Description of TLD Policies

Submitted by:


Dubai Technology, Electronic Commerce and
Media Free Zone Authority




E.1      General Overview

In the initial stages of the establishment of the proposed new TLDs, DTEC-MFZA intends to work as closely as possible with ICANN in all policy-making matters.  DTEC-MFZA recognizes the extensive experience that ICANN has both in policy formulation and policy implementation processes and wishes to be able to benefit from ICANN’s experience in these areas.

As discussed more fully below, DTEC-MFZA intends to formulate policies based in very significant part on existing ICANN policies, recognizing the rigorous processes that were employed in their development and the widely-acknowledged success of their implementation.

E2.      TLD String

The present application concerns two TLD strings:


Hereinafter, except where the context so requires, the foregoing shall be collectively referred to as the New TLDs.

DTEC-MFZA has exercised its best efforts to ensure that neither of the New TLDs is duplicative or in conflict with any other existing or otherwise reserved TLDs, or that they would lead to confusion.

It is to be noted that there is currently no ISO 3166 country code digraph for the Emirate of Dubai.

E3.      Naming Conventions

At present, DTEC-MFZA intends to employ a naming convention and structure within the above TLDs that only allows for names to be registered at the second level directly under each new TLD.  For example:



However, with the benefit of experience, DTEC-MFZA may consider in the future allowing for sub‑domains to be registered, subject to further consultations and agreement with ICANN. 


E4.      Registrars

DTEC-MFZA proposes to allow any ICANN-accredited registrar to register <.go> domain names.  DTEC-MFZA has thoroughly reviewed ICANN’s registrar accreditation requirements and considers that these requirements both support and promote the objectives underlying the New TLDs.  DTEC-MFZA thus intends to implement those requirements at a minimum in evaluating accreditation requests by registrars for the <.go> TLD. 

DTEC-MFZA intends to supplement its accreditation procedures by introducing contractual and administrative procedures that would allow it to verify that accredited registrars are in compliance with the terms and conditions of the accreditation  (e.g., whether the registrar is processing registration requests in accordance with the established registration criteria and procedures, whether the registrar is acting in accordance with the procedures established for resolving domain name registration conflicts).

However, because of the restrictions relating to registrations in the <.dubai> TLD, DTEC-MFZA proposes that initially the registration of <.dubai> domains would only be through the Dubai Internet Domains Registration Authority (DIDRA). 

The respective roles and responsibilities of accredited registrars and the Registry shall be as set out variously in the following documents:

·        Statement of Registrar Accreditation Policy (adopted
March 4, 1999);

·        Registrar Accreditation Agreement (approved November 4, 1999);

·        NSI-Registrar License and Agreement (approved
November 4, 1999);

·        ICANN-NSI Registry Agreement (approved November 4, 1999 and signed November 10, 1999).

As the Registry, DIDRA (together with Network Solutions Inc.(VeriSign Global Registry Services)) will accept registrations and registration service requests from all accredited, licensed registrars, while protecting the integrity of registrations from unauthorized access and interference by third parties. Every new domain name application will be checked to ensure that the domain name is not already registered.  This function demands exceptional speed and accuracy to confirm registrations definitively and to arbitrate near-simultaneous requests for the same domain name.  In addition, DIDRA will play a partnership role with accredited registrars in screening <.go> domain name applications.


Domain name registrations and name servers, including domain name, name servers, IP address, registrar name, transfer date, registration period, expiration date, status, registration creation date, created by, updated date, and updated by information will be maintained by DIDRA/VeriSign, which shall be the authoritative source for the TLD zone file content (i.e., domain name, name server, and associated IP address). 

The registrar of the particular domain name or name server will be responsible for maintaining all other customer data.  This is in order to protect customer privacy, give greater flexibility to registrars and allow them to determine their business models. DTEC-MFZA will have a formal con­tractual relationship with each individual registrar accredited for registering domain names in their new TLD.  This is commonly referred to as a “thin” registry model.

Registration of a domain name or name server in the Registry database does not automatically create entries in the Internet DNS. For this to occur, a zone file associating all registered domain names with their corresponding IP addresses is generated and exported to the DNS root servers for the TLD.  DIDRA/VeriSign will operate and maintain distributed root servers to which the zone file is exported and from which the domain name information is dis­seminated to the Internet community.  

To enable close to 100% Registry availability, multiple data­base servers will be used, with off-site backup to protect against catastrophic data loss.  Redundancy will be in place at almost every level within the Registry to ensure high-availability of the systems and applications for the registrars.

SRS is the Registry architecture and processes used to enable registrations by multiple registrars.  It includes the Registry Registrar Protocol (RRP), which is used to support communications between the Registry and Registrars, and provides the security and authentication functions to protect the Registry database while supporting all necessary registrar operations.  RRP is also used during the certification process for accredited registrars for operational testing and evaluation of registrar implementations of the RRP prior to commencement of actual registrar operations.  DIDRA/VeriSign will be responsible for providing the RRP software interfaces, documentation, and training to accredited registrars for the <.go> TLD.  Hands-on technical support to new registrars will be available from DIDRA/VeriSign to assist them in resolv­ing difficulties in successful inter­facing with the Registry.

In sum:  DTEC-MFZA will establish the <.go> registration policies, DIDRA/VeriSign will implement the infrastructure for the <.go> policies, and accredited registrars will give effect to those policies.  

E5.      Intellectual Property Provisions

E5.1.   What measures will be taken to discourage registration of domain names that infringe intellectual property rights?

DTEC-MFZA intends to implement an infrastructure that is as comprehensive as possible to discourage registration of domain names that infringe established intellectual property rights.  This infrastructure will be based on the inter-marriage of properly promulgated regulations for Dubai Internet City, sound policy, rigorous implementation of those regulations and policies, co-operation agreements and partnering relationships with national trademark and copyright offices and state-of-the-art technical tools.

q       Promulgation of Laws and Regulations;

q       Accreditation policies;

q       Fee set at a level to discourage dilatory non-serious applications;

q       Stringent registration criteria;

q       Rigorous application screening criteria;

q       Trademark checks in cooperation with national authorities;

q       Creation and maintenance of an intelligent database for the purpose of maintaining a record of rejected applications, terminated registrations, and other information to assist in cross-checking applications;

q       On going web site verification;

q       Upon application by a third-party alleging an infringement of its rights, immediate non-binding action regarding the potentially infringing site;

q       Criteria and procedures for the exclusion of so-called famous and well-known marks, consistent with the evolution of ICANN policy-making process and policy concerning this issue;

q       Registration/service agreement clauses providing that an infringement of established intellectual property rights shall be considered a fundamental breach of the terms and conditions of the agreement;

q       Dispute resolution policies allowing for the award of monetary damages.

E5.2.   If pre‑screening for potentially infringing registrations is being proposed, how will the pre‑screening be performed?

As discussed below, domain name applicants will be required to provide information, and perhaps documentary support, establishing prima facie their right to the domain name that is the subject of the application.  

DTEC-MFZA is considering two types of pre-screening.  The first method would entail “character mapping”, whereby the second-level domain character string would be mapped against an existing database.  Applications that, for example, mapped against an existing name, or portion thereof, would be subjected to a higher level of scrutiny and evidentiary burden.  The second method would entail a longer-term project of co-operation agreements and partnering relationships with national trademark authorities and involvement in initiatives that DTEC-MFZA is aware of that are underway at the World Intellectual Property Organization and within the European Union. 

E5.3.   What registration practices will be employed to minimize abusive registrations?

Because of the rationale underlying the New TLDs, DTEC-MFZA intends to put in place rigorous registration procedures and criteria, to be implemented in partnership with accredited registrars.  While dispute resolution policies will be available at the back-end to deal with abusive registrations in the same manner as is currently possible through the infrastructure of the Uniform

Domain Name Dispute Resolution Policy, front-end measures (generally analogous to the manner in which applications for credit cards are processed) that are being considered include:

q       A statement of justification by the applicant of its right to register and use the domain name applied for (e.g., submission of a trademark or servicemark certificate, the nexus between the applicant’s personal or tradename and the name applied for, evidence of registration of the same name in another TLD);


q       A description of the purpose for which the related web site that will eventually be established will be used;


q       A projected date by which that site will be activated;


q       Information regarding the hosting location of the site, for purposes of security evaluation.


The above criteria are in addition to those that ICANN currently requires registrars to include in their registration/service agreements.

Applicants will be required to submit the registration details for review and to submit the required payment.  If all registration requirements are satisfied, the application will be provisionally approved.  An alternative outcome might be that the applicant is requested for additional information, before the registration is accepted.

DTEC-MFZA intends to set the fees for domain name registrations at a level that will discourage abusive registrations.

E5.4.   What measures are proposed to comply with applicable trademark and anti‑cybersquatting legislation?

As yet, there is no legislation in force in the Dubai Technology, Electronic Commerce and Free Zone with respect to intellectual property protection.  However, it is to be re-emphasized that, Article 8 of Law No. 1 of 2000 provides that among the objectives of DTEC-MFZA shall be:

“To prepare researches and advise the Government [of Dubai] in relation to laws appropriate to the regulation and encouragement of Technology, Electronic Commerce and Media in the Emirate, including but not limited to

                        1 -        […]


                        2 -        protection of intellectual property rights.


                                    […] “


DTEC-MFZA is keenly aware of the importance of intellectual property protection and safeguard measures.  Notwithstanding the present application, DTEC-MFZA has sponsored a major initiative involving international legal experts to develop a comprehensive set of laws and regulations for the Free Zone.  The expert group includes international intellectual property experts, who will be working closely with intellectual property constituencies and associations to develop legislation to give effect to the mandate contained in Article 8 of Law No. 1 of 2000. The group will also be studying legislation already adopted in countries such as Belgium and the United States with a view towards assessing the applicability thereof for the Free Zone.

It is to be expected that the registration policies, criteria and procedures for the New TLDs will be consistent and in full compliance with the relevant laws adopted for the Free Zone.

E5.5.   Are you proposing any special protections (other than during the start‑up period) for famous trademarks?

DTEC-MFZA is aware that the issue of famous and well-known marks is currently being studied and debated within ICANN forums and has followed the process that led to the recommendations reflected in the Final Report of the WIPO Internet Domain Name Process.

DTEC-MFZA does not wish to propose policies or implementation measures concerning an issue and in an environment which is still not yet settled, but will await the outcome of the ICANN process before taking steps in this area.  Consistent with its overall approach, DTEC-MFZA expects that, in all likelihood, it will follow the policies for famous and well-known marks adopted by ICANN.

It is perhaps appropriate to note that, in the context of its screening operations, DTEC-MFZA has considered the possibility of establishing a minimal list of marks that could conservatively be considered “famous and well-known”; this would not be exclusive and mark holders could be added to the list on a fee-paying basis.  Web sites and associated domain names would be screened in relation to that list.  Furthermore, registration requests involving a domain name that reflected all or any part of a name appearing on the list would be flagged for special consideration.  

E5.6.   How will complete, up‑to‑date, reliable, and conveniently provided Whois data be maintained, updated, and accessed concerning registrations in the TLD?

As Registry Operator, DIDRA will have primary overall responsibility for the Whois database.  However, it should be noted that DTEC-MFZA has entered into a teaming relationship with Network Solutions Inc. (VeriSign Global registry Services), pursuant to which VeriSign will design, deploy and support an onsite registry infrastructure and provide critical monitoring and management services.  It is expected that until DIDRA takes over the full registry function, that the Whois data compilation and database creation, organization and maintenance will be done by VeriSign.  It is anticipated that the Whois information and services currently available for existing open gTLDs will also be available for the New TLDs.

Domain name registrations and name servers, including domain name, name servers, IP address, registrar name, transfer date, registration period, expiration date, status, registration creation date, created by, updated date and updated by information will be maintained by DIDRA/VeriSign; the authoritative source for the TLD zone file content, that is, domain name, name server, and associated IP address.

The registrar of a particular domain name or name server will maintain all other customer data in order to ensure customer privacy and to maintain the current flexibility enjoyed by ICANN-accredited registrars.  DTEC-MFZA will have a formal contractual relationship with each individual registrar accredited to register domain names in the New TLD <.go>.  In accordance with the terms and conditions set out in the agreement, registrars will be required to provide all required Whois information in the same way as is currently required of ICANN-accredited registrars.

E6.      Dispute Resolution

DTEC-MFZA recognizes that regardless of the safeguards that are put in place to minimize the risk of improper and abusive (not just in the trademark/service mark sense) registrations, that undermine the integrity, reliability, safety and soundness of the Domain Name System, situations will arise requiring the involvement of an impartial and independent third-party neutral to resolve conflicts. 

TEC-MFZA has carefully followed from the very outset the process that ultimately led to ICANN’s adoption of the Uniform Domain Name Dispute Resolution Policy.  It has also observed and studied the implementation of the UDRP, as reflected in the decisions of administrative panels and in the many commentaries that have been published (on-line and off-line) assessing the effectiveness of the UDRP.

DTEC-MFZA believes that the UDRP administrative procedure provides a sound model for domain name dispute resolution.  However, DTEC-MFZA believes that certain procedural modifications, such as those recently discussed at a meeting convened by ICANN of approved dispute resolution providers, could be made to expedite the process and to introduce additional safeguards to protect the interests of the parties

As DTEC-MFZA contemplates that the procedural amendments would be developed in consultation with ICANN and to ensure consistency with the UDRP, the dispute resolution procedure for the New TLDs could be used as a testing ground for future modifications to the UDRP. 

E7.      Data Privacy, Escrow, and Whois

See generally, Item E.5.6.  All policies will be consistent with those set out in the following documents:


·        Registrar Accreditation Agreement (approved November 4, 1999);

·        ICANN-NSI Registry Agreement (approved November 4, 1999, signed November 10, 1999);

·        NSI-Registrar License and Agreement (approved November 9, 2000).

E8.      Billing and Collection

 Generally consistent with the relevant policies (e.g., pre-payment of registration fees) set out in the following documents:

·        Registrar Accreditation Agreement (approved November 4, 1999);

·        NSI-Registrar License and Agreement (approved November 9, 2000).  

E9.      Services and Pricing





Registrations and Renewals

USD 35 – 180

Processing Fee

USD 30 – 65






Not yet established





To be determined


To be determined


 See generally, Registry Operator Proposal, Section 13.2.



E11.    In this section, you should thoroughly describe all policies (including implementation details) that you propose to follow during the start‑up phase of registrations in the TLD, to the extent they differ from the General TLD Policies covered in items E1‑E9. 

See generally preceding sections.  It is worth mentioning that no policies can be finalized until fully tested with real world experience.  In DTEC-MFZA’s view, it would be both prudent and cautious to rely largely on the policies already adopted by ICANN, with minimal deviations initially, simply because that policy infrastructure has been tried and tested.  The supplementary policies proposed by DTEC-MFZA could thus easily be filtered into the existing framework without undue disruption.

E12.    How do you propose to address the potential rush for registration at the initial opening of the TLD? How many requested registrations do you project will be received by the registry operator within the first day, week, month, and quarter? What period do you believe should be considered the TLD's "start‑up period," during which special procedures should apply?


As will be apparent, what DTEC-MFZA is proposing with the introduction of the New TLDs is not a mass registration model, but rather one that entails up-front prudence and care in registration with resulting long-term benefits for all <.go> and <.dubai> domain name registrants.

DTEC-MFZA anticipates that, with the significant resources at its disposal, and by virtue of its alliance with Network Solutions Inc. (VeriSign Global Registry Services), it will have the technical, operational and administrative infrastructure required to meet the demand for the New TLDs.

 It is difficult to project with any sufficient degree of accuracy what the demand will be in a new open TLD, such as <.go>; the numbers will be only in the few thousands for <.dubai>.  Suffice it say that, if the basic premises underlying the value-added of <.go> are accepted, registration volumes approximating the registrations in the <.com> TLD can be expected.

 DTEC-MFZA is giving consideration to a number of options for regulating the influx of registration requests, including restricting for a test-bed phase of 6-9 months the number of registrars to only those that can meet DTEC-MFZA’s exacting standards at the “go-live” date and/or regulating the number of registrations.

E13.    Do you propose to place limits on the number of registrations per registrant? Per registrar? If so, how will these limits be implemented?

See preceding section.

E14.    Will pricing mechanisms be used to dampen a rush for registration at the initial opening of the TLD? If so, please describe these mechanisms in detail.


As set out more fully in the Registry Operator’s Proposal and in Item E.9 above, because of the “premium” character of the New TLDs, the pricing structure should impact the demand for registrations. 

One idea that DTEC-MFZA has considered in order to create a preference for “famous and well known” mark holders is to set initially a registration price that only such mark holders would be willing to pay.

E15.    Will you offer any "sunrise period" in which certain potential registrants are offered the opportunity to register before registration is open to the general public? If so, to whom will this opportunity be offered (those with famous marks, registered trademarks, second‑level domains in other TLDs, pre‑registrations of some sort, etc.)? How will you implement this?


DTEC-MFZA is aware of the various proposals that have been raised regarding “sunrises” and is continuing to study and evaluate them.  As mentioned above, DTEC-MFZA is considering implementing such a period whereby famous mark holders, registered trademark holders, second‑level domain registrants in other TLDs could benefit from a “first right of refusal”.  Such a period would also allow DIDRA an opportunity to perfect its registration criteria and procedures.


In implementing the foregoing, the following proposals are being considered:

q       Inviting the top companies listed on national stock exchanges or included in tracking indexes to be the first to register;

q       Differentiated premium pricing;

q       Detailed eligibility criteria and evidentiary requirements;


Applicants that do not meet the eligibility criteria would enter a queue for second-stage screening.





E16.    As noted in the New TLD Application Process Overview, a restricted TLD is one with enforced restrictions on (1) who may apply for a registration within the domain, (2) what uses may be made of those registrations, or (3) both. In this section, please describe in detail the restrictions you propose to apply to the TLD. Your description should define the criteria to be employed, the manner in which you propose they be enforced, and the consequences of violation of the restrictions. 


E17.    Describe in detail the criteria for registration in the TLD. Provide a full explanation of the reasoning behind the specific policies chosen.


The purpose behind the proposed <.dubai> restricted TLD may be characterized as encompassing all of the requirements for <.go> and, in addition, the requirement of a nexus between the applicant/domain name holder and activities being carried out in or with or arising out of or relating to the Emirate of Dubai or Dubai Internet City.


E18.    Describe the application process for potential registrants in the TLD.


The application process will be the same as for <.go>, with certain additional requirements relating to the requirements of a Dubai nexus.

E19.    Describe the enforcement procedures and mechanisms for ensuring registrants meet the registration requirements


Generally speaking, applications will be processed with reference to the commercial registries and other civil identification information available in Dubai’s public infrastructure.


E20.    Describe any appeal process from denial of registration

 one yet established, although mechanisms are available through traditional legal channels within the Dubai Court System.

E21.    Describe any procedure that permits third parties to seek cancellation of a TLD registration for failure to comply with restrictions.


            None yet established.




DTEC-MFZA does not intend to use this application for a discourse on the importance of the domain name system for the phenomenal growth of the Internet.  Suffice it to say that, in large part, the Internet has grown because of the ease with which it has been possible to register a domain name and thereby establish an on-line identity.  This has resulted in remarkable benefits for the global community:  e-commerce, social and cultural interchange, information dissemination, to mention a few.  At the same time, this has also led to gross abuses of the Internet:  child pornography, financial fraud, trademark and copyright abuse, again, to mention only a few.


IN DTEC-MFZA’s humble opinion, what is required now is the introduction in the DNS of what may be characterized as a “next generation” open TLD that does not directly compete with the existing gTLDs, but rather that offers the on-line community a viable alternative by virtue of the fact that it represent reliability, integrity, safety and soundness based on the following principles:

(i)         The implementation of sound registrar accreditation policies based on the criteria and policies established by ICANN;

(ii)        The on-going verification of accredited registrars to ensure compliance with the terms and conditions of the accreditation;

(iii)       The development of registration criteria intended to reflect the above goals;

(iv)       The rigorous implementation by registrars of those registration criteria;

(vi)       The introduction of fair and balanced measures to safeguard intellectual property rights;

(vi)       On-going monitoring to ensure that the second-level domain is being used in a manner consistent with the representations made at the time of application;

(vii)      Cost-effective, expeditious, fair, balanced, neutral and transparent conflict resolution procedures.

A TLD based on the foregoing principles would contribute in fundamental and significant ways to promoting confidence in Internet-based commerce, and the overall utility of the Internet as a medium of interaction and exchange.

Because of the value-concept underlying the <.go> TLD, registrars accredited to register <.go> domain names would be offering a “premium” service.  Such registrars, in addition to competing on price, would also be competing on the basis of their effectiveness in implementing the registration criteria and procedures established by DTEC-MFZA.




E29.    What concepts are likely to be proved/disproved by evaluation of the introduction of this TLD in the manner you propose?


q       Whether there is a demand for a new open top-level domain that provides a viable alternative to <.com>;

q       Whether it is possible to put in place a technical, operational and administrative infrastructure that is ambitious, expeditious, cost-effective and not overly bureaucratic and that at the same time implements safeguards to ensure a clean, uncluttered and efficient TLD.


E30.    How do you propose that the results of the introduction should be evaluated? By what criteria should the success or lack of success of the TLD be evaluated?


Through an independent verification/audit of the registration process according to the following criteria, inter alia:


q       Number of registration applications received;

q       Number of correctly completed applications;

q       Screening time;

q       Response time to applicant;

q       Screening errors;

q       Overhead costs per application;

q       General revenue model;

q       Technical capabilities and infrastructure.


E31.    In what way would the results of the evaluation assist in the long-range management of the DNS?

The above factors will be generally relevant in allowing ICANN to better evaluate the feasibility of introducing more demanding registration criteria in order to minimize, in the future, replication of the problems that currently afflict the <.com> space (and to a lesser extent <.org> and <.net>).

E32.    Are there any reasons other than evaluation of the introduction process that this particular TLD should be included in the initial introduction?


DTEC-MFZA would urge that ICANN take into account:


q       The significant human and financial and resources that DTEC-MFZA is willing to dedicate to the success of this project;


q       Its commitment to the betterment of the Domain Name System;


q       Its contribution and role in the cyber-world of today and tomorrow, as shown already by the establishment of the Dubai Technology, Electronic Commerce and Media Free Zone Authority, Dubai Internet City, Dubai Media City and Dubai Incubator Oasis; and


q       The region, people, culture and traditions it represents.

If anything, the New TLDs offer the Internet community an opportunity for a unique testing ground to put in place policies and best practices “if we had to do it all over again.”

By signing this application through its representative, the Applicant attests that the information contained in this Description of TLD Policies, and all referenced supporting documents, are true and accurate to the best of Applicant's knowledge.

Dubai on the 28th day of September in the year 2000.


Mr. Mohammad Al-Gergawi

Director General


Name of Entity to Which Title Applies:
Dubai Technology, Electronic Commerce
Media Free Zone Authority


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Copyright September 2000 -DTEC & MFZA -DiDRA-LOK
2000-10-24 01:19:35