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C19. Please describe in detail mechanisms that you propose to implement to ensure compliance with ICANN-developed policies and the requirements of the registry agreement.

Through the designation of senior staff that will be responsible for policy development and implementation, as well as established mechanisms to ensure compliance, RegisterOrg will operate in accordance with ICANN-developed policies and requirements of the registry agreement.

RegisterOrg plans to fully comply with all ICANN developed policies, including consensus policies, and the requirements of the .org registry agreement. We believe that no registry can optimally function without the support, trust, and confidence of its sponsoring registrars and the DNS community as a whole. Therefore, RegisterOrg will be committed to operating the .org Registry as a trusted neutral third-party provider of registry services. Moreover, in conjunction with ICANN, RegisterOrg will develop responsible policies and mechanisms for ensuring that the registry best serves the public interest by providing for equal treatment of all registrars using the system, respect for the privacy and access to the Whois database, compliance with the UDRP, and other registry policy matters.

For more than four years,, the parent company of RegisterOrg, has consistently complied with and operated its registrar division in accordance with ICANN’s technical and policy management. has been a leader in collaborating with ICANN and the various Internet constituencies. In coordination with the Intellectual Property constituency, helped craft and establish the Uniform Dispute Resolution Process to effectively protect the rights of trademark owners. Moreover, strictly enforces a corporate policy that protects the interests of its customers’ intellectual property interests. also participates in ICANN processes to craft fundamental DNS-related policies, including the Registrar Code of Conduct, a Best Practices Statement for the Aftersale Market, and an Escrow Policy. Not only has played a leadership role, but the Company has taken initiative in ensuring the best service to its customers and setting a standard for the registrar community.

The Company is therefore familiar with ICANN policy and oversight. Moreover, RegistryPro—which finalized an agreement with ICANN in May 2002 to serve as the operator of the .pro top level-domain, and is owned by—has implemented requirements for ensuring, among other things, equivalent access for all registrars, compliance with a sanctions program, and technical protocols as they are developed. The Company has therefore already instituted the mechanisms described below.

Policy Compliance: Registry Staff Guidance and Oversight
To oversee registry policy compliance, RegisterOrg’s staff would include a Policy Director who would be designated, along with RegisterOrg’s (outside and internal) legal counsel, to administer duties including the following:

1. Execute the .org registry agreement between RegisterOrg and ICANN.

2. Identify and oversee implementation of all policies and requirements under the ICANN registry agreement, including policies and procedures designed to promote openness, competition, and transparency—such as a Code of Conduct, an Equivalent Access Policy, and an Access to Data Policy (see C21).

3. Oversee all subcontractor compliance and training.

4. Implement policies, including regular staff and subcontractor training and education about the requirements, to ensure that all policies are implemented in an equitable manner with regard to all sponsoring registrars.

5. Participate in the ICANN gTLD constituency meetings and listserv to monitor any developments of registry policy or ICANN consensus policy.

6. Monitor policy announcements by ICANN and participate in ICANN meetings to keep abreast of policies developments and update registry staff of any such modifications.

7. Inform ICANN’s general counsel, in a timely manner, of any changes to the .org contact information held by ICANN. 8. Oversee compliance with the UDRP.

9. Assist in training staff and subcontractors with regard to compliance with ICANN and registry agreement-related policies (such as policies pertaining to organizational conflict of interest).

10. Ensure that all registry agreements, including but not limited to Registry-Registrar agreements and vendor agreements, shall include requirements to comply with ICANN policies and the requirements of the .org registry agreement.

In addition, the Registry’s technology staff will monitor any developments by ICANN, to remain in compliance with technology developments, protocols, and best practices. The Company’s (registry) technical staff already collaborates in the Internet Engineering Task Force (IETF) working groups on technical management of the DNS, in particular working on the evolving next-generation registry-registrar protocol. The Company’s technical staff will continue such collaboration in order to ensure continued compliance with IETF policies and protocols.

The chief technical officer would also be responsible for overseeing implementation of ICANN policies concerning interoperability of .org with the DNS and Internet generally; operational capabilities and performance of the Registry; and the obtaining, maintaining, and public access to, accurate and up-to-date contact information for .org registrants.

Registry Agreement Requirements: Compliance Mechanisms
In the event it is designated as the operator of the .org registry, RegisterOrg will establish the following mechanisms to fulfill the obligations established under the proposed .org Registry Agreement.

Provide Registry Services Meeting Functional and Performance Specifications
RegisterOrg will operate and maintain in a stable and secure manner the authoritative primary and secondary name servers of the .org, TLD adequate to resolve names within .org for users throughout the Internet, and any sub-domains over which they retain administrative authority. RegisterORG will ensure that the zone file and accurate and up-to-date registration data is continuously available to ICANN for purposes of verifying and ensuring the operational stability of the .org domain.

Fairly Treat All Registrars
RegisterOrg will enter into equivalent (ICANN approved) agreements, with regard to all material terms, including pricing, with all ICANN-accredited registrars seeking to offer the .org domain name. RegisterOrg will also provide registrars with the ability to become sponsoring registrars in an equivalent manner. Moreover, as described in our answer to question C21, the Registry shall provide all sponsoring registrars with information and access to the shared registry system in a fair, timely and equivalent manner. Each registrar will be provided with the same access methods and an equal number of connections to the shared registry system, including access to Web- and phone-based customer support. To assist registrars in different time zones and using different languages, each registrar will be appointed a liaison charged with overseeing all aspects of the relationship and that can meet the needs of the registrar partner. Moreover, each registrar will be provided secure access to the registrar Web-based portal that will feature various self-help mechanisms and support information.

RegisterOrg will conduct internal neutrality reviews of itself and any subcontractors on a regular basis to ensure that it is in compliance with the Registry Code of Conduct (described in our answer to question C21). In addition, the Registry and ICANN may mutually agree on an independent party that ICANN may hire, to conduct a neutrality review of the registry and its subcontractors to ensure that the registry, any subcontractors, and its owners are in compliance with the Code of Conduct.

To bolster confidence in the registry, and earn the public trust, the Registry will also provide certifications regarding the code of conduct and equivalent access six months (6) following the effective date of the .org Registry Agreement, and each subsequent six-month (6) period thereafter. The .org Registry shall certify to ICANN that it is providing all ICANN-accredited registrars with equivalent access to the Registry.

RegisterORG will participate in the ICANN sanctions program, which is intended to allow ICANN flexibility to address violations of the Registry Agreement by means less extreme than proceedings to terminate the Registry Agreement. Generally, through the Sanctions Program, ICANN will be able to conduct investigations into the operation of the registry upon receipt of a credible allegation of a specific violation from an ICANN-Accredited Registrar in good standing. The Sanctions Program provides clear guidance on the protocols of such investigations and the role of the Registry in the process. Just as each of the current gTLD’s is participating in the program, RegisterOrg, as part of its Registry Agreement, would commit to the same.

Periodically Escrow Registry Data
To ensure the safety and integrity of the registry database, the Registry will periodically deposit registry data into escrow. RegisterOrg has already identified an appropriate escrow agent for which it would seek ICANN approval.

Provide Whois Services
RegisterOrg will provide an interactive Web page and centralized Whois service, with public query-based access to a real-time updated database. The Registry will operate the centralized, authoritative, and shared database of .org domain names, in compliance a new service level agreement. It will also update the database, per commands received through registrars.

Financially Support ICANN
Through the timely payment of quarterly fixed and variable registry-level fees, the Registry will meet its obligation to provide registry-level financial support of ICANN.

We believe that RegisterOrg will be able to fully comply with its policy and registry agreement requirements through the designation of senior staff, with policy, legal, and technical expertise. These individuals will bring with them the knowledge and demonstrated compliance capabilities from RegisterOrg’s parent company,


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