Statement of Capabilities of the
Applicant and Contracted Service


Section II — Statement of Capabilities of the Applicant and Contracted Service Providers

  Executive Summary
C11. Overview
  1. PIR will provide a stable, well-functioning .ORG registry
  2. PIR will comply with ICANN-developed policies
  3. PIR's .ORG will enhance competition for registration services
  4. PIR will differentiate the .ORG TLD
  5. PIR will institute mechanisms to ensure responsiveness to the non-commercial community
  6. PIR has a high level of support from .ORG registrants
  7. PIR will provide registry services better than those currently provided
  8. PIR will support and adopt protocol changes in the shared registry system
  9. PIR will provide a smooth transition
  10. PIR will comply with the requirements of the VeriSign endowment
  11. PIR's proposal is complete and realistic, and demonstrates sound analysis
C12. Contracted Service Providers
C13. Identification of Contracted Service Providers
C14. Agreements with Contracted Service Providers
C15. Abilities of Applicant and Key Technical Personnel
  A. Overview: Applicant's ability to operate the .ORG TLD registry
  B. Key Technical Personnel/Size of Technical Workforce/ Access to Systems Development Tools

Executive Summary

The Internet Society's (ISOC) bid on behalf of its subsidiary, Public Interest Registry, Inc. (PIR), to operate the registry rests on its extraordinary capabilities in two areas.

First, ISOC is the foremost non-profit organization focused exclusively on Internet-issues-and has been for more than ten years. As the organizational home of the Internet Engineering Task Force (IETF), Internet Architecture Board (IAB), and other Internet standards-setting bodies, ISOC has a global constituency that provides deep understanding of the policy and management issues facing TLDs, as well as keen insight into proposed enhancements to .ORG. PIR will have the benefit of ISOC's established consensus building mechanisms that will enable it to manage both policy and strategy for the domain. Further, ISOC has earned the respect of the Internet and noncommercial communities, which will help PIR.

Second, PIR has Afilias' commitment to provide the back-end registry services for .ORG. Afilias is the registry operator for .INFO, the most successful of the 7 new gTLDs, and the .VC ccTLD. Afilias manages more than 805,000 names in .INFO using the new EPP (Extensible Provisioning Protocol) standard for registry operations-and has spearheaded the use of EPP, including the first implementation of EPP's transfer capability. Afilias supports more than 90 ICANN-accredited registrars. Together these registrars already handle 99% of .ORG's current registrations. Afilias has prepared an EPP transition plan based on experience both with these registrars and a similar conversion being managed by AusRegistry Pty. Ltd., in Australia. (Afilias is a minority shareholder in AusRegistry.)

This section will detail the capabilities of PIR and Afilias to deliver "best in class" registry services that enhance the stability of the Internet, deliver affordable services with a high degree of service responsiveness and reliability, and enable .ORG to realize its full potential on a global basis.

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C11. Overview

As stated in the Criteria for Assessing Proposals, "ICANN's first priority is to preserve the stability of the Internet" and "ICANN will place significant emphasis on the demonstrated ability of the applicant or a member of the proposing team to operate a TLD registry of significant scale in a manner that provides affordable services with a high degree of service responsiveness and reliability." This section of the Proposal offers the applicant the opportunity to demonstrate its ability to operate the .org registry in that manner.

Throughout this document, operation of the .ORG registry, including providing all associated Registry Services, as defined in subsection 1.16 of the model .org Registry Agreement, is referred to as the "Registry Function."

Summary of how PIR's proposal meets or exceeds the 11 Assessment Criteria

This section summarizes how PIR's capabilities meet or exceed all of the assessment criteria. Expanded discussions follow in the subsequent sections of this proposal.


1. PIR will provide a stable, well-functioning .ORG registry

PIR has identified a team that will operate .ORG in such a way as to preserve the stability of the Internet and the DNS; deliver technically sound, high quality services; and meet the needs of .ORG registrants.

PIR's ability to operate the registry in a technologically stable manner is provided through its selection of Afilias as its back-end registry services provider. Afilias has more domain years of management experience with the new EPP protocol than any other registry services provider. As the operator of the .INFO TLD, Afilias has demonstrated its ability to manage day-to-day registry operations in a stable, reliable, and secure manner, delivering excellent service levels to both registrars and registrants.

Beyond this, Afilias managed the "Sunrise" and "Land Rush" periods for the new .INFO gTLD. These complex and critical phases of the launch illustrate Afilias' ability to successfully support "first-ever" policy implementations that have significant technical, legal, and customer service implications. In conjunction with this launch, Afilias also implemented the first-ever near-real-time propagation of domain information. This allowed registrants to register a domain name and then have their domains live and functioning on the Web within minutes, introducing unprecedented speed and ease of use for registrants worldwide. Afilias has also assisted in the first-ever transition of an existing domain to an EPP registry system. Afilias continues to strengthen its capabilities, and is now taking the speed and reliability of its DNS service to the next level.

PIR will provide high quality services to both .ORG registrants and registrars. In addition to core registry services, PIR plans to strengthen .ORG by developing and introducing, at the registry level, services tailored to noncommercial entities such as registrant controlled name locking; search engine submission; a .ORG directory; name watch; navigational links; plus database and list management. Given the relatively unsophisticated nature of many noncommercial organizations, we believe that these extra "helping hand" services can help them move successfully to the Internet.

ISOC is a long-standing member of the community of .ORG registrants, and many of its existing programs support these organizations. In addition to the many existing ISOC programs detailed in Section VII ("Responsiveness to the Noncommercial Internet User Community"), PIR proposes adding two major new elements:

  • The establishment of a .ORG Advisory Council: leaders from key noncommercial groups who provide advice to .ORG management on policy and other issues.

  • A special input section on the PIR Web site that provides .ORG news and empowers visitors to comment on and even introduce items of interest.

Details may be found in Section III ("Technical Plan"); Section V ("Proposed Registry Services"), and Section VII ("Responsiveness to the Noncommercial Internet User Community").

2. PIR will comply with ICANN-developed policies

ISOC stands firmly behind the goals and outcomes of the ICANN policy development process. This was one of the key considerations in the selection of Afilias, who deals with ICANN-accredited registrars ONLY, and already has proven mechanisms in place to ensure equitably shared registry access, adherence to the UDRP process (as well as the special Sunrise Challenge process), compliance with the WHOIS data accessibility requirements, and so on. The most complete review of the proposal's adherence to ICANN policies can be found in Section III ("Technical Plan").

3. PIR's .ORG will enhance competition for registration services

Under PIR management, competition in the domain space will be strengthened in three ways:

  • First, PIR will be a new entry to the registry space, providing an effective new voice for the long-neglected noncommercial sector.

  • Second, this proposal strengthens a currently small but promising back-end registry services player (Afilias, which holds 3% of the current gTLD registry market), ensuring the continued availability of a realistic alternative to VeriSign.

  • And third, PIR is proposing an effective marketing effort for .ORG, reinforcing its strengths and establishing strong branding that will withstand inevitable market changes in the future. Details are found in Section VI ("Enhancement of Competition") and Section VIII ("Differentiation of the .ORG TLD").

4. PIR will differentiate the .ORG TLD

PIR's program for differentiating .ORG is far-reaching and realistic. Through a combination of marketing and public relations, PIR's program will create a sustainable competitive advantage for .ORG through: 1) a clear and compelling positioning that leverages .ORG's noncommercial heritage and sets it apart from other TLDs; 2) a marketing campaign that enlists and equips registrars to tap .ORG's growth potential; and 3) a public relations program that expands the market by educating the budding noncommercial sector around the world. Details are provided in Section VIII ("Differentiation of the .ORG TLD").

5. PIR will institute mechanisms to ensure responsiveness to the non-commercial community

PIR will institute mechanisms for promoting the registry's operation in a manner that is responsive to the needs, concerns, and views of the non-commercial Internet user community.

ISOC has long-established mechanisms in place for responding to and supporting noncommercial Internet users. These include a wide range of programs of global impact that support ISOC's four pillars: education and training (including outreach to less-developed countries); standards and protocols; public policy; and membership. PIR will supplement these with: 1) a new .ORG Advisory Council selected from globally representative leaders from noncommercial organizations; and 2) additional Web-based input mechanisms that allow comment by interested parties. Details of these mechanisms are found Section VII ("Responsiveness to the Noncommercial Internet User Community").

6. PIR has a high level of support from .ORG registrants

ISOC's established reputation allows PIR's approach to enjoy the support of a wide range of individuals and entities, including the leaders of many noncommercial entities both inside and outside the Internet space. These organizations and individuals are attracted by ISOC's heritage of responsiveness and support for noncommercial interests, and PIR's proposed governance and consensus-building mechanisms. This solid foundation will help enable .ORG to reach its full potential under new management. Details regarding these supportive organizations and individuals are found in Section VII ("Responsiveness to the Noncommercial Internet User Community").

7. PIR will provide registry services better than those currently provided

PIR will provide high-quality, reasonably priced services to both .ORG registrants and registrars. Once transitioned, .ORG will operate as a "thick" registry based on EPP, providing all of the core registry functions needed to support a TLD consistent with ICANN requirements. EPP provides a number of improvements over the legacy RRP system, including the benefits of having "thick" registrant information kept at the registry level, near-instant WHOIS updating, and faster resolution of registered names. These benefits will be available to .ORG automatically upon completion of the transition to PIR's EPP system. See Section III ("Technical Plan")

In addition to core registry services, PIR plans to strengthen .ORG by introducing the add-on services described in Section V ("Proposed Registry Services").

We will maintain the current price of US$6.00/domain year for three reasons:

  • First, we know from experience that we can provide the enhanced core services at the current price (add-on services may be priced separately). It is not necessary to increase the registration/renewal price to cover costs.

  • Second, a portion of the current price is needed to fund the activities outlined in the proposal for properly serving the noncommercial community and developing the space.

  • And third, we believe that a price reduction at the registry level is unlikely to be reflected in the retail price. Hence, a price reduction would have no benefit to registrants or Internet users.

8. PIR will support and adopt protocol changes in the shared registry system

PIR will contract with Afilias to provide back-end registry services. ISOC itself is deeply involved in the standards-setting process and works closely with every major Internet standards-setting body. Afilias has more experience with the new EPP standard than any other provider, and is an active participant in the various industry groups that determine the evolution of the standards. Both PIR and Afilias share a commitment to open standards and ISOC's mission, which is "to assure the open development, evolution, and use of the Internet for the benefit of all people throughout the world."

This commitment is illustrated by plans Afilias already has in place to: 1) improve the speed, reliability, and security of its DNS services; and 2) evolve to the new EPP v0.6, the most recent and current version of this protocol. See Section III ("Technical Plan") for an extensive discussion of this topic.

9. PIR will provide a smooth transition

Central to PIR's selection of Afilias as the back-end provider was Afilias' reputation for stability and its deliberate approach to problem solving. Afilias is a pioneer in transitioning an existing TLD to EPP through its relationship with AusRegistry. Afilias provided technical assistance to AusRegistry for moving parts of the .AU ccTLD to EPP, a transition now in progress and set to launch July 1, 2002. Further, auDA, the .AU governing body, contracted Afilias to certify the transition before allowing it to proceed. We are confident that the transition of .ORG will be as smooth as possible and that any wrinkles that occur will be addressed with Afilias' deliberate, thorough manner. Section III ("Technical Plan") contains a complete plan.

10. PIR will comply with the requirements of the VeriSign endowment

PIR is both able and fully committed to complying with the requirements of the endowment. While the endowment is not required for PIR to successfully transition .ORG, it will greatly accelerate our ability to reinvigorate the domain and make it the true global home of non-commercial organizations on the Internet.

PIR proposes that the endowment be dedicated primarily to expanding outreach to non-commercial organizations on behalf of .ORG. The non-commercial community worldwide is technologically behind other economic sectors in adopting and leveraging the Internet. The key impediment is lack of KNOWLEDGE. To address this pressing need, PIR proposes to field extensive programming for non-commercials in two areas: education and awareness building, especially in technologically emerging markets.

These supplemental efforts will include expanded and tailored versions of the proven ISOC-modeled workshops, Internet Fiestas, and conferences designed to reach out to and educate non-commercials. To build awareness, we would enlarge core marketing and PR activities (e.g. press outreach, speakers at non-commercial events, on-line resource center) to reach more non-commercials with a more tailored package.

In addition, we also propose investing a portion of the endowment in accelerating the availability of new .ORG services designed to help organizations develop their visibility, give donors peace of mind, and connect people to communities. These include: no-cost, value adding services such as name locking, a directory, and site linking; and low cost options to add monitoring, search engine submission and security services. While these products are part of the ongoing plan, endowment funds would provide immediate resources to initiate development and get these into the market more quickly.

These efforts have the dual benefits of helping these organizations enter the Internet age and building .ORG sites through the recruitment of quality registrants. And, they will address the goals of the endowment, since: PIR is a non-profit organization; and these activities deliver primary market development, a future operating expense of the registry. Section IX ("The VeriSign Endowment") contains details.

11. PIR's proposal is complete and realistic, and demonstrates sound analysis

We believe that this proposal is complete, and addresses not only the requirements stated in the .ORG Proposal Form, but also all of the requirements for successfully transitioning and operating the .ORG domain for the benefit of current and future .ORG registrants.

ISOC believes that it has more experience assessing and solving Internet-related issues than any other organization in existence. This makes PIR well qualified to provide general and policy management to a significant domain such as .ORG. Further, its standing in the noncommercial community makes it particularly well suited to manage a domain dedicated to an extremely large and varied community, the needs of which can best be understood by a fellow member.

To provide back-end registry services, PIR has selected Afilias, the leading EPP pioneer. Afilias brings extensive experience with: the .INFO launch using EPP; domain transition to EPP; EPP capabilities such as transfers; and relationships with nearly all of the current ICANN-accredited .ORG registrars. Afilias has an established track record of delivering back-end registry services in a stable, secure, and professional manner consistent with ICANN's requirements.

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C12. Contracted Service Providers

State whether the applicant intends to perform all aspects of the Registry Function, or whether the applicant intends to outsource some or all aspects of the Registry Function to other entities that will provide services or facilities under contract with the applicant. If any portion(s) of the services or facilities will be provided by another entity under contract, please describe which portion(s), state the time period during which they will be provided under contract, and identify what entity will be providing the services or facilities..

PIR will manage all policy and general management aspects of the .ORG domain. Afilias will provide back-end registry services. These include operational interfacing with Registrars and managing the names from registration through resolution. Afilias already supports the .INFO domain. Afilias is committed to the contract between ICANN and PIR for its duration. Afilias, in turn, has long-term contracts with best-in-class technology providers such as IBM, UltraDNS, and DSI Technology Escrow Services (a subsidiary of Iron Mountain Incorporated), which, in combination, enable the company to deliver complete domain services. Section III ("Technical Plan") contains details.

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C13. Identification of Contracted Service Providers

Identify by name each entity other than the applicant that will provide any of the following:

- all services and facilities used to perform the Registry Function;
- any portion of the services and facilities used to perform the Registry Function accounting for 10% or more of overall costs of the Registry Function; or
- any portion of any of the services and facilities used to perform the following parts of the Registry Function accounting for 25% or more of overall costs of the part: database operation, zone file generation, zone file distribution and publication, billing and collection, data escrow and backup, customer (registrar) support, and Whois service.

The identification of each entity should include:

C13.1 The full legal name, principal address, telephone and fax numbers, and e-mail address of the entity, and the URL of its principal World Wide Web site.
C13.2. A general description of the entity's business and other activities.
C13.3. The entity's type (e.g., corporation, partnership, etc.) and law (e.g., Denmark) under which it is organized. Please state whether the entity is for-profit or non-profit. If it is non-profit, please provide a detailed statement of its mission.
C13.4. Dun & Bradstreet D-U-N-S Number (if any) of the entity.
C13.5. The number of employees currently employed by the entity.
C13.6. The entity's total revenue (in US dollars) in the last-ended fiscal year.

See summary chart

Full Legal Name Afilias Limited IBM Corporation ULTRA DNS DSI Technology
Services, Inc.
        (Wholly owned
subsidiary of
Iron Mountain, Inc.)
Principal address Office 125
52 Broomhill Road
Tallaght, Dublin 24 Ireland
New Orchard
Road Armonk,
New York 10504
800 N. San Mateo
DriveSan Mateo,
CA 94401
745 Atlantic
MA 02111
Telephone number +353-1-431-0511 1-914-499-1900 1-650-227-2600 1-617-535-4766
Fax number +353-1-431-0557 1-650-227-2662 1-617-350-7881
E-mail address
World wide web site
Business and other activities Afilias is a fully integrated global provider of domain name registry services. Afilias was formed in September of 2000 and was the first new gTLD operator selected by ICANN in November of 2000 to launch a new registry system using a thick registry model based on the new EPP (extensible provisioning protocol) standard.

At IBM, we strive to lead
in the creation,
development and
of the industry's most
advanced information technologies,including
computer systems, software, networking
systems, storage devices
and microelectronics.

We translatethese
advanced technologies
into value for our
customers through our
professional solutions
and services businesses

UltraDNS™ Corporation is the leading Directory Infrastructure Services Provider (DISP), delivering solutions that enhance the reliability and performance of the world's largest directories and the mission-critical applications that access them. UltraDNS provides managed services and also develops custom infrastructure solutions based on its proprietary Directory Services Platform, the first global directory infrastructure capable of the most demanding database problems -- such as Internet site requests. Iron Mountain, Inc. is the global leader in records and information management services. Iron Mountain currently provides services to over 150,000 customer accounts in 80 markets in the United States and 44 markets outside of the United States. The Company operates over 650 records management facilities in the United States, Canada, Europe and Latin America.
Entity type Corporation Corporation Corporation Corporation
Jurisdiction Ireland New York Delaware Pennsylvania
D-U-N-S 98-539-8986 00-136-8083 15-050-9185 62-253-5417
No. of employees 30 319,876 32 11,300
Annual revenue US$1,118,923 US$85.9 billion Privately held US$1.2 billion
Annual report Attached (See Appendix A)

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C14. Agreements with Contracted Service Providers

For each entity identified in item C13, please state the scope and terms of the contract under which the facilities or services will be provided and attach documentary evidence that the entity has committed to enter into that contract.

ISOC has selected Afilias, Limited to support PIR by providing the back end registry management services for .ORG. Afilias is a fully integrated global provider of domain name registry services and is committed to delivering all the core registry functions required to operate the .ORG TLD successfully, including: database development and management; zone file generation, distribution and publication; operational testing and evaluation; dispute resolution; billing; technical and customer support; data escrow and backup; WHOIS; and system security. At PIR's direction, Afilias will manage the names from registration through to resolution.

Evidence of Afilias' commitment is shown below and in Appendix T.

In addition, Afilias has committed to provide a $250,000 line of credit to PIR to cover any start-up expenses, contingent upon the selection of ISOC's bid by ICANN.

Afilias, in turn, has entered into long-term agreements with the following vendors to provide critical functions for the operation of the registry:

  • International Business Machines (IBM) [] and Afilias have an existing long-term agreement to provide data center, systems and technology. Please refer to Section III for technical details.

  • UltraDNS Corporation (UltraDNS) [] and Afilias have an existing long-term agreement to provide global DNS services on behalf of the registry operator. Please refer to Section III for technical details.

  • Iron Mountain, Inc. (DSITechnology Escrow Services) [] and Afilias have an existing long-term agreement to perform data escrow services. Please refer to Section III for technical details.

C15. Abilities of Applicant and Key Technical Personnel

Describe in detail the abilities of the applicant and the entities identified in item C13 to operate a TLD registry of significant scale in a manner that provides affordable services with a high degree of service responsiveness and reliability. Your response should give specifics, including significant past or present achievements and activities of the applicant and the entities identified in item C13 that demonstrate the described abilities. It should also include information about key technical personnel (qualifications and experience), size of technical workforce, and access to systems development tools.


A. Overview: Applicant's ability to operate the .ORG TLD registry

ISOC believes that it has more experience assessing and solving Internet related issues than any other organization in existence. Through its links to virtually every significant Internet technical body, it has access to the Internet's most experienced and visionary individuals. This provides PIR with outstanding qualifications for the general and policy management of .ORG.

Further, ISOC has senior standing in the noncommercial community, as illustrated by the endorsements detailed in Section VII ("Responsiveness to the Noncommercial Internet user Community"). This will make it much easier for PIR to successfully manage a large domain dedicated to the needs of fellow noncommercial organizations.

PIR has chosen Afilias as its back-end registry services provider. Afilias brings significant strength to .ORG, including: 1) experience managing a large registry in a stable, secure manner; 2) EPP knowledge including transition of existing names to EPP; and 3) existing capacity to immediately handle the demands of .ORG. Further, Afilias has standing relationships with virtually all of the ICANN Accredited registrars currently handling .ORG.-which will make the transition even smoother.

The management of a domain of the scale of .ORG is a significant challenge for any organization. However, we have assembled a seasoned team that possesses the qualifications, character and capacity to revitalize .ORG and enable it to fulfill its potential as the global home of noncommercial entities on the Internet.

B. Key Technical Personnel/Size of Technical Workforce/ Access to Systems Development Tools

Afilias' technology team combines many years of experience in designing, building and maintaining highly scalable, distributed and networked transaction-based systems. The team is led by Ram Mohan, the company's VP of Business Operations and CTO, along with Howard Eland, Afilias' Senior Technology Architect, Michael Young, the company's Director of Information Technology, and Andrew Sullivan, the company's Senior Database Architect.

Ram helped Afilias navigate through the launch of the .INFO domain, including the first-ever large scale random-ordered queue processing system, followed by a transition to a real-time first-come-first-served Registry system. Ram's prior experience is in massively parallel, real-time transaction based systems in the search engine and financial services industries. Ram was the architect of and led the team responsible for one of the largest existing full-text document search engines in the world, Electric Library ( - a system that serves over 4,000 transactions concurrently with sub-second performance, performing natural-language search over 40 million documents with over 500 million keywords. Ram serves on ICANN's Committee on Security and Stability, is a member of the DNSO WHOIS Task Force, and is the Registry representative on ICANN's Technical Steering Committee on Redemption Grace Periods. Ram has a BS in Electrical Engineering from the University of Mangalore, an MBA in Entrepreneurial Management from Bharathidasan University, and is completing an MS in Computer Science from Drexel University, Philadelphia.

The team's strengths are significantly augmented by Howard Eland, the company's Senior Technology Architect. Howard most recently helped design the new EPP-6 compliant .AU registry to be highly scalable and support the transition of over 300,000 .AU domains. Howard brings a background in networking, security, database and systems architecture, and is an Internet pioneer who founded Information Technology Enterprises Inc. (ITEI), an early Internet and Application Services company. Howard's prior experience includes significant assignments at Infonautics Inc, and at AT&T GIS' Federal Systems Division, including the development of 2,000,000 lines of C language code for X.400 systems for the US Army. Howard is actively involved in the IETF's provreg group, as well as other Internet standards working groups. Howard has been published in various peer-reviewed technical journals. Howard has a B.S. in Computer Science from the Michigan State University.

Michael Young strengthens the company's technology leadership. In his role as Director of Information Technology, Michael oversees the day-to-day operations of the .INFO registry, and is responsible for the significant optimization of the Registry system in 2001, leading to its stable, speedy and scalable characteristics. The most recent 7 years of Michael's 12 year IT experience has been in systems operations and software development management, specializing in 24/7 high availability environments. Michael headed up technology operations for one of the Canadian Stock Exchange's institutional brokerage houses, Griffiths McBurney and Partners. As, Senior Project Manager at an Internet based grocery retailer,, he coordinated and engineered the start-up of mission critical systems involving business systems, development and IT. In addition to numerous technology certifications, Michael has a B.A. from the University of Toronto.

Andrew Sullivan is the company's Senior Database Architect, and brings strong knowledge and experience in database design, development and deployment. Andrew began exploring database design in 1996, while pursuing graduate studies at McMaster University. His interest led him to abandon his studies, and to enter the technology sector. After two years, he returned to McMaster to work in Computing and Information Services. He holds a B.A. form the University of Ottawa and an M.A. from McMaster University. Andrew is active in the database community.

Afilias' technical workforce numbers over 20, and includes key personnel in Database Administration, Systems Architecture, Quality Assurance, Technical Support, Documentation, Database Analysis, Financial Systems and Billing Support, as well as front-line Customer Support. Section III, C17.11 describes in further detail key technical personnel who will help the .org registry establish the highest standards of customer service and problem resolution.

The .ORG registry will have access to the full range of systems development and monitoring tools that have been acquired or developed by Afilias. These tools will provide the .ORG registry unparalleled ability to provide best-of-breed services to registrars, registrants, organizations, individuals and other interested parties. The registry has a strong background and has implemented engineering standards in each of the major components of registry management, including (but not limited to) software code management, quality assurance and control, software operations metrics, systematic testing procedures and formal development and operational methodologies. The .ORG registry intends to meet or exceed stringent technical, security and performance standards and set the benchmark for how a registry in the public interest ought to operate.

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| Table of Contents | Section 1 | Section 2 | Section 3 | Section 4 |
| Section 5 | Section 6 | Section 7 | Section 8 | Section 9 | Section 10 |

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