receives a create domain EPP command.
-WithNS:The domain has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
-WithOutNS:The domain has not met the minimum number of nameservers required by registry policy. The domain will not be in the DNS zone.
-Remove Nameservers: Domainʹs nameserver(s) is removed as part of an update domain EPP command. The total nameserver is below the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
-Add Nameservers: Nameserver(s) has been added to domain as part of an update domain EPP command.The total number of nameservers has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
-Delete: Registry receives a delete domain EPP command.
-DeleteAfterGrace: Domain deletion does not fall within the add grace period.
-DeleteWithinAddGrace:Domain deletion falls within add grace period.
-Restore: Domain is restored.Domain goes back to its original state prior to the delete command.
-Transfer: Transfer request EPP command is received.
-Transfer Approve⁄Cancel⁄Reject:Transfer requested is approved or cancel or rejected.
-TransferProhibited: The domain is in clientTransferProhibited and⁄or serverTranferProhibited status. This will cause the transfer request to fail.The domain goes back to its original state.
-DeleteProhibited: The domain is in clientDeleteProhibited and⁄or serverDeleteProhibited status.This will cause the delete command to fail.The domain goes back to its original state.

Note: the locked state is not represented as a distinct state on the diagram as a domain may be in a locked state in combination with any of the other states: inactive, active, pending transfer, or pending delete.

27.5.1 EPP RFC Consistency

As described above, the domain lifecycle is determined by ICANN policy and the EPP RFCs. Neustar has been operating ICANN TLDs for the past 10 years consistent and compliant with all the ICANN policies and related EPP RFCs.

27.6 Resources

The registration lifecycle and associated business rules are largely determined by policy and business requirements; as such the Product Management and Policy teams will play a critical role in working with Citigroup Inc. (ʺApplicantʺ) to determine the precise rules that meet the requirements of the TLD. Implementation of the lifecycle rules will be the responsibility of Development⁄Engineering team, with testing performed by the Quality Assurance team.Neustarʹs SRS implementation is very flexible and configurable, and in many case development is not required to support business rule changes.

The .CITI registry will be using standard lifecycle rules, and as such no customization is anticipated.However should modifications be required in the future, the necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31.The following resources are available from those teams:

-Development⁄Engineering 19 employees
-Registry Product Management 4 employees

These resources are more than adequate to support the development needs of all the TLDs operated by Neustar, including the .CITI registry.

Abuse within the TLD will not be tolerated.  Citigroup Inc. (ʺApplicantʺ) will implement very strict policies and procedures to minimize abusive registrations and other activities that have a negative impact on Internet users.    

One of Applicant’s primary abuse prevention and mitigation strategies is to ensure that only Applicant registers and Applicant and⁄or its Affiliates (as defined in Applicant’s registration policy) use domain names in the TLD under strict guidelines as set by Applicant.  In order to ensure that Applicant does not register abusive domain names, Applicant has appointed a single group of employees as authorized to register, acquire, and⁄or monitor domain names in the TLD.

As stated elsewhere, Applicant will not allow the registration of any domain names, except for those required by ICANN and for internal business or testing purposes, that resolve to websites for likely one (1) to five (5) years while it conducts marketing and technical studies on how to best operate the TLD.  Accordingly, Applicant will initially register and use only two domain names, namely, [NIC.CITI] to host a homepage that provides Applicant’s contact information and the Abuse Policy and [WHOIS.CITI] to provide access to the TLD’s Whois database.

Any registration of a domain name in the applied-for .CITI gTLD (the ʺTLDʺ) will be guided by internal guidelines that define a set of governance policies and processes for managing Applicant’s portfolio of domain names and sub-domains used internally and externally.  The guidelines will provide that a single group of employees, namely Applicant’s Domain Name Team, which consists of several domain professionals based in North America and Singapore, will review and approve or reject all new domain and sub-domain registrations and transfers that are requested by Applicant’s business divisions and after approval from Applicant’s Legal and Operations & Technology (“O&T”) team.  The Domain Name Team’s role is to facilitate adherence to the guidelines and to review requests with respect to branding, trademark, and technical issues.

The guidelines’ objectives are:

1.	Provide standards and governance for the various aspects of domain names managed and owned by Applicant, considering their domain’s impact on global or corporate areas such as Applicant’s Operations & Technology (“O&T”), Global Branding, and Trademark groups;
2.	Define Applicant’s businesses’ roles and responsibilities in the management of domain names though their life-cycle; and
3.	Support corporate strategies on brand naming and trademark protection in the domain name space. 

Applicant’s guidelines also provide for various representatives of Applicant’s Domain Name Team, O&T Team, Senior Global branding, Corporate Communications, Corporate Technology, Trademark Counsel, and Regional Consumer and Institutional Clients Group (“ICG”) Digital officers to consult on:

•	Reviewing and approving requests during the last month for trends and compliance
•	Reviewing and deciding on exceptions requested in the last month
•	Reviewing and deciding on domain names to be retired
•	Initiating and approving updates to the guidelines
•	Discussing strategic internal and external issues in connection with domain and sub-domain policies and procedures (i.e. ICANN events, new gTLDs, etc.)

The Domain Name Team is further tasked with monitoring domain name data (e.g., ownership, name servers, etc.) and configuration (redirects) in order to guarantee compliance adherence to the guidelines in the long term.  If a domain name is found not compliant, the Domain Name Team will notify the business client to take remedial action and confirm that required changes were made.

Regarding how Applicant will likely structure its domain names, if displayed to the public, the Domain Name Team will only be allowed to register or acquire domain names for approved business purposes that consist of a generic qualifier followed by an existing, approved primary domain name corresponding to one of Applicant’s brand or business names under Applicant’s branding standards or a modifier after the TLD.  A generic qualifier is defined as a clear, straightforward term that corresponds to the services offered on the particular Website or pages, e.g., college.citicards.citi or cashtradetreasury.citibank.citi.  A modifier is a “subdirectory” of a domain name (each term is separated by a slash) that identifies a particular web page or web site on the TLD server. In the example “www.citigroup.tld⁄corporaterealtyservices” “corporaterealtyservices” is the subdirectory⁄modifier.  Names that do not have this structure require branding approval and trademark review and⁄or clearance and will be reviewed by the Domain Name Team.  Non-standard domain names will be redirected to primary Applicant websites.  

The guidelines also provide that all domain names or sub-domains owned and managed by Applicant that include or reference a third party brand or trademark require written approval, through license or otherwise, from the third party granting permission to Applicant to use its brand name in the specific URL.  

With these and other policies in place regarding sub-domains, intranet websites, subdirectories, vanity domain names, re-registration, domain retirement, among others, Applicant will have a strong and robust internal structure prepared to avoid and root out any abusive domain name registration and⁄or use in the applied-for TLD.

Anti-Abuse Policy

Applicant will implement in its internal guidelines and its Registrar and Registration agreements that all domain names in the TLD will be subject to this Domain Name Anti-Abuse Policy (“Abuse Policy”).

The Abuse Policy will provide Applicant with broad power to suspend, cancel, or transfer domain names that violate the Abuse Policy.  Applicant will publish the Abuse Policy on its website at NIC.CITI and clearly  provide Applicant’s Abuse Point of Contact (“Abuse Contact”) and its contact information.  This information shall consist of, at a minimum, a valid e-mail address dedicated solely to the handling of abuse complaints, and a telephone number, mailing address, and fax number for the Abuse Contact.  Applicant will ensure that this information will be kept accurate and up to date and will be provided to ICANN if and when changes are made.  

Inquiries addressed to the Abuse Contact will be forwarded to Applicant’s Intellectual Property Legal Team, which currently consists of four (4) lawyers, who will review with possible consultation with outside counsel (together, Applicant’s “Legal Team”) and if applicable remedy any Complaint regarding an alleged violation of the Abuse Policy as described in more detail below.  Applicant will catalog all abuse communications and provide them to third parties within a reasonable time under limited circumstances, such as in response to a subpoena or other such court order or demonstrated official need by law enforcement.

The Abuse Policy will state, at a minimum, that Applicant reserves the right to deny, cancel, or transfer any registration or transaction, or place any domain name(s) on registry lock, hold, or similar status, that it deems necessary, in its discretion; (1) to protect the integrity and stability of the registry; (2) to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of Applicant, as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement or any agreement Applicant has with any party; (5) to correct mistakes made by the Applicant, registry services provider, or any registrar in connection with a domain name registration; (6) during resolution of any dispute regarding the domain; and (7) if a registrant’s pre-authorization fails.

The Abuse Policy will define the abusive use of domain names to include, but not be limited to, the following activities:

•	Illegal or fraudulent actions: use of the Applicant’s or Registrarʹs services to violate the laws or regulations of any country, state, or other jurisdiction in which the Internet may operate, or in a manner that adversely affects the legal rights of any other person;
•	Spam: use of electronic messaging systems from email addresses from domains in the TLD to send unsolicited bulk messages. The term applies to e-mail spam and similar abuses such as instant messaging spam, mobile messaging spam, and the spamming of Web sites and Internet forums;
•	Phishing: use of counterfeit Web pages within the TLD that are designed to trick recipients into divulging sensitive data such as usernames, passwords, or financial data;
•	Pharming: redirecting of unknowing users to fraudulent Web sites or services, typically through DNS hijacking or poisoning;
•	Willful distribution of malware: dissemination of software designed to infiltrate or damage a computer system without the ownerʹs informed consent.  Examples include, without limitation, computer viruses, worms, keyloggers, and trojan horses.
•	Fast flux hosting: use of fast-flux techniques to disguise the location of Web sites or other Internet services, or to avoid detection and mitigation efforts, or to host illegal activities. Fast-flux techniques use DNS to frequently change the location on the Internet to which the domain name of an Internet host or name server resolves. Fast flux hosting may be used only with prior permission of PIR;
•	Botnet command and control: services run on a domain name that are used to control a collection of compromised computers or ʺzombies,ʺ or to direct denial-of-service attacks (DDoS attacks);
•	Distribution of pornography;
•	Illegal Access to Other Computers or Networks: illegally accessing computers, accounts, or networks belonging to another party, or attempting to penetrate security measures of another individualʹs system (often known as ʺhackingʺ). Also, any activity that might be used as a precursor to an attempted system penetration (e.g., port scan, stealth scan, or other information gathering activity);
•	Non-intended Use: use of the domain name other than that which was stated during the registration, without a change of intended use accepted by Applicant;
•	Reselling Domain Names: resale of a domain name will not be accepted by Applicant or any registrar during the life of the TLD;
•	Cybersquatting: registration of a domain name confusingly similar to a third party’s name or trademark without any legitimate interest in the name and in bad faith;
•	Domain Kiting⁄Tasting: registration of domain names to test their commercial viability before returning them during a Grace Period;
•	High Volume Registrations⁄Surveying: registration of multiple domain names in order to warehouse them for sale or pay-per-click websites in a way that can impede Applicant from offering them to legitimate users or timely services to other subscribers;
•	Inadequate Security: registering and using a domain name to host a website that collects third-party information but does not employ adequate security measures to protect third-party information in accordance with that geographic area’s data and financial privacy laws.

Domain Anti-Abuse Procedure

Applicant will provide a domain name anti-abuse procedure (“Abuse Procedure”) modeled after the Digital Millennium Copyright Act’s notice-and-takedown procedure.  At all times, Applicant will publish on its website at NIC.CITI the Abuse Policy and Abuse Procedure and the contact information for the Abuse Contact.  The Abuse Procedure will specify that it is recommended that any correspondence (“Complaint”) be sent by both fax and email, that any email include “Notice of Alleged Abuse” in the subject line of the email, and that all Complaints specify the type of abuse at issue as defined in the Abuse Policy. 

Inquiries addressed to the Abuse Contact will be received by Legal Team who will remedy or deny any Complaint regarding an alleged violation of the Abuse Policy.  Applicant will catalog all abuse communications and provide them to third parties only under limited circumstances, such as in response to a subpoena or other such court order or demonstrated official need by law enforcement.

Legal Team will first give the Complaint a “quick look” to see if the Complaint reasonably falls within an abusive use as defined by the Abuse Policy.  If not, the Abuse Contact will write a timely correspondence to Complainant stating that the subject of the complaint clearly does not fall within one of the delineated abusive uses as defined by the Abuse Policy and that Applicant considers the matter closed.

If the quick look does not resolve the matter, Legal Team will timely give the Complaint a full review.  If an abusive use is determined, the Abuse Contact will alert the registry services provider to immediately suspend the resolution of the domain name.  Legal Team will then immediately notify the registrant of the suspension of the domain name, the nature of the complaint, and provide the registrant with the option to respond within a timely fashion or the domain name will be canceled.  

If the registrant responds within a timely period, its response will be reviewed by Legal Team for further review.  If Legal Team is satisfied by the registrant’s response that the use is not abusive, Legal Team will submit a timely request to the registry services provider to unsuspend the domain name.  The Abuse Contact will then timely notify the Complainant that its complaint was ultimately denied and provide the reasons for the denial.  If the registrant does not respond within a timely fashion, the Abuse Contact will notify the registry services provider to cancel the abusive domain name.

This Abuse Procedure will not prejudice either party’s election to pursue another dispute mechanism, such as URS or UDRP.

With the assistance of its back-end registry services provider, Applicant will meet its obligations under Section 2.8 of the Registry Agreement to take reasonable steps to investigate and respond to reports from law enforcement and governmental and quasi-governmental agencies of illegal conduct in connection with the use of its TLD.  Accordingly, Applicant will timely respond to legitimate law enforcement inquiries.  Any such response shall include, at a minimum, a timely acknowledgement of receipt of the request, questions or comments concerning the request, and an outline of the next steps to be taken by Applicant for a timely resolution of the request.  

In the event such request involves any of the activities which can be validated by Applicant’s Legal Team and involves the type of activity set forth in the Abuse Policy, Abuse Contact will timely notify the registry services provider to either suspend or cancel the domain name.  If Legal Team determines that it is not an abusive activity, Abuse Contact will timely provide the relevant law enforcement, governmental and⁄or quasi-governmental agency a compelling argument to keep the name in the zone.

Whois Accuracy

Applicant will provide WHOIS accessibility in a reliable, consistent, and predictable fashion in order to promote Whois accuracy.  The TLD will adhere to port 43 WHOIS Service Level Agreements (SLAs), which require that port 43 WHOIS service be highly accessible and fast.  

Applicant will offer thick WHOIS services, in which all authoritative WHOIS data—including contact data—is maintained at the registry.  Through Applicant’s registrar and registry services operators, Applicant will maintain timely, unrestricted, and public access to accurate and complete WHOIS information, including all data objects as specified in Specification 4.  Moreover, prior to the release of any domain names, Applicant’s registrar will provide Applicant’s Domain Name Team with an authorization code to provide when registering domain names, and Applicant’s Domain Name Team will provide registrar with authorized registrant contact information to verify upon the attempted registration of any domain names.  Upon registration, registrar will verify the authorization code and contact information before the prospective registrant is allowed to proceed.

In order to further promote WHOIS accuracy, Applicant will offer a mechanism duly posted on its WHOIS.CITI website whereby third parties can submit complaints directly to the Applicant’s Domain Name Team (as opposed to ICANN or the sponsoring Registrar) about inaccurate or incomplete WHOIS data.  Such information shall be forwarded to the registrar, who shall be required to address those complaints with their registrants.  Within a reasonable time period after forwarding the complaint to the registrar, Domain Name Team will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition.  If the registrar has failed to take any action, or it is clear that the registrant was either unwilling or unable to correct the inaccuracies, Applicant reserves the right to suspend the applicable domain name(s) until such time as the registrant is able to cure the deficiencies.

In addition, Applicant’s Domain Name Team will at least twice per year perform a manual review of a random sampling of domain names within the applied-for TLD to test the accuracy of the WHOIS information.  Through this review, Applicant’s Domain Name Team will examine the WHOIS data for evidence of inaccurate or incomplete Whois information.  In the event that such errors or missing information exists, it shall be forwarded to the registrar, who shall be required to address such deficiencies with their registrants.  Within a reasonable time period, Domain Name Team will examine the current WHOIS data for names that were alleged to be inaccurate or incomplete to determine if the information was corrected, the domain name was deleted, or there was some other disposition.  If the registrar has failed to take any action, or it is clear that the registrant was either unwilling or unable to correct the inaccuracies, Applicant reserves the right to suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.

Abuse Prevention and Mitigation – Domain Name Access

All domain name registrants will have adequate controls to ensure proper access to domain functions.

In addition to the above, all domain name registrations in the applied-for TLD will be required to name at least two (2) unique points of contact within Applicant’s Domain Name Team, all of whom will be authorized to request and⁄or approve update, transfer, and deletion requests.  The points of contact will establish strong passwords with the registrar that along with at least one other authentication factor must be authenticated before a point of contact will be allowed to process updates, transfer, and deletion requests.  Once a process update, transfer, or deletion request is entered, all of the points of contact will automatically be notified when a domain has been updated, transferred, or deleted through by Applicant’s registrar.

28.1 Abuse Prevention and Mitigation

Strong abuse prevention of a new gTLD is an important benefit to the internet community.  TLD and its registry operator and back-end registry services provider, Neustar, agree that  a registry must not only aim for the highest standards of technical and operational competence, but also needs to act as a steward of the space on behalf of the Internet community and ICANN in promoting the public interest.   Neustar brings extensive experience establishing and implementing registration policies.  This experience will be leveraged to help TLD combat abusive and malicious domain activity within the new gTLD space.

One of those public interest functions for a responsible domain name registry includes working towards the eradication of abusive domain name registrations, including, but not limited to, those resulting from:

	Illegal or fraudulent actions 
	Spam
	Phishing
	Pharming 
	Distribution of malware 
	Fast flux hosting 
	 Botnets 
	Distribution of child pornography 
	Online sale or distribution of illegal pharmaceuticals.

More specifically, although traditionally botnets have used Internet Relay Chat (IRC) servers to control registry and the compromised PCs, or bots, for DDoS attacks and the theft of personal information, an increasingly popular technique, known as fast-flux DNS, allows botnets to use a multitude of servers to hide a key host or to create a highly-available control network. This ability to shift the attacker’s infrastructure over a multitude of servers in various countries creates an obstacle for law enforcement and security researchers to mitigate the effects of these botnets. But a point of weakness in this scheme is its dependence on DNS for its translation services. By taking an active role in researching and monitoring these sorts of botnets, Applicant’s partner, Neustar, has developed the ability to efficiently work with various law enforcement and security communities to begin a new phase of mitigation of these types of threats.

Policies and Procedures to Minimize Abusive Registrations
A Registry must have the policies, resources, personnel, and expertise in place to combat such abusive DNS practices.  As TLDʹs registry provider, Neustar is at the forefront of the prevention of such abusive practices and is one of the few registry operators to have actually developed and implemented an active “domain takedown” policy. We also believe that a strong program is essential given that registrants have a reasonable expectation that they are in control of the data associated with their domains, especially its presence in the DNS zone. Because domain names are sometimes used as a mechanism to enable various illegitimate activities on the Internet often the best preventative measure to thwart these attacks is to remove the names completely from the DNS before they can impart harm, not only to the domain name registrant, but also to millions of unsuspecting Internet users.

Removing the domain name from the zone has the effect of shutting down all activity associated with the domain name, including the use of all websites and e-mail.  The use of this technique should not be entered into lightly. .CITI has an extensive, defined, and documented process for taking the necessary action of removing a domain from the zone when its presence in the zone poses a threat to the security and stability of the infrastructure of the Internet or the registry. 

28.3 Measures for Removal of Orphan Glue Records

As the Security and Stability Advisory Committee of ICANN (SSAC) rightly acknowledges, although orphaned glue records may be used for abusive or malicious purposes, the “dominant use of orphaned glue supports the correct and ordinary operation of the DNS.”  See http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf.  

While orphan glue often support correct and ordinary operation of the DNS, we understand that such glue records can be used maliciously to point to name servers that host domains used in illegal phishing, bot-nets, malware, and other abusive behaviors. Problems occur when the parent domain of the glue record is deleted but its children glue records still remain in DNS.   Therefore, when the Registry  has written evidence of actual abuse of orphaned glue, the Registry will take action to remove those records from the zone to mitigate such malicious conduct.   

Neustar runs a daily audit of entries in its DNS systems and compares those with its provisioning system. This serves as an umbrella protection to make sure that items in the DNS zone are valid. Any DNS record that shows up in the DNS zone but not in the provisioning system will be flagged for investigation and removed if necessary. This daily DNS audit serves to not only prevent orphaned hosts but also other records that should not be in the zone.  

In addition, if either .CITI or Neustar become aware of actual abuse on orphaned glue after receiving written notification by a third party through its Abuse Contact or through its customer support, such glue records will be removed from the zone.

28.5 Resourcing Plans 
Responsibility for abuse mitigation rests with a variety of functional groups.  The Legal Team is primarily responsible for providing analysis and conducting investigations of reports of abuse.  The customer service team also plays an important role in assisting with the investigations, responded to customers, and notifying registrars of abusive domains.  Finally, the Policy⁄Legal team is responsible for developing the relevant policies and procedures.  

The necessary resources from Neustar will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:

Customer Support – 12 employees

Policy⁄Legal – 2 employees

The resources are more than adequate to support the abuse mitigation procedures of the .CITI registry.

Use of domain names that infringe upon the legal rights of others in the TLD will not be tolerated and preventing abusive registrations is a core objective of Citigroup, Inc. (ʺApplicantʺ).  The nature of such uses creates security and stability issues for the registry, registrars, and registrants, as well as for users of the Internet in general.  Primarily, Applicant will prevent abusive registrations by allowing only Applicant to register and Applicant and⁄or its Affiliates (as defined in Applicant’s Registration Policy) to use domain names in the registry under strict internal registration, anti-abuse and rights protection guidelines as defined in its Abuse Policy.  In order to identify and address the abusive use of registered names on an ongoing basis, Applicant 
promises to additionally incorporate and abide by the following Rights Protection Mechanisms and all other rights protection mechanisms as specified in Specification 7 of the Registry Agreement and as adopted by the ICANN Board of Directors as ICANN Consensus Policies.

Anti-Abuse Policy

Applicant will implement in its internal guidelines and its Registrar and Registration agreements that all domain names in the TLD will be subject to this Domain Name Anti-Abuse Policy (“Abuse Policy”).

The Abuse Policy will provide Applicant with broad power to suspend, cancel, or transfer domain names that violate the Abuse Policy.  Applicant will publish the Abuse Policy on its website at NIC.CITI and clearly provide Applicant’s Abuse Point of Contact (“Abuse Contact”) and its contact information.  This information shall consist of, at a minimum, a valid e-mail address dedicated solely to the handling of abuse complaints, and a telephone number, mailing address, and fax number for the Abuse Contact.  Applicant will ensure that this information will be kept accurate and up to date and will be provided to ICANN if and when changes are made.  

Inquiries addressed to the Abuse Contact will be forwarded to Applicant’s Intellectual Property Legal Team, which currently consists of four (4) lawyers, who will review with possible consultation with outside counsel (together, Applicant’s “Legal Team”) and if applicable remedy any Complaint regarding an alleged violation of the Abuse Policy as described in more detail below.  Applicant will catalog all abuse communications and provide them to third parties within a reasonable time under limited circumstances, such as in response to a subpoena or other such court order or demonstrated official need by law enforcement.

The Abuse Policy will state, at a minimum, that Applicant reserves the right to deny, cancel, or transfer any registration or transaction, or place any domain name(s) on registry lock, hold, or similar status, that it deems necessary, in its discretion; (1) to protect the integrity and stability of the registry; (2) to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of Applicant, as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement or any agreement Applicant has with any party; (5) to correct mistakes made by the Applicant, registry services provider, or any registrar in connection with a domain name registration; (6) during resolution of any dispute regarding the domain; and (7) if a registrant’s pre-authorization fails.

The Abuse Policy will define the abusive use of domain names to include, but not be limited to, the following activities:

•	Illegal or fraudulent actions: use of the Applicant’s or Registrarʹs services to violate the laws or regulations of any country, state, or other jurisdiction in which the Internet may operate, or in a manner that adversely affects the legal rights of any other person;
•	Spam: use of electronic messaging systems from email addresses from domains in the TLD to send unsolicited bulk messages. The term applies to e-mail spam and similar abuses such as instant messaging spam, mobile messaging spam, and the spamming of Web sites and Internet forums;
•	Phishing: use of counterfeit Web pages within the TLD that are designed to trick recipients into divulging sensitive data such as usernames, passwords, or financial data;
•	Pharming: redirecting of unknowing users to fraudulent Web sites or services, typically through DNS hijacking or poisoning;
•	Willful distribution of malware: dissemination of software designed to infiltrate or damage a computer system without the ownerʹs informed consent.  Examples include, without limitation, computer viruses, worms, keyloggers, and trojan horses.
•	Fast flux hosting: use of fast-flux techniques to disguise the location of Web sites or other Internet services, or to avoid detection and mitigation efforts, or to host illegal activities. Fast-flux techniques use DNS to frequently change the location on the Internet to which the domain name of an Internet host or name server resolves. Fast flux hosting may be used only with prior permission of PIR;
•	Botnet command and control: services run on a domain name that are used to control a collection of compromised computers or ʺzombies,ʺ or to direct denial-of-service attacks (DDoS attacks);
•	Distribution of pornography;
•	Illegal Access to Other Computers or Networks: illegally accessing computers, accounts, or networks belonging to another party, or attempting to penetrate security measures of another individualʹs system (often known as ʺhackingʺ). Also, any activity that might be used as a precursor to an attempted system penetration (e.g., port scan, stealth scan, or other information gathering activity);
•	Non-intended Use: use of the domain name other than that which was stated during the registration, without a change of intended use accepted by Applicant;
•	Reselling Domain Names: resale of a domain name will not be accepted by Applicant or any registrar during the life of the TLD;
•	Cybersquatting: registration of a domain name confusingly similar to a third party’s name or trademark without any legitimate interest in the name and in bad faith;
•	Domain Kiting⁄Tasting: registration of domain names to test their commercial viability before returning them during a Grace Period;
•	High Volume Registrations⁄Surveying: registration of multiple domain names in order to warehouse them for sale or pay-per-click websites in a way that can impede Applicant from offering them to legitimate users or timely services to other subscribers;
•	Inadequate Security: registering and using a domain name to host a website that collects third-party information but does not employ adequate security measures to protect third-party information in accordance with that geographic area’s data and financial privacy laws.

Domain Anti-Abuse Procedure

Applicant will provide a domain name anti-abuse procedure (“Abuse Procedure”) modeled after the Digital Millennium Copyright Act’s notice-and-takedown procedure and detailed in Question 28.  At all times, Applicant will publish on its website at NIC.CITI the Abuse Policy and Abuse Procedure and the contact information for the Abuse Contact.  The Abuse Procedure will specify that it is recommended that any correspondence (“Complaint”) be sent by both fax and email, that any email include “Notice of Alleged Abuse” in the subject line of the email, and that all Complaints specify the type of abuse at issue as defined in the Abuse Policy.

Trademark Clearinghouse

The first mandatory rights protection mechanism (“RPM”) required to be implemented by each new gTLD Registry is support for, and interaction with, the Trademark Clearinghouse.  The Trademark Clearinghouse is intended to serve as a central repository for information to be authenticated, stored, and disseminated pertaining to the rights of trademark holders.  The data maintained in the clearinghouse will support and facilitate other RPMs, including the mandatory Sunrise Period and Trademark Claims service.  Although many of the details of how the Trademark Clearinghouse will interact with each registry operator and registrars are still being developed by ICANN, Applicant is actively monitoring the developments of the Implementation Assistance Group (“IAG”) designed to assist ICANN staff in refining and finalizing the rules and procedures associated with the policies and technical requirements for the Trademark Clearinghouse.  

Utilizing the Trademark Clearinghouse, all operators of new gTLDs must offer: (i) a Sunrise registration service for at least 30 days during the pre-launch phase giving eligible trademark owners an early opportunity to register second-level domains in new gTLDs; and (ii) a Trademark Claims service for at least the first 60 days that second-level registrations are open. The Trademark Claim service is intended to provide clear notice to a potential registrant of the rights of a trademark owner whose trademark is registered in the clearinghouse.

Sunrise Period

All domain names registered during the Sunrise Period will be subject to Applicant’s domain name registration policy, namely, that all registrants be Applicant.  Applicant will offer a Sunrise Period of sixty (60) days for owners of trademarks listed in the Trademark Clearinghouse that also meet applicant’s domain name registration requirements to register domain names that consist of an identical match of their listed trademarks.  Applicant’s Intellectual Property Legal Team, which currently consists of four (4) lawyers, will receive and authenticate with possible consultation with outside counsel (together, Applicant’s “Legal Team”) all Sunrise Registrations.  

Applicant’s registrar will ensure that all Sunrise Registrants meet sunrise eligibility requirements (SERs), which will be verified by Clearinghouse data.  The proposed SERs include: (i) ownership of a mark that is (a) nationally or regionally registered and for which proof of use, such as a declaration and a single specimen of current use – was submitted to, and validated by, the Trademark Clearinghouse; or (b) that have been court-validated; or (c) that are specifically protected by a statute or treaty currently in effect and that was in effect on or before 26 June 2008, (ii) optional registry elected requirements re: international class of goods or services covered by registration; (iii) representation that all provided information is true and correct; and (iv) provision of data sufficient to document rights in the trademark.  

Upon submission of all of the required information and documentation, registrar will forward the information to Applicant’s Legal Team for authentication.  Legal Team will review the information and documentation and verify the trademark information and registration eligibility, and notify the potential registrant of any deficiencies.  If a registrant does not cure any deficiencies and⁄or respond by the means listed within a timely matter, Applicant will notify its registrar and the domain name will be released for registration.  

Applicant will incorporate a Sunrise Dispute Resolution Policy (SDRP).  The SRDP will allow challenges to Sunrise Registrations by third parties for a ten-day period after acceptance of the registration based on the following four grounds: (i) at time the challenged domain name was registered, the registrant did not hold a trademark registration of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; (ii) the domain name is not identical to the mark on which the registrant based its Sunrise registration; (iii) the trademark registration on which the registrant based its Sunrise registration is not of national or regional effect or the trademark had not been court-validated or protected by statute or treaty; or (iv) the trademark registration on which the domain name registrant based its Sunrise registration did not issue on or before the effective date of the Registry Agreement and was not applied for on or before ICANN announced the applications received.

After receiving a Sunrise Complaint, Legal Team will review the Complaint to see if the Complaint reasonably asserts a legitimate challenge as defined by the SDRP.  If not, Legal Team will timely send an email to the Complainant that the subject of the complaint clearly does not fall within one of the delineated grounds as defined by the SDRP and that Applicant considers the matter closed.

If the domain name is not found to have adequately met the SERs, Legal Team will alert the registrar and registry services provider to immediately suspend the resolution of the domain name.  Thereafter, Legal Team will immediately notify the Sunrise Registrant of the suspension of the domain name, the nature of the complaint, and provide the registrant with the option to timely cure the SER deficiencies or the domain name will be canceled.  

If the registrant timely responds, its response will be reviewed by Legal Team to determine if the SERs are met.  If Legal Team is satisfied by the registrant’s response, Legal Team will timely submit a request to the registrar and the registry services provider to unsuspend the domain name.  If registrant does not timely respond, Legal Team will then timely notify the Complainant that its complaint was ultimately denied and provide the reasons for the denial.

Trademark Claims Service

Applicant will offer a Trademark Claims Service during the first one hundred and twenty (120) days of general registration.  The Trademark Claims Service will be monitored by Legal Team, and will receive all communications regarding the Trademark Claims service and catalog them.  Applicant’s registrar will be required to review all domain names requested to be registered during the Trademark Claims period to determine if they are an identical match of a trademark that has been filed with the Trademark Clearinghouse and they meet Applicant’s domain name registration requirements.  A domain name will be considered an identical match when the domain name consists of the complete and identical textual elements of the mark, and includes domain names where (a) spaces contained within a mark that are either replaced by hyphens (and vice versa) or omitted; (b) certain special characters contained within a trademark are spelled out with appropriate words describing it (e.g., @ and &); and (c) punctuation or special characters contained within a mark that are unable to be used in a second-level domain name are either (i) omitted or (ii) replaced by spaces, hyphens or underscores.  Domain names that are plural forms of a mark or that merely contain a mark will not qualify as an identical match.

If the registrar determines that a prospective domain name registration is identical to a mark registered in the Trademark Clearinghouse, the registrar will be required to ensure that a “Trademark Claims Notice” (“Notice”) in English is sent to the prospective registrant of the domain name and blind copy Legal Team on all such correspondence.  The Notice will provide the prospective registrant information regarding the trademark referenced in the Trademark Claims Notice to enhance understanding of the Trademark rights being claimed by the trademark holder.  The Notice will be provided in real time without cost to the prospective registrant. 

After sending the Notice, the registrar will be required to require that the prospective registrant specifically warrant within five (5) days that: (i) the prospective registrant has received notification that the mark(s) is included in the Clearinghouse; (ii) the prospective registrant has received and understood the notice; and (iii) to the best of the prospective registrant’s knowledge that the registration and use of the requested domain name will not infringe on the rights that are the subject of the notice.  If the warranty satisfies these requirements, the registrar will be required to effectuate the registration and notify Legal Team.  

After the effectuation of a registration that is identical to a mark listed in the Trademark Clearinghouse, the registrar will be required to then ensure that a clear notice to the trademark owner of the trademark consisting of the domain name that has been registered and will blind copy Legal Team confirming that it has done so.  The trademark owner then has the option of filing a Complaint under the Uniform Domain Name Dispute Resolution Policy (UDRP) and the Uniform Rapid Suspension System (URS) against the domain name, as the Applicant will require in its domain name registration agreements that the registry, registrar, and registrant all submit to the Uniform Domain Name Dispute Resolution Policy (UDRP) and the Uniform Rapid Suspension (URS) system.  Applicant will require its registrar and registry service operators to abide by decisions rendered under the UDRP and URS in a timely and ongoing basis.

Uniform Rapid Suspension System (URS)

Applicant will specify in its Registry-Registrar and Registration Agreements used in connection with the TLD that all parties will timely abide by all decisions made by panels in accordance with the Uniform Rapid Suspension System (URS).  On Applicant’s NIC.CITI website, Applicant will designate a Rights Protection Contact (“Rights Contact”) that will receive all URS Complaints verified by the URS Provider and provide its contact information.  This information shall consist of, at a minimum, a valid e-mail address dedicated solely to the handling of rights protection complaints, and a telephone number, mailing address, and fax number for the Rights Contact.  Applicant will ensure that this information will be kept accurate and up to date and will be provided to ICANN if and when changes are made. 

Within 24 hours of receipt of the Notice of Complaint from the URS Provider, the Rights Contact shall notify its registry operator to “lock” the domain, meaning the registry shall restrict all changes to the registration data, including transfer and deletion of the domain names, but the name will continue to resolve.  The Rights Contact will notify the URS Provider immediately upon locking the domain name (”Notice of Lock”).  

Immediately upon receipt of a Determination in the Complainant’s favor, Rights Contact will notify the registry operator to suspend the domain name, which shall remain suspended for the balance of the registration period and will not resolve to the original web site.  The nameservers shall be redirected to an informational web page provided by the URS Provider about the URS.  The Whois for the domain name shall continue to display all of the information of the original Registrant except for the redirection of the nameservers.  In addition, the Whois shall reflect that the domain name will not be able to be transferred, deleted or modified for the life of the registration.  Finally, Applicant will be sure to abide by any timely requests by Complainant to extend the registration period for one additional year at commercial rates.  Legal Team will catalog all abuse communications, but only provide them to third-parties under limited circumstances, such as in response to a subpoena or other such court order or demonstrated official need by law enforcement. 

Immediately upon receipt of a Determination in registrant’s favor, Rights Contact will notify the registry operator to unlock the domain name.

Uniform Domain Name Dispute Resolution Policy (UDRP)

Applicant will specify in its Registry-Registrar and Registration Agreements used in connection with the TLD that all parties will timely abide by all decisions made by panels in accordance with the Uniform Domain Name Dispute Resolution Policy (UDRP).  Applicant’s Rights Contact will receive all UDRP Complaints and decisions, temporarily lock any domain names as required, and will notify its registrar to timely cancel or transfer all registrations determined to by a UDRP panel to be infringing.  Legal Team will catalog all abuse communications, but only provide them to third-parties under limited circumstances, such as in response to a subpoena or other such court order or demonstrated official need by law enforcement.

Trademark Post-Delegation Dispute Resolution Procedure (Trademark PDDRP)

Applicant will participate in all post-delegation procedures, including the Trademark Post-Delegation Dispute Resolution Procedure (Trademark PDDRP), and will timely abide by any Determinations of any PDDRP Provider after exhaustion of all appeals and⁄or times to appeal or other determination challenges.

Registry Restrictions Dispute Resolution Procedure (RRDRP)

Because the application is not community-based, Applicant is not required to participate in the RRDRP and will not be bound by any Determinations of a RRDRP Provider.

Proven Registrars

Applicant intends that only Applicant will be permitted to register domain names in the TLD for its own exclusive use.  Hence, Applicant is exempt from the Registry Operator Code of Conduct (“ROCC”) as detailed in Specification 9 of the Registry Agreement with ICANN.  Thus, as Applicant is not required to grant access to the TLD to all registrars, and in order to reduce abusive registrations and other activities that affect the legal rights of others, Applicant will only contract with one ICANN-accredited registrar that has proven capable of providing adequate defenses against abusive registrations and superior response capabilities.  The registrar, according to the Registry-Registrar agreement, will not be able to register any domain names, thus eliminating the possibility of front-running.  The Registrar will also agree not to submit fake renewal notices.  Any evidence of abusive behavior on the part of the Registrar will be promptly reported to ICANN Compliance.

Pre-Authorization and Authentication

Prior to the release of any domain names, Applicant will designate that only its Domain Name Team will be authorized to register domain names within the TLD under strict domain name registration guidelines.  As part of these guidelines, Applicant will provide Applicant’s registrar with identification criteria so that only Applicant’s Domain Name Team will be authorized to register domain names with in the TLD and registrar can verify potential authorized registrants.  Accordingly, prior to any domain name registration, Applicant’s Domain Name Team will provide registrar with this identification criteria.  Then, Applicant’s registrar will verify and authenticate the identification criteria before the prospective registrant is allowed to proceed.  

In addition, Applicant’s Domain Name Team will at least twice per year perform a manual review of a random sampling of domain names within the applied-for .CITI gTLD (the ʺTLDʺ) to test the accuracy and authenticity of the WHOIS information.  Through this review, Domain Name Team will examine the WHOIS data for evidence of inaccurate or incomplete Whois information.  In the event that such errors or missing information exists, it shall be forwarded to the registrar, who shall be required to address such deficiencies with their registrants.  Within a reasonable time period, Domain Name Team will examine the current WHOIS data for names that were alleged to be inaccurate or incomplete to determine if the information was corrected, the domain name was deleted, or there was some other disposition.  If the registrar has failed to take any action, or it is clear that the registrant was either unwilling or unable to correct the inaccuracies, Applicant reserves the right to suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.

Thick Whois

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

Takedown Procedure

Applicant will provide a Rights Protection Takedown Procedure (“Takedown Procedure”) modeled after the Digital Millennium Copyright Act’s notice-and-takedown procedure.

At all times, Applicant will publish on its home website at NIC.CITI contact information for receiving rights protection complaints (Complaints) from rightsholders.  At all times, Applicant will publish on its website at NIC.CITI the Takedown Procedure and the contact information for the Rights Contact.  The Takedown Procedure will specify that it is recommended that any correspondence (“Complaint”) be sent by both fax and email, that any email include “Notice of Alleged Rights Infringement” in the subject line of the email, and that all Complaints specify the type of rights infringement at issue.

Inquiries addressed to the Rights Contact will be forwarded Applicant’s Legal Team who will remedy or deny any Complaint regarding an alleged violation of the rights of the Complainant.  Applicant will catalog all rights infringement communications and provide them to third parties only under limited circumstances, such as in response to a subpoena or other such court order or demonstrated official need by law enforcement.

During the review of any Complaint, Legal Team will first give the Complaint a “quick look” to see if the Complaint reasonably alleges the infringement of any legal right.  If not, the Rights Contact will write a timely correspondence to Complainant stating that the subject of the complaint clearly does not violate its rights.

If the quick look does not resolve the matter, Legal Team will timely give the Complaint a full review.  If a rights infringement is determined, the Rights Contact will alert the registry services provider to immediately suspend the resolution of the domain name.  Legal Team will then immediately notify the registrant of the suspension of the domain name, the nature of the complaint, and provide the registrant with the option to respond or take down the infringing content within a timely fashion or the domain name will be canceled.  

If the registrant responds within a timely period, its response will be reviewed by Legal Team for further review.  If Legal Team is satisfied by the registrant’s response that no rights have been infringed, Legal Team will submit a timely request to the registry services provider to unsuspend the domain name.  The Rights Contact will then timely notify the Complainant that its complaint was ultimately denied and provide the reasons for the denial.  If the registrant does not respond within a timely fashion, the Rights Contact will notify the registry services provider to cancel the abusive domain name.

This Takedown Procedure will not prejudice either party’s election to pursue another dispute mechanism, such as URS or UDRP.

With the assistance of its back-end registry services provider, Applicant will meet its obligations under Section 2.8 of the Registry Agreement to take reasonable steps to investigate and respond to reports from law enforcement and governmental and quasi-governmental agencies of illegal conduct in connection with the use of its TLD.  Applicant will accordingly timely respond to legitimate law enforcement inquiries.  Any such response shall include, at a minimum, an acknowledgement of receipt of the request, questions or comments concerning the request, and an outline of the next steps to be taken by Applicant for a timely resolution of the request.  

In the event such request involves any infringing activity which can be validated by Legal Team, Rights Contact will timely notify the registry services provider to either suspend the domain name until the infringing activity is cured or cancel the domain name.  If Legal Team determines that it is not an infringing activity, Rights Contact will provide the relevant law enforcement, governmental and⁄or quasi-governmental agency a compelling argument to keep the name in the zone.

Neustar and Trademark Clearinghouse Including Sunrise and Trademark Claims

Applicant’s registry service provider, Neustar, has already implemented Sunrise and⁄or Trademark Claims programs for numerous TLDs including .biz, .us, .travel, .tel and .co and will implement the both of these services on behalf of theTLD. 

Neustar’s Experience in Implementing Sunrise and Trademark Claims Processes

In early 2002, Neustar became the first registry operator to launch a successful authenticated Sunrise process.  This process permitted qualified trademark owners to pre-register their trademarks as domain names in the .us TLD space prior to the opening of the space to the general public.  Unlike any other “Sunrise” plans implemented (or proposed before that time), Neustar validated the authenticity of Trademark applications and registrations with the United States Patent and Trademark Office (USPTO).  

Subsequently, as the back-end registry operator for the .tel gTLD and the .co ccTLD, Neustar launched validated Sunrise programs employing processes.  These programs are very similar to those that are to be employed by the Trademark Clearinghouse for new gTLDs.  

Below is a high level overview of the implementation of the .co Sunrise period that demonstrates Neustar’s experience and ability to provide a Sunrise service and an overview of Neustar’s experience in implementing a Trademark Claims program to trademark owners for the launch of .BIZ.  Neustar’s experience in each of these rights protection mechanisms will enable it to seamlessly provide these services on behalf of .CITI as required by ICANN. 

a)	Sunrise and .co
The Sunrise process for .co was divided into two sub-phases: 
	Local Sunrise giving holders of eligible trademarks that have obtained registered status from the Colombian trademark office the opportunity apply for the .CO domain names corresponding with their marks 
	Global Sunrise program giving holders of eligible registered trademarks of national effect, that have obtained a registered status in any country of the world the opportunity apply for the .CO domain names corresponding with their marks for a period of time before registration is open to the public at large. 

Like the new gTLD process set forth in the Applicant Guidebook, trademark owners had to have their rights validated by a Clearinghouse provider prior to the registration being accepted by the Registry.  The Clearinghouse used a defined process for checking the eligibility of the legal rights claimed as the basis of each Sunrise application using official national trademark databases and submitted documentary evidence. 

Applicants and⁄or their designated agents had the option of interacting directly with the Clearinghouse to ensure their applications were accurate and complete prior to submitting them to the Registry pursuant to an optional “Pre-validation Process”.  Whether or not an applicant was “pre-validated”, the applicant had to submit its corresponding domain name application through an accredited registrar.  When the Applicant was pre-validated through the Clearinghouse, each was given an associated approval number that it had to supply the registry.  If they were not pre-validated, applicants were required to submit the required trademark information through their registrar to the Registry.

As the registry level, Neustar, subsequently either delivered the: 
	Approval number and domain name registration information to the Clearinghouse
	When there was no approval number, trademark information and the domain name registration information was provided to the Clearinghouse through EPP (as is currently required under the Applicant Guidebook).  

Information was then used by the Clearinghouse as either further validation of those pre-validated applications, or initial validation of those that did not go through pre-validation.  If the applicant was validated and their trademark matched the domain name applied-for, the Clearinghouse communicated that fact to the Registry via EPP.   

When there was only one validated sunrise application, the application proceeded to registration when the .co launched.  If there were multiple validated applications (recognizing that there could be multiple trademark owners sharing the same trademark), those were included in the .co Sunrise auction process.  Neustar tracked all of the information it received and the status of each application and posted that status on a secure Website to enable trademark owners to view the status of its Sunrise application. 

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

Trademark Claims Service Experience
With Neustar’s biz TLD launched in 2001, Neustar became the first TLD with a Trademark Claims service.   Neustar developed the Trademark Claim Service by enabling companies to stake claims to domain names prior to the commencement of live .biz domain registrations.  

During the Trademark Claim process, Neustar received over 80,000 Trademark Claims from entities around the world. Recognizing that multiple intellectual property owners could have trademark rights in a particular mark, multiple Trademark Claims for the same string were accepted. All applications were logged into a Trademark Claims database managed by Neustar. 

The Trademark Claimant was required to provide various information about their trademark rights, including the:

	Particular trademark or service mark relied on for the trademark Claim

	Date a trademark application on the mark was filed, if any, on the string of the domain name

	Country where the mark was filed, if applicable

	Registration date, if applicable

	Class or classes of goods and services for which the trademark or service mark was registered

	Name of a contact person with whom to discuss the claimed trademark rights. 

Once all Trademark Claims and domain name applications were collected, Neustar then compared the claims contained within the Trademark Claims database with its database of collected domain name applications (DNAs).  In the event of a match between a Trademark Claim and a domain name application, an e-mail message was sent to the domain name applicant notifying the applicant of the existing Trademark Claim.  The e-mail also stressed that if the applicant chose to continue the application process and was ultimately selected as the registrant, the applicant would be subject to Neustar’s dispute proceedings if challenged by the Trademark Claimant for that particular domain name. 
The domain name applicant had the option to proceed with the application or cancel the application. Proceeding on an application meant that the applicant wanted to go forward and have the application proceed to registration despite having been notified of an existing Trademark Claim. By choosing to “cancel,” the applicant made a decision in light of an existing Trademark Claim notification to not proceed.  
If the applicant did not respond to the e-mail notification from Neustar, or elected to cancel the application, the application was not processed.  This resulted in making the applicant ineligible to register the actual domain name. If the applicant affirmatively elected to continue the application process after being notified of the claimant’s (or claimants’) alleged trademark rights to the desired domain name, Neustar processed the application. 

This process is very similar to the one ultimately adopted by ICANN and incorporated in the latest version of the Applicant Guidebook.  Although the collection of Trademark Claims for new gTLDs will be by the Trademark Clearinghouse, many of the aspects of Neustar’s Trademark Claims process in 2001 are similar to those in the Applicant Guidebook.  This makes Neustar uniquely qualified to implement the new gTLD Trademark Claims process.

UDRP

Prior to joining Neustar, Mr. Neuman was a key contributor to the development of the Uniform Dispute Resolution Policy (“UDRP”) in 1998.  This became the first “Consensus Policy” of ICANN and has been required to be implemented by all domain name registries since that time.   The UDRP is intended as an alternative dispute resolution process to transfer domain names from those that have registered and used domain names in bad faith.  Although there is not much of an active role that the domain name registry plays in the implementation of the UDRP, Neustar has closely monitored UDRP decisions that have involved the TLDs for which it supports and ensures that the decisions are implemented by the registrars supporting its TLDs.  When alerted by trademark owners of failures to implement UDRP decisions by its registrars, Neustar either proactively implements the decisions itself or reminds the offending registrar of its obligations to implement the decision.  

URS
Applicant is fully aware of each of these requirements and will have the capability to implement these requirements for new gTLDs.  In fact, during the IRT’s development of the URS, Neustar began examining the implications of the URS on its registry operations and provided the IRT with feedback on whether the recommendations from the IRT would be feasible for registries to implement.  

Although there have been a few changes to the URS since the IRT recommendations, Neustar continued to participate in the development of the URS by providing comments to ICANN, many of which were adopted.  As a result, Neustar is committed to supporting the URS for all of the registries that it provides back-end registry services.

Resourcing Plans

The rights protection mechanisms described in the response above involve a wide range of tasks, procedures, and systems.  The responsibility for each mechanism varies based on the specific requirements.  In general the development of applications such as sunrise and IP claims is the responsibility of the Engineering team, with guidance from the Product Management team.  Customer Support and Legal play a critical role in enforcing certain policies such as the rapid suspension process.   These teams have years of experience implementing these or similar processes.  

The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31.  The following resources are available from those teams:

Development⁄Engineering – 19 employees

Product Management- 4 employees

Customer Support – 12 employees

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

Applicant Citigroup Inc. (“Applicant”) and its back-end operator, Neustar, recognize the vital need to secure the systems and the integrity of the data in commercial solutions relating to the .CITI TLD (“TLD”). The TLD registry solution will thus leverage industry-best security practices including the consideration of physical, network, server, and application elements.

The following is a summary of the security policies that will be used in the TLD, including:

1. Summary of the security policies used in the registry operations

2. Description of independent security assessments

3. Description of security features that are appropriate for the TLD

4. List of commitments made to registrants regarding security levels

All of the security policies and levels described in this section are appropriate for the Applicant’s financial services registry.

Summary of Applicant’s Security Policies

Applicant’s information and data security policies abide by industry standards for the financial services industry, and they will apply to any information and data received by the Applicant relating to the TLD registry. Indeed, online security and protecting confidential information is of the utmost importance to Applicant. Applicant believes that good security covers all the bases—sophisticated technology, as well as the most stringent principles of privacy. Below, Applicant outlines a few of the ways it safeguards Internet users’ current online experience at its websites and how it will do so in relation to the TLD registry, if it ever uses the TLD with the public.

Strong Encryption—To ensure security while accessing its password-protected websites, Applicant employs 128-bit encryption and Secure Sockets Layer. 128-bit encryption, the strongest level of encryption generally available today, provides high-level security for these transmissions and is the industry standard for electronic financial transactions.

Secure User Name and Password–Users will select their preferred user name and password for websites that contain private information, and these items must be entered every time they sign-in to such a website. For information security reasons, users will be instructed to change their password periodically.

Automatic Time Out—When there is no activity for 20 minutes on one of its websites, a user’s session will be terminated to help protect against unauthorized access.

Client-Driven Authentication Questions – When a user calls Web Services and Support with questions about a website within the TLD, Applicant will confirm its identity on the phone before discussing any account information. The questions and answers the user selects when logging into a website in the TLD for the first time will be used for this identification process.

Of course, much of Applicant’s data security occurs behind the scenes. And, Applicant has a legal duty under federal and state information security laws, contracts, and industry standards to protect its customers’ nonpublic personal information (NPI), including any NPI in the custody of a third-party service provider. Applicant commits to providing backend registry services in accordance with the following relevant security standards.

Specifically, there are a wide variety of federal, state, and industry information security rules that create a duty to detect, prevent and respond to any anticipated threats or hazards to the security or integrity of customer records, including attacks, intrusions or other systems failures, as well as to protect against unauthorized access to or use of customersʹ records or information that could cause them harm or inconvenience. In general, these laws require financial services companies to implement a comprehensive written information security program that includes administrative, technical, and physical safeguards for the protection of customer information. There are also state regulations addressing privacy and information security.

Applicant has already developed several internal information security policies that apply to its websites in the current Internet space and will apply to any websites within the TLD used with the public to meet these requirements and Internet users’ Web-based security expectations. These policies, which are attached to the answer to Question 30b, consist primarily of:

Data Management Policy and Standards. The objective of this policy is to ensure the proper management of data or information that has broad applicability to Applicant and its business processes, especially consolidated functions, and individual elements of data that support key processes and outputs, i.e., critical business uses of the data. These items, which are key resources utilized by Applicant and external stakeholders, are accorded special treatment under the Data Management Policy and Standards. Specifically, the Data Management Policy sets forth the minimum requirements for Senior Management to implement a consistent and controlled approach to the development and use of data and information across Applicant’s company. The Data Management Standards set forth the standards for implementation and compliance with the Data Management Policy.

Records Management Policy & Standards. The Records Management Policy and Standards establishes a uniform process for identifying, managing, retaining, securing, and when appropriate, disposing of Applicant’s Records. This policy is designed to address the legal, regulatory, financial and operational obligations associated with Records Management. Specifically, Applicant requires the maintenance of authentic, reliable and useable records that support the business requirements and activities for which they were created. Records must be kept as long as, and only as long as, required to meet legal, regulatory and operational requirements. Effective implementation of this policy includes a well-defined governance structure. It establishes a systematic and consistent approach to the classification, retention, protection, retrieval and disposal of records.

Information Security Standards. Applicant’s Information Security Standards establish clear and concise minimum security requirements which every one of Applicant’s businesses must satisfy in their environments. These standards identify information protection requirements to ensure all of Applicant’s businesses protect Applicant’s information in accordance with applicable legal and regulatory requirements in the locations where Applicant does business. These standards are based on International code of practice for information security management (ISO 27002) and are updated on a regular basis.

Information Technology Management Standards. Applicant’s Information Technology Management Standards details how Applicant protects its clients’ information entrusted to it as well as ensuring the security and integrity of its own information. These standards are based on an International Framework (COBIT 4.1) for managing Information Technology. These standards also encompass U.S. as well as other country’s regulatory and legal Information Technology and Security requirements.

Information Technology Management Policy. Applicant’s Information Technology Management Policy demonstrates how Applicant protects clients’ information and ensures the security and integrity of Applicant’s information. Specifically, Applicant’s Technology Management has been set into 14 process areas, covering all major aspects of IT, in order to maintain an effective governance structure. This policy is based on an International Framework (Control Objectives for Information and related Technology (COBIT 4.1)) for managing technology and encompasses country-specific legal and regulatory requirements.

Policy on Confidentiality of Information. The objective of this policy is to set forth minimum standards for the safeguarding of confidential or proprietary information by Applicant’s employees. This policy requires that Applicant’s employees safeguard all non-public information from disclosure to the public. This includes not disclosing confidential information, profiting from confidential information, seeking confidential information unnecessary to the employee’s job, and⁄or sharing information with other employees where unnecessary, among others.

These standards and policies, which work together and provide for a robust Information Security Policy, are attached to the answer to application Question 30(b) in whole. These policies will apply to the TLD registry once launched.

Both internal and external auditors as well as regulators regularly review and test Applicant’s Information Security Program.

Neustarʹs approach to information security starts with comprehensive information security policies. These are based on the industry best practices for security including SANS (SysAdmin, Audit, Network, Security) Institute, NIST (National Institute of Standards and Technology), and CIS (Center for Internet Security). Policies are reviewed annually by Neustarʹs information security team.

All of the security policies and levels described in this section are appropriate for the TLD registry.

30.(a).2 Summary of Security Policies

Neustar has developed a comprehensive Information Security Program in order to create effective administrative, technical, and physical safeguards for the protection of its information assets, and to comply with Neustarʹs obligations under applicable law, regulations, and contracts. This Program establishes Neustarʹs policies for accessing, collecting, storing, using, transmitting, and protecting electronic, paper, and other records containing sensitive information.

-The policies for internal users and our clients to ensure the safe, organized and fair use of information resources.
-The rights that can be expected with that use.
-The standards that must be met to effectively comply with policy.
-The responsibilities of the owners, maintainers, and users of Neustarʹs information resources.
-Rules and principles used at Neustar to approach information security issues

The following policies are included in the Program:

1. Acceptable Use Policy
The Acceptable Use Policy provides the rules of behavior covering all Neustar Associates for using Neustar resources or accessing sensitive information.

2. Information Risk Management Policy
The Information Risk Management Policy describes the requirements for the on-going information security risk management program, including defining roles and responsibilities for conducting and evaluating risk assessments, assessments of technologies used to provide information security and monitoring procedures used to measure policy compliance.

3. Data Protection Policy
The Data Protection Policy provides the requirements for creating, storing, transmitting, disclosing, and disposing of sensitive information, including data classification and labeling requirements, the requirements for data retention. Encryption and related technologies such as digital certificates are also covered under this policy.

4. Third Party Policy
The Third Party Policy provides the requirements for handling service provider contracts, including specifically the vetting process, required contract reviews, and on-going monitoring of service providers for policy compliance.

5. Security Awareness and Training Policy
The Security Awareness and Training Policy provide the requirements for managing the on-going awareness and training program at Neustar. This includes awareness and training activities provided to all Neustar Associates.

6. Incident Response Policy
The Incident Response Policy provides the requirements for reacting to reports of potential security policy violations. This policy defines the necessary steps for identifying and reporting security incidents, remediation of problems, and conducting lessons learned post-mortem reviews in order to provide feedback on the effectiveness of this Program. Additionally, this policy contains the requirement for reporting data security breaches to the appropriate authorities and to the public, as required by law, contractual requirements, or regulatory bodies.

7. Physical and Environmental Controls Policy
The Physical and Environment Controls Policy provides the requirements for securely storing sensitive information and the supporting information technology equipment and infrastructure. This policy includes details on the storage of paper records as well as access to computer systems and equipment locations by authorized personnel and visitors.

8. Privacy Policy
Neustar supports the right to privacy, including the rights of individuals to control the dissemination and use of personal data that describes them, their personal choices, or life experiences. Neustar supports domestic and international laws and regulations that seek to protect the privacy rights of such individuals.

9. Identity and Access Management Policy
The Identity and Access Management Policy covers user accounts (login ID naming convention, assignment, authoritative source) as well as ID lifecycle (request, approval, creation, use, suspension, deletion, review), including provisions for system⁄application accounts, shared⁄group accounts, guest⁄public accounts, temporary⁄emergency accounts, administrative access, and remote access. This policy also includes the user password policy requirements.

10. Network Security Policy
The Network Security Policy covers aspects of Neustar network infrastructure and the technical controls in place to prevent and detect security policy violations.

11. Platform Security Policy
The Platform Security Policy covers the requirements for configuration management of servers, shared systems, applications, databases, middle-ware, and desktops and laptops owned or operated by Neustar Associates.

12. Mobile Device Security Policy
The Mobile Device Policy covers the requirements specific to mobile devices with information storage or processing capabilities. This policy includes laptop standards, as well as requirements for PDAs, mobile phones, digital cameras and music players, and any other removable device capable of transmitting, processing or storing information.

13. Vulnerability and Threat Management Policy
The Vulnerability and Threat Management Policy provides the requirements for patch management, vulnerability scanning, penetration testing, threat management (modeling and monitoring) and the appropriate ties to the Risk Management Policy.

14. Monitoring and Audit Policy
The Monitoring and Audit Policy covers the details regarding which types of computer events to record, how to maintain the logs, and the roles and responsibilities for how to review, monitor, and respond to log information. This policy also includes the requirements for backup, archival, reporting, forensics use, and retention of audit logs.

15. Project and System Development and Maintenance Policy
The System Development and Maintenance Policy covers the minimum security requirements for all software, application, and system development performed by or on behalf of Neustar and the minimum security requirements for maintaining information systems.

30.(a).3 Independent Assessment Reports

Neustar IT Operations is subject to yearly Sarbanes-Oxley (SOX), Statement on Auditing Standards #70 (SAS70) and ISO audits. Testing of controls implemented by Neustar management in the areas of access to programs and data, change management and IT Operations are subject to testing by both internal and external SOX and SAS70 audit groups. Audit Findings are communicated to process owners, Quality Management Group and Executive Management. Actions are taken to make process adjustments where required and remediation of issues is monitored by internal audit and QM groups.
External Penetration Test is conducted by a third party on a yearly basis. As authorized by Neustar, the third party performs an external Penetration Test to review potential security weaknesses of network devices and hosts and demonstrate the impact to the environment. The assessment is conducted remotely from the Internet with testing divided into four phases:

-A network survey is performed in order to gain a better knowledge of the network that was being tested
-Vulnerability scanning is initiated with all the hosts that are discovered in the previous phase
-Identification of key systems for further exploitation is conducted
-Exploitation of the identified systems is attempted.

Each phase of the audit is supported by detailed documentation of audit procedures and results. Identified vulnerabilities are classified as high, medium and low risk to facilitate managementʹs prioritization of remediation efforts. Tactical and strategic recommendations are provided to management supported by reference to industry best practices.

30.(a).4 Augmented Security Levels and Capabilities

There are no increased security levels specific for TLD. However, Neustar will provide the same high level of security provided across all of the registries it manages.
A key to Neustarʹs Operational success is Neustarʹs highly structured operations practices. The standards and governance of these processes:

-Include annual independent review of information security practices
-Include annual external penetration tests by a third party
-Conform to the ISO 9001 standard (Part of Neustarʹs ISO-based Quality Management System)
-Are aligned to Information Technology Infrastructure Library (ITIL) and CoBIT best practices
-Are aligned with all aspects of ISO IEC 17799
-Are in compliance with Sarbanes-Oxley (SOX) requirements (audited annually)
-Are focused on continuous process improvement (metrics driven with product scorecards reviewed monthly).

A summary view to Neustarʹs security policy in alignment with ISO 17799 can be found in section 30.(a).5 below.

30.(a).5 Commitments and Security Levels

The TLD registry commits to high security levels that are consistent with the needs of the TLD. These commitments include:

Compliance with High Security Standards

-Security procedures and practices that are in alignment with ISO 17799
-Annual SOC 2 Audits on all critical registry systems
-Annual 3rd Party Penetration Tests
-Annual Sarbanes Oxley Audits

Highly Developed and Document Security Policies

-Compliance with all provisions described in section 30.(b) and in the attached security policy document.
-Resources necessary for providing information security
-Fully documented security policies
-Annual security training for all operations personnel

High Levels of Registry Security

-Multiple redundant data centers
-High Availability Design
-Architecture that includes multiple layers of security
-Diversified firewall and networking hardware vendors
-Multi-factor authentication for accessing registry systems
-Physical security access controls
-A 24x7 manned Network Operations Center that monitors all systems and applications
-A 24x7 manned Security Operations Center that monitors and mitigates DDoS attacks
-DDoS mitigation using traffic scrubbing technologies

Alain J.P. Belda	Director, Citigroup ⁄ Managing Director, Warburg Pincus
Anthony M. Santomero	Director, Citigroup ⁄ Former President, Federal Reserve Bank of Philadelphia
Diana L. Taylor	Director, Citigroup ⁄ Managing Director, Wolfensohn Fund Management, L.P.
Ernesto Zedillo	Director, Citigroup ⁄ Director, Center for the Study of Globalization ⁄ Professor, Yale Univ.
Judith Rodin	Director, Citigroup ⁄ President, Rockefeller Foundation
Lawrence R. Ricciardi	Director, Citigroup ⁄ Senior Advisor, IBM Corporation, Jones Day and Lazard Frères & Co.
Michael E. O’Neill	Director, Citigroup ⁄ Former Chairman and CEO, Bank of Hawaii Corporation
Richard D. Parsons	Director, Citigroup ⁄ Chairman, Citigroup Inc.
Robert L. Joss	Director, Citigroup ⁄ Professor of Finance Emeritus and Former Dean, Stanford University Graduate School of Business
Robert L. Ryan	Director, Citigroup ⁄ Chief Financial Officer, Retired, Medtronic Inc.
Timothy C. Collins	Director, Citigroup ⁄ Chairman of Investment Committee, Ripplewood Holdings LLC
Vikram Pandit	Director, Citigroup ⁄ Chief Executive Officer, Citigroup Inc.
William S. Thompson, Jr.	Director, Citigroup ⁄ Chief Executive Officer, Retired, Pacific Investment Management Company (PIMCO)

Brian Leach	Chief Risk Officer-Citigroup
Don Callahan	Chief Administrative Officer, Chief Operations & Technology Officer-Citigroup
Eugene McQuade	Chief Executive Officer-Citibank, N.A.
Jeffrey R. Walsh	Controller and Chief Accounting Officer
John C. Gerspach	Chief Financial Officer-Citigroup
John Havens	President and Chief Operating Officer, Citigroup ⁄ Chief Executive Officer, Institutional Clients Group
Manuel Medina-Mora	Chief Executive Officer⁄Global Consumer Banking and Chairman of the Global Consumer Council
Michael Helfer	General Counsel⁄Corporate Secretary-Citigroup
Michael L. Corbat	Chief Executive Officer-Europe, Middle East and Africa
Stephen Bird	Chief Executive Officer-Asia Pacific
Vikram Pandit	Chief Executive Officer, Citigroup Inc.
William J. Mills	Chief Executive Officer-North America

New gTLD Application Submitted to ICANN by: Citigroup Inc.

String: CITI

Originally Posted: 13 June 2012

Application ID: 1-2086-70305

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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