Pro-Active Abuse Prevention, Monitoring, and Mitigation
Historically, domain name registries have viewed their companies as purely technical service providers and seen socially undesirable Internet behavior, such as abuse, criminality and fraud, as someone elseʹs problem. The Internet increasingly permeates human interactions and processes, whether those interactions are social, commercial, financial, industrial, or governmental. Uniregistry believes that a registry should possess sophisticated technical tools to identify and redress behavior, wielded by experienced and knowledgeable management committed to rapid response to clearly abusive behavior. While what may be a criminal act in one jurisdiction might be a lawful expression in another, we believe it is possible, and necessary, to define and respond to behaviors which constitute, in their motivations and consequences, attacks on the Internet itself as a reliable medium for the free expression of ideas, information and commerce. Fraud, cybervandalism, identity theft and other universally recognized forms of cybercrime can adversely impact utilization of the Internet to advance the human condition in ways that are as insidious as the injudicious application of policies designed to combat them.
This Application proposes a suite of abuse prevention, investigation and response tools, including active monitoring of WHOIS accuracy; participation in ISCʹs Security Information Exchange; detection of anomalous network traffic consistent with abuse profiles; agents for service of legal process, warrants and subpoenas in the United States; a single point of contact for abuse reporting and response with 24x7 availability; a directory of abuse response resources for third party responders; zone file access; searchable WHOIS; anti-terrorism measures; and graduated tiers of registrar incentives and disincentives based on policy compliance and responsiveness. As undesirable Internet behavior continues to evolve in sophistication and creative unpredictability Uniregistryʹs commitment to be an active participant in the relevant cooperative law enforcement and industry and anti-abuse communities, and the demonstrated record of Uniregistryʹs contractor Internet Systems Consortium in that regard, is perhaps of greater importance than the rules, policies and services which Uniregistry will provide and enforce.
18.C.3.2 Civil Disputes
Uniregistry will require and enforce registrar compliance with the Uniform Domain-Name Dispute Resolution Policy, Uniform Rapid Suspension (URS), and all requirements of the RAA relevant to civil disputes. The URS is not currently offered by any dispute resolution provider which has committed to ICANNʹs target estimate of $300 for URS disputes. Uniregistry believes that cases of clearly unambiguous, facially apparent cybersquatting against established brands can be resolved fairly, promptly and economically, because the type of cases qualifying for the URS are precisely the sort of cases which do not require analysis at length. Uniregistry will seek to implement a URS equivalent to be administered by recognized experts in the field of domain name disputes in the absence of URS availability at the cost target established by ICANN. In conjunction with Sunrise registrations, Uniregisty will implement Sunrise challenges to address abuse of the Sunrise registration system; a trademark claim notification service for pre-empting a defense of ignorance as an excuse for cybersquatting; designated resolution of suspended or blocked domains to prevent ISP re-direction of non-resolving names; and a registration string watch service to permit policing of domain registrations containing strings of interest to users.
18.C.3.3 Technical Security and Stability
Uniregistryʹs technical services provider, ISC is well known in the domain name services community as the operator of the F-Root, and its personnel include highly respected and experienced participants in the Internet Engineering Task Force, and numerous ICANN working groups, task forces and committees. ISC brings decades of experience in operating high reliability and high security systems to the operation of the .MEDIA TLD. The application proposes a modular, scalable, and geographically diverse registry platform which can accommodate registration volume and name resolution second to none, independent of whether the actual volume fails to meet or overwhelming exceeds expectations, and can accommodate addition or replacement of capacity without service interruption. The WHOIS system described in the application is further designed to accommodate selective publication of WHOIS data on a jurisdictional basis, as various standards for the handling of personal data continue to evolve.
18.C.3.5 Financial Stability
Experience gained since the launch of new TLDs and general marketing of certain ccTLDs since 2000 has demonstrated that treatment of a TLD delegation as a privately-owned balance sheet asset or private fiefdom does not inspire user confidence. Uniregistry believes that delegation of a TLD is an appointment of a private steward of a public trust. Accordingly, a registry should be prepared to execute a plan of operation which does not rely on rosy scenarios, unrealistic projections and revenue gimmicks.
Uniregistryʹs business plan is based on providing registry services to end users, and not on ʺpremium nameʺ sales, extorting trademark owners, or returning gains to passive outside investors. Uniregistry is not seeking to obtain any necessary capital based on the prospect of selling a stake in Uniregistry ownership contingent upon approval of this application. Uniregistry is well-capitalized, fully funded and ready to commence operation rapidly upon approval of this application. Uniregistryʹs financial reserve is held in gold, and thus immune to currency fluctuations from global economic uncertainty.