Name.Space TLD Registry Application

Name.Space, Inc.

ICANN gTLD Registry

Accreditation Application

September 30,2000

Generic Top Level Domain Registry Accreditation Application

Name.Space, Inc., currently operates highly automated and technically advanced domain registry and registrar services spanning the full range of technical, administrative and financial qualifications established by ICANN for a shared registrar system ("SRS") testbed applicant. Name.Space is well-positioned to bring significant cost efficiencies and technical improvements, including diverse routing, "smart" whois service and server mirroring, to second level domain registrations in new gTLDs that Name.Space publishes and operates. Given Name.Space’s unparalled real-world experience operating a global nameserver system and automated, Web-based domain registration worldwide, Name.Space provides a proven track record of reliable service and ground-breaking innovation to the ICANN gTLD registry process.

I. GENERAL INFORMATION

D2.) Name.Space, Incorporated

11 East 4th Street Second Floor

New York, New York, 10003

USA

Telephone: 212.677.4080

Fax: 212.677.3603

Email: info@name-space.com

D4.) Type of Business: Corporation; Legal Jurisdiction: United States

D5.) URL: http://name-space.com

D6.) D-U-N-S Number: 96-828-3739

D7.) Number of employees: Under 10

D8.) Total revenues last fiscal year (1999): -$251,827

D9.) Full names and positions of:

(i) All Directors:

Founder/CEO: Paul Garrin

(ii) All Officers:

CFO: Satomi Sugishita

(iii) All relevant managers:

N/A

(iv) Any persons or entities owning five percent of moreof registry operator

Jaghi Trade

Faurschou Gallery

D10.) Name, telephone and fax number, and e-mail address of person to contact for additional information regarding this proposal:

Contact Person: Paul Garrin

Contact Telephone: 212.677.4080

Email: pg@name-space.com

D11.) The full legal name, principal address, telephone and fax numbers, e-mail address, and Dun & Bradstreet D-U-N-S Number (if any) of all subcontractors identified in item D15.3 below:

N/A

II. Business Capabilities and Plan

D13.1.) Detailed description of the registry operator's capabilities:

Name.Space, Incorporated ("Name.Space"), including its predecessor company pgMedia, Inc., has been a pioneer in the domain name registration and name service business since 1996, developing and servicing new generic TLDs and providing related value-added services. Since June 1998, Name.Space has also operated as an independent reseller of second level domains in the legacy ".com." ".org," and ".net" TLDs, offering simplified, secure, Web-based registration and administration services oriented toward small businesses and individual consumers. Online operations are currently up and running and may be accessed via the Web site at <http://name-space.com>.

One example of Name.Space’s practical technological developments is the "smart" Whois (sWhois) service, created in 1996. sWhois is a universal domain name search engine that handles all toplevel domains, ccTLDs and new gTLDs, and queries the appropriate database, returning domain informaiton, or indicating the availability of a domain for registration. sWhois can also search IP number block assignments, Internic handles, and registered nameserver host information, all via a simple, web-based form, or via UNIX command line on standard "whois" port 43. Name.Space was the first to successfully implement a global whois service, and is among the very few who offer this capability to internet users today.

Name.Space provides a free, encrypted web-based email service called "LokMail" to its customers. LokMail is compatible with standard PGP and GnuPG encryption, and uses a standard 128 bit SSL brower/server connection. Name.Space encourages the use of encryption and digital signatures to protect the integrity of confidential communications with customers, which may contain sensitive account information such as passwords or credit card information, as well as to authenticate update requests to domain and contact information. Name.Space intends to make the use of encryption and digital signatures a standard feature available to all of its domain registration and web hosting clients, as well as to its affiliates and resellers.

Current operational facilities consist of the company’s main premises, located at 11 East 4th Street, New York, N.Y., occupying the entire second floor at that location. Connectivity at that site currently consists of two full 1.544Mbps T1 service (clear channel) running BGP routing through two different upstream providers to provide for route redundancy and to insure against interruptions in service.

Name.Space operates a nameserver network consisting of seven redundant and geographically diverse nameservers, in addition to its New York City production center, co-located at various facilities in San Jose, California (in a facility with T3 connection and backup generators), New York (redundant T1’s), Amsterdam (2Mbps connection), with volunteer servers operating in , Stockholm (10Mbps connection), Riga (2Mbps connection), Amsterdam and Ljubljana. Present server locations are publicly accessible at <http://name-space.com/admin>.

Presently, Name.Space serves international clients in regions as diverse as China, India, Singapore, Malaysia, Hong Kong, Taiwan, in addition to Europe and North America and Australia. We plan to extend our market globally by translating our interface into Italian, Spanish, Portugese, French, Japanese, Korean and Chinese and by forming alliances with ISPs who serve clients in those languages. We have already begun dialogues with potential partners interested in local language domain services.

D13.2.) Current Business Operations:

Name.Space, Incorporated

11 East 4th Street Second Floor

New York, New York, 10003

USA

Telephone: 212.677.4080

Fax: 212.677.3603

Email: info@name-space.com

Date of Incorporation, January 22, 1999

Name.Space previously owned and operated by

pgMedia, Inc. Incorporated May 8, 1996

Type of Business: Corporation; Legal Jurisdiction: United States

Ownership: Privately owned and operated

URL: http://name-space.com

URL: http://DNS411.com

URL: http://sWhois.net

URL: http://MakeMy.com

D-U-N-S Number: 96-828-3739

Number of employees: Under 10

D13.1.3. Past business operations/entity history:

pgMedia, Inc. d/b/a/ Name.Space

11 East 4th Street Second Floor

New York, New York, 10003

USA

Telephone: 212.677.4080

Fax: 212.677.3603

email: info@pgmedia.net

pgMedia, Inc. incubated the Name.Space business beginning in 1996. It began publishing and operating new gTLDs during the summer of 1996 and opened its services to the public for registrations in September of 1996. pgMedia’s Name.Space business had a sole purpose to publish and operate registry and registration services for new gTLDs. pgMedia developed the first generation of software for the Name.Space real- time registry system and "smart" whois system.

In 1999, new investment came into the business and the corporation Name.Space, Inc

was formed on January 22, 1999. Name.Space, Inc. took over the complete operations

of the Name.Space business. pgMedia, Inc. owns a minority stake in Name.Space, Inc.

D13.1.4. Registry/database/Internet related experience and activities:

Name.Space has operated TLD registry services and SLD registrar services since 1996, and has been a provider of web hosting and email services since 1997. Name.Space has developed its systems entirely in-house using open-source software and development tools. Engineers at Name.Space have advanced degrees in engineering, as detailed below.

Billy Donahue has worked with internet-oriented Perl andJava programs for 5 years now. Every project has involved a database backend for which he was the database administrator as well as application programmer. he's run Oracle, mySQL and PostgreSQL installations on UNIX and Linux platforms. Billy is the author of sWhois 3.0 and the latest Name.Space registry system. Billy holds Bachelor's and Master's degrees in Electrical Engineering from The Cooper Union. He has worked at Lucent Technologies writing DSP firmware code for cellular base station equipment. He is also an experienced web developer. He commands a mastery of a wide variety of programming idioms including Assembly, C, C++, Perl, and Java as well as SQL, Postgres, and other database technologies. He specializes in UNIX based computing, particularly Linux. He is a member of the New York Linux User's Group and has contributed to the development of the Linux kernel.

Simon Lok is presently a contractor and consultant to Name.Space whom the company seeks to hire full-time as Chief Security and Technical Officer. Mr. Lok is currently the Vice President of INW, Inc., a solutions integrator and value added reseller based in New York, a position that he has held for three years. His previous position was that of a network administrator at an educational institution where he successfully lobbied for over 12 million dollars in software donations over the course of two years from vendors including HP, SGI and OrCAD. Prior to that, Mr. Lok was a software engineer and systems administrator for NASA's Goddard Institute for Space Studies where he helped develop interfaces to global climate modeling software. Mr. Lok is also involved in cutting edge technology research including parallel-distributed computing clusters, tactical mobile robotics and microwave frequency logic gates for which he has patents pending. Mr. Lok holds professional certifications from Microsoft (MCSE, MCP+I) and Cisco Systems (CCNA) as well as a Bachelors and Masters of Engineering degrees in electrical engineering from The Cooper Union. Mr. Lok is currently a Ph.D. candidate in Computer Science at Columbia University.

D13.1.5.) Mission.

Name.Space was founded in 1996 to publish and provide registry services for new generic toplevel domains (gTLDs), such as .art, .cam, .design, .gallery, .music, .news, .shop, .sports, .sex, and others, to open the domain name market to competition and diversity and to bring new services to the marketplace, as well as provide cultural and educational support for communities, and to bridge the "digital divide". Through public survey, Name.Space has selected, established, published and presently operates over 540 new gTLDs. Through practice and hands-on development, Name.Space and its engineers have proven the concept for new gTLDs that are published and managed in accordance to market demand and best technical practice, beyond any doubts.

In the past, many have declared that it could not, or should not be done--to add large numbers of new gTLDs. The question "why so many?" is not at all difficult to explain. Some gTLDs will inevitably become commercially successful as witnessed by the "dot-com" phenomenon.

When the "dot-everything" phenomenon comes, not all TLDs will fare that well in terms of commercial success, but nonetheless have value for non-profit, educational, cultural, or other uses. Although there is a strong value to cultural, educational and non-commercial TLDs, registrations in them may not total the numbers sufficient to pay the necessary infrastructure costs to support them. If a registry were limited to operating only a single TLD, one that may not turn out to be a popular commercial success, or by its nature is oriented toward expressive, educational or non-commercial use, said registry would have to charge prices too high for most non-profits to afford. A popular commercial TLD can easily support registry operations for the less popular TLDs because once the necessary technical and business infrastructure is in place to run one TLD, sufficient resources remain available to simultaneously operate a large number of additional TLDs with no substantial increase in costs. This model is proven in that Network Solutions can charge the same price for "com" "org" and "net" because they operate them on the same infrastructure, thereby sharing the costs of operations. This same scenario allows NSI to continue to support "edu" domains for free. This model can be refined and improved with new TLDs in order to keep the prices fair across the board for TLDs that are both popular and commercial and those that are cultural and non-commercial, while giving investors an excellent return on investment.

During the course of development, the Name.Space Lab in New York has spun off many features and services that have become popular and even emulated by others. These include a "Smart" Whois (sWhois) the Universal Domain Search located at http://swhois.net and http://DNS411.com., and secure, online Portable Account Manager, and of course the first fully automated real-time new gTLD domain registry and database with real-time domain activation and whois data updates.

All new domain name registrations begin with a search. sWhois is registry/registrar aware for all "legacy" TLDs, ccTLDs, gTLDs, IP address assignments, Autonomous System Numbers, NIC handles, and selective general search. sWhois is the center of the "shared registry universe" and is an essential tool to provide powerful domain directory access across the globe and throughout a diverse namespace. In a "stand-alone" mode, sWhois is a the most powerful DNS and IP Number search tool on the Internet. sWhois can also act as a "meta" registrar, to find the best prices across all registries/registrars, creating a unique business opportunity and a valuable service to customers.

Once a client establishes an account with Name.Space, they need to manage it to configure their DNS records where appropriate, and to access their contact information to keep it up to date. Secure, online account management using 128 bit SSL makes a domain portable by allowing client to update domain to IP mappings to change as their service provider does, or for "dynamic" DNS (DynDNS) purposes. This Portable Account Manager (PAM) also enables clients secure access to their contact information and may update it safely, quickly and conveniently, as well as use it to make instant online payments to their accounts with their credit cards.

This high degree of automation is key to the efficiency and the success of the Name.Space model and a key competitive advantage the company has.

D13.1.6.) Management. Qualifications and experience of financial and business officers and other relevant employees.

The company was founded in 1996 by Paul Garrin, who continues as CEO. Paul has a wide range of hands-on experience in art and technology that spans 20 years and includes his work in video art, experimental advanced television and computer animation, interactive systems, robotics and internet. His unconventional mix of knowledge and experience in media, communications and technology led to the creation of Name.Space, and the establishment of a model service for the DNS industry. Paul holds a Bachelor of Fine Arts from Cooper Union; Awards include NY State Council for the Arts, NY Foundation for the Arts, ZKM Media Arts Prize, Ars Electronica Prize, and others. Paul's work has been published worldwide, and he has lectured internationally on media art and internet in both academic and non-academic forums. Media Art installations by Paul Garrin have been exhibited internationally including Holly Solomon Gallery, Sao Paulo Biennale, Lyon Biennale, Musee d'Art Contemporaine du Montreal, Kwangju Biennale, Faurschou Gallery, and others. Paul is a member of CPSR (Computer Professionals for Social Responsibility) and serves as a member of the CPSR working groups on Privacy and Domain Name Policy. He also is a member of the ICANN Domain Name Supporting Organization (DNSO) and its Working Group C dealing with issues of new generic top level domains.

Satomi Sugishita is the Chief Financial Officer of Name.Space, and wears many hats, including web designer. Satomi holds a Bachelors of Science degree and graduated with honors from New York Institute of Technology. Satomi is accomplished in television and video production, having worked formerly for NHK-TV, Japan as Producer and video editor. In addition to her "number crunching" skills, Satomi is proficient in HTML, Javascript, Photoshop, and a wide range of image and web authoring tools. Satomi designed the Name.Space and DNS411.com websites, among others.

Billy Donahue is presently a contractor whom the company seeks to hire full-time as Chief of Software Engineering. Billy holds Bachelor's and Master's degrees in Electrical Engineering from The Cooper Union. He has worked at Lucent Technologies writing DSP firmware code for cellular base station equipment. He is also an experienced web developer. He commands a mastery of a wide variety of programming idioms including Assembly, C, C++, Perl, and Java as well as SQL, Postgres, and other database technologies. He specializes in UNIX based computing, particularly Linux. He is a member of the New York Linux User's Group and has contributed to the development of the Linux kernel.

D13.1.7.) Staff/employees. Current staff size, demonstrated ability to expand employee base, hiring policy, employee training, space for additional staff.

Name.Space will expand its staff to meet growth demands over the next 12-18 months. Additional staff positions will include a Chief Financial Officer, a Business and Marketing Director, Systems Maintenance Engineer, and Customer Service and Phone Support.

The Name.Space Production Center on East 4th Street in Manhattan has sufficient space to expand staff for the forseeable and expected demand. In the event that additional staff is needed, Name.Space may consider outsourcing, depending on the service required, or hiring additional staff and acquiring sufficient space to support them in the event staff requirements exceed present facilities.

In-house technical staff and management will train new employees on the job.

New employees will be screened according to their capabilities and will be required to have proficiency in their field at the time of hiring. Name.Space will provide an internship program for students to engage in on the job training with our staff. Name.Space will also be seeking to form community partnerships with public schools and non-profit community and cultural organizations and plans to initiate a community service program to raise awareness about computers and technology for communites and cultural use, and to bridge the digital divide.

D13.1.8.) Commercial general liability insurance. Address/include amount of insurance policy, provider of policy, plans for obtaining additional insurance.

Name.Space presently carries a 5 million dollar commercial business and liabilities policy

with Hanover Insurance.

SEE ATTATCHED PROOF OF INSURANCE

D13.2.) Business plan for the proposed registry operations.

Name.Space, Inc.

Company Overview

Table of contents

1 Introduction………………………………………………............…………….3

1.1 Business concept

1.2 Background

2 Product and service offerings…………………………………………4

2.1 Wholesale domain name registrar

2.2 TLD operator and registry for new and emerging Generic Toplevel Domains

2.3 Small business ecommerce internet solution provider

3 Domain name market.......................................................................................5

3.1 Changes in the Market

3.2 Market structure

3.2.1 Legacy domain names

3.2.2 New generic Toplevel Domain names

3.2.3 Security

3.3 Market opportunities

4 Competition..........................................................................................................9

4.1 Competitive Analysis

4.2 Competitive products and services

4.3 Competitive capabilities/weaknesses

5 brief financial status..................................................................................11
6 Human reSources.............................................................................................12
7 Strategic Alliances.......................................................................................13

8 Capital requirements....................................................................................15

9 registry failure contingency.................................................................16

1. Introduction: Name.Space, Inc.

1.1 Business Concept

Provider of secure, automated online Top Level Domain registry, management and accounting services, Wholesale provider of TLD services, Application Service Provider to domain registrar/resellers, sWhois (Smart Whois) Universal Domain Search Engine, Generic Toplevel Domain Name server operations in 5 countries, Public Key Infrastructure and digital signatures, and an interest in a secure web-based email solution.

1.2 Background

This high degree of automation is key to the efficiency and the success of the Name.Space model and a key competitive advantage of the company.

2. Product and service offerings

The company owns proprietary technologies that were developed in-house, several excellent brand names and domain names that it uses to market its services, as well as an interest in a new secure, encrypted webmail service called LokMail. Some of those brands include "DNS411.com" popular domain reverse-lookup service, and "Name.Space" the primary corporate identity and signifier of new toplevel domains.

The technologies and infrastructure that evolved out of the Name.Space lab since 1996 set a model for the industry and a solid basis for our business and include:

2.1 Wholesale Top Level Domain Name Registry

Primary wholesale provider of new and emerging gTLDs, Provider of new gTLD registry services to "registrar" resellers at wholesale rates. Recurring annual revenues, high volume continuous growth.

Name.Space provides registry service to Internet Service Providers (ISPs) for new gTLDs to sell domain registrations at wholesale rates to high volume clients including ISPs, agencies, web design and hosting firms.

2.3 Small business ecommerce internet solution provider

Value-added service provider providing custom, secure DNS services, web presence, secure and conventional email solutions. Recurring monthly and annual revenues, higher price point for aggregated and packaged services, provided in-house and through strategic partnerships.

Provider of co-branded and custom branded solutions to affiliate partners and resellers License and lease back-end technology for domain registrars and resellers Turn-key systems for partners provide recurring revenues. Resellers handle marketing and client billing. Recurring revenues, high volume continuous growth.

3. Domain name market

3.1 Changes in the Market

The domain name market was dominated by a set price of $70 for an initial registration period of two years. Opportunities for resellers was limited and margins relatively low. The new "registry/registrar" model of wholesale/retail changes the price structure of domain name registrations. Companies who have paid the $5000 ICANN accreditation fee, $10,000 to NSI for registrar software, can buy domain names at a wholesale price of $6/year per domain now, directly from NSI. This puts a severe downward pressure on the price, and increases the potential margins for resellers and value-added resellers.

3.2 Market structure

The market structure for the Name.Space gTLD registry is very similar to the wholesale (registry) / retail (registrar) model now in effect between Network Solutions as "registry" and ICANN accredited "registrars".

3.2.1 Legacy domain names

a. Primary wholesaler (registry/NSI) sells $6 to Primary reseller

(registrar/Name.Space)

b. Primary reseller (registrar/NS) sells $10-15 to Secondary resellers (ISPs)

c. Secondary reseller (ISPs) sells $20-35 to end users

NSI and several others have chosen to keep the price at $70/2 years and $35/year, and charge additional rates for value-added services. Other "retailers" are offering domain names for "free" when they purchase other services (such as web hosting or long-distance telephone service).

Competition in the "retail" end of the market will be price competitive and marketing intensive, requiring more expenditures on marketing, therefore requiring higher prices or capitalizaton. Increased numbers of players in the domain name market will drive the price down and force competition in value-added services and customer service.

3.2.2 New generic Toplevel Domain names

New gTLDs will bring new opportunities to Name.Space as a candidate for registry services for new gTLDs it presently operates, and as a registry with an already established and functioning business in the field of new gTLDs.

A wholesale (registry) retail (registrar) structure, similar to that in place with the NSI registry/ICANN accredited registrar, is appropriate at this time since it is relatively easy and cost effective to implement and has proven successful for many businesses who participate.

3.2.3 Security

Security and privacy are serious issues largely ignored by our competitors. Name.Space has an advantage in security practices and capabilities to provide secure and trusted DNS, email and web services.

Domain registrars will increasingly provide certification services for digital signatures, encryption public keys and e-commerce. Name.Space has begun using PGP keys for signature authentication and secure communications with clients, and has well-established computer security practices and services. A law was recently passed in the US recognizing digital signatures as legally binding. This presents an additional opportunity for Name.Space to leverage its position as a certifier of digital signatures, as well as provide encryption services to our clients to protect their data security while doing business with Name.Space.

Mobile IP devices will demand dynamic DNS (DynDNS) services and directory services. Name.Space has the technology that naturally incorporates these functions and services, and can evolve to meet the demands of the growing and expanding IP based universe that includes telephone to IP-telephone migration that will increase demand for DNS and dynamic DNS services to support increased IP device mobility. DynDNS services exists today, but are not secure and are vulnerable to hijack and malicious abuse. Name.Space Secure DynDNS is a solution to the vulnerabilities inherent in other DynDNS systems.

3.3 Market opportunities

The acceptance and global recognition of new gTLDs presents a great opportunity for Name.Space, an early mover and pioneer of new gTLDs and services, to be a primary wholesale registry for new gTLDs. It is possible that a number of gTLDs published and operated by Name.Space will become globally recognized by ICANN or other means, and Name.Space will be in a position similar to NSI's position with legacy domains for at least some of the new gTLDs. As a provider of new gTLDs to the primary wholesale market, as well as the retail market, Name.Space would be likely to service several million accounts over the next 24-36 months, in addition to a number of possible legacy domain clients, resulting in substantial revenues and profits.

The domain name market is growing at an increasing rate, and will continue to grow as more people use the internet, and as more telephony and other communication devices migrate to IP based systems that will use domain names to address them. The increasing mobility of IP based systems will create opportunities to market mobile DNS services. New gTLDs will expand the offerings of attractive, sensible and expressive domain names as well as expand the present market limitations of legacy domains well beyond the present limits.

Security and privacy have always been among the main concerns at Name.Space, and this year, the heightened level of awareness of the importance of computer security and encryption technologies that protect computer systems and individuals' privacy have become key issues in the public eye as well as in the corporate board room. As an early mover in secure systems and services, Name.Space can gain consumer confidence as a provider of LokMail encrypted webmail services, and secure DNS services. Other popular webmail systems, including Hotmail and Network Solutions webmail have had repeated and high-profile compromises of users accounts and information. Name.Space can benefit by providing the best secure webmail solution along with its domain name services, and by integrating the secure mail and encryption capabilities into its every day dealings with its clients. Name.Space can also gain greater consumer confidence by its strong and progressive privacy policy geared for maximum protection of its clients’ privacy.

3.4 Marketing plan

Functioning primarily as a wholesaler of gTLD registry services, Name.Space intends to develop a stong registrar/reseller base. Because Name.Space strongly believes that the gTLDs that it publishes and operates will be highly popular, and as proven by our own usage statistics, users will seek them out as they now do with "legacy" domains. By making its complete capabilities available to our clients, Name.Space will reduce time to market and lower the barrier to entry by scaling its role as an "Applications Service Provider" to a "Solutions Provider" in accordance to client demand and budget. Name.Space will offer opportunities for resellers to license the Name.Space brand name and technology to provide Name.Space services in their local languages and or to their local communities at an affordable scale. Name.Space will also work with non-profit, community, and cultural groups to set up a domain name partnership to help fund access, training and resources and to bridge the digital divide.

4. Competition

4.1 Competitive Analysis

The domain name industry is dominated by a few major players, the most prominent, Network Solutions, whose main advantage lies in the US Government monopoly that it has had over domain names, and the monopoly it still has over the .com, .org, and net.

TLDs as "primary wholesaler" of "legacy domains". NSI has a customer base of more than 7.5 million acquired largely because of their monopoly.

Multi-level market structuring of the domain market, brought about by actions of the US Department of Commerce and the agreements that it executed with ICANN and NSI introduced tiers of wholesale and retail businesses selling domains.

The main competitors who have gained prominence in the retail market are Network Solutions, Verio/Tabnet, Register.com. These companies are among the better-funded domain retailers, and also among the highest priced.

In the "interim-wholesale" sector, that is accredited registrars who buy domain registrations for $6/year from NSI and offer them at a marked up (or 2nd tier) wholesale price to ISPs, there are two major players: TUCOWS, who offers ISPs a wholesale price of $10/year/domain at a flat rate, and Alabanza/Bulkregister.com, who charges an initial "membership" fee, then allows ISPs to register domain names in "bulk" at $10-15/year. Both of these companies are well-funded.

4.2 Competitive products and services

	Network Solutions	Register.com	VERIO/TabNet	Name.space
Wholesale Domain Name Registrations	Yes	No	No	Yes
Retail Domain Name Registrations	Yes	Yes	Yes	Yes
Domain Web hosting	No	Yes	Yes	Yes
URL forwarding	No	Yes	Yes	Yes
Domain Email	Yes	Yes	Yes	Yes
Email Forwarding	No	Yes	Yes	Yes
Web-based email	Yes	Yes	Yes	Yes
Secure Web email	No	No	No	Yes
Secure DNS management	No	No	No	Yes
Directory Listings	Yes	No	No	Planned
Search engine placement	Yes	No	No	Planned
Business to Business listings	Yes	No	No	Planned
Domain Search	Legacy only	Legacy only	Legacy only	Universal
Reverse Lookup	No	No	No	Yes
DynamicDNS	No	No	No	Planned

4.3 Competitive capabilities/weaknesses

Name.Space has several key competitive capabilities:

Excellent Technical Staff

High level of system security

Secure email and encryption services

Excellent brands and domain names

Brand recognition and established reputation

Hi customer satisfaction

Relatively low operating expenses

Head start on new gTLD services

Prior publication of gTLDs and a client base of SLD holders.

Highly automated systems

Foresight

Imagination

Motivation

Persistence

Resillience

Key competitive disadvantages:

gTLDs published and operated by Name.Space are not recognized globally

Unreasonably high registry application fee is adverse to small businesses and non- profits.

ICANN may exclude smaller companies as TLD registries

ICANN may not approve any new gTLDs

NTIA may not accept ICANN’s recommendations for any new TLDs

Most investors and potential TLD sponsors who believe in Name.Space

were unwilling to risk $50,000.00 to ICANN because of uncertainties about whether ICANN will approve any TLDs at all, or any significant

number of TLDs to make a meaningful change to the marketplace. Those same potential funding sources also said that they would certainly invest in Name.Space if its published TLDs were globally recognized, and considered it otherwise a worthwhile investment. The key competitive disadvantage here is that the TLDs published and operated by Name.Space are not recognized globally, and not enough numbers are using Name.Space DNS to make it marketable to mainistream users in the short run.

5. BRIEF FINANCIAL STATUS

Ownership: 63% CEO Paul Garrin

35% private investors

2% pgMedia, Inc

The primary sources of revenues are domain name registrations in both legacy and new gTLDs, plus web hosting and email services.

6. Human reSources

Staff requirements are fulfilled by outside contractors, under strict non-disclosure agreements, usually working under extended contract or consulting basis. There are three full and part time contractors working on extended basis in the areas of systems security and configurations, software development, web design and business services. Paul Garrin conducts general operations and management.

Paul Garrin, who continues as CEO, founded the company in 1996. Paul has a wide range of hands-on experience in art and technology that spans 20 years and includes his work in video art, experimental advanced television and computer animation, interactive systems, robotics and internet. His unconventional mix of knowledge and experience in media, communications and technology led to the creation of Name.Space, and the establishment of a model service for the DNS industry. Paul holds a Bachelor of Fine Arts from Cooper Union; Awards include NY State Council for the Arts, NY Foundation for the Arts, ZKM Media Arts Prize, Ars Electronica Prize, and others. Paul's work has been published worldwide, and he has lectured internationally on media art and Internet in both academic and non-academic forums. Media Art installations by Paul Garrin have been exhibited internationally including Holly Solomon Gallery, Sao Paulo Biennale, Lyon Biennale, Musee d'Art Contemporaine du Montreal, Kwangju Biennale, Faurschou Gallery, and others. Paul is a member of CPSR (Computer Professionals for Social Responsibility) and serves as a member of the CPSR working groups on Privacy and Domain Name Policy. He also is a member of the ICANN Domain Name Supporting Organization (DNSO) and its Working Group C dealing with issues of new generic top level domains.

Billy Donahue is presently a contractor whom the company seeks to hire full-time as Chief of Software Engineering. Billy holds Bachelor and Master's degrees in Electrical Engineering from The Cooper Union. He has worked at Lucent Technologies writing DSP firmware code for cellular base station equipment. He is also an experienced web developer. He commands a mastery of a wide variety of programming idioms including Assembly, C, C++, Perl, and Java as well as SQL, Postgres, and other database technologies. He specializes in UNIX based computing, particularly Linux. He is a member of the New York Linux User's Group and has contributed to the development of the Linux kernel.

6.1 Recruitment and training of new staff

The Name.Space Production Center on East 4th Street in Manhattan has sufficient space to expand staff for the foreseeable and expected demand. In the event that additional staff is needed, Name.Space may consider outsourcing, depending on the service required, or hiring additional staff and acquiring sufficient space to support them in the event staff requirements exceed present facilities.

In-house technical staff and management will train new employees on the job.

New employees will be screened according to their capabilities and will be required to have proficiency in their field at the time of hiring. Name.Space will provide an internship program for students to engage in on the job training with our staff. Name.Space seeks to form community partnerships with public schools and non-profit community and cultural organizations and plans to initiate a community service program to raise awareness about computers and technology for communities and cultural use, and to bridge the digital divide.

7. Strategic Alliances

Name.Space is strategically aligned with INW technologies, a provider of hardware and networking solutions, and LokMail, Inc., a provider of secure web and email services. INW and LokMail, Inc. are critical partners in security services and network and server infrastructure for Name.Space, Inc. Name.Space owns an equity interest in LokMail.

Name.Space has entered into a strategic marketing agreement with Netnamelicensing.com (http://netnamelicensing.com) to develop business relationships with companies who wish to license the Name.Space brand and technology to provide domain name registration, web hosting and email services in local languages. In addition, Netnamelicensing offers a value-added service of licensing domain names to merchandisers who wish to produce and sell products that feature domain names.

Name.Space seeks alliances with ISPs and resellers of domain names to increase its market share. There are presently several small affiliates who are buying, reselling, or promoting Name.Space services. The company intends to increase the number and quality of affiliates, especially affiliates who serve local clients in various languages.

8. capital requirements

Name.Space will require 150,000 between now and the end of year 2000 to ramp up our operations to and to begin to accommodate resellers. Name.Space has the for those funds by our standing investors once the new gTLDs are recognized globally. Name.Space believes that revenues from sales will be strong enough in the next quarter to minimize the need to borrow any additional capital. It is possible that during that time Name.Space may enter into negotiations with other investors, but that has not been determined at this time. Name.Space is highly confident that it can raise sufficient capital once its gTLDs are activated globally. Since Name.Space already has the bulk of its capabilities online now, there is little need for an immediate investment to bring its already operational service to market. The present capabilities in place today can support the expected demand

in the next quarter without the need for any substantial upgrades or new system software.

That next quarter is likely to be very profitable once the new gTLDs are globally recognized.

8. registry failure contingency

In the event of total or catastrophic failure of our New York City production center, the functioning of the DNS resolution top-level domains for which Name.Space is responsible will be unaffected due to geographically diverse redundant TLD servers. Whois and registry services can be restored within 48 hours through activation of an auxilliary production facility. Through colocation agreements at another facility, Name.Space will maintain one or more "clones" of its registry services to assure uninterrupted operation of mission-critical registry/registrar and whois functions.

This mirror of our registry engine server will be securely synchronized via the SINDI protocol developed by Name.Space. This deployment gives us "hot-swap" capabilities, and load balancing our operations, as well as insuring uninterrupted service in the event of any service interruptions at either site. The ultimate goal is a zero-down time hot-swap by redirecting traffic to a backup colocated system.

90% Confidence Level.

50% Confidence Level

10% Confidence Level

D13.3.) Pro-forma financial projections.

SEE ATTATCHED PRO-FORMA FINANCIAL PROJECTIONS

D13.4.) Supporting documentation

SEE ATTATCHED SUPPORTING DOCUMENTATION

INCLUDING CERTIFICATE OF INCORPORATION,

PROOF OF INSURANCE CERTIFICATE

ANNUAL REPORT

TRADE REFERENCES

D14.)

III Technical Capabilities And Plan

D15

D15.1. Detailed description of the registry operator's technical

capabilities.

D15.2. Technical plan for the proposed registry operations.

D15.2.1. General description of proposed facilities and systems.

The Name.Space registry is hosted primarily at the New York facility in lower Manhattan. This is a 3300 square foot unit in a private commercial building with a security guard on duty 24-hours a day and 24 hour audio and video surveillance in the building entrances, public hallway and elevator. In addition, Name.Space has its own independent audio and visual surveillance installed in its facility. No other companies or individuals have access to the floor where Name.Space is located, Name.Space is the sole occupant of its space.

The registry runs on one or more FreeBSD systems on high-end server computers. The New York facility is connected to two full T1 lines connected through an adaptive BGP router configuration to two independent upstream providers: Intermedia-Digex and @Work. A redundant auxilliary registry at a remote location is also planned as a 'fallover' server and load-balancing solution, to be located at a large scale colocation facility. Name.Space is considering colocations with Exodus Communications and Alabanza.

Fig. 1 shows the Network at the New York facility.

Each block is explained:

o two dedicated firewalls serve, manage, and monitor the T1 connections to '@Work' and 'Digex', publishing BGP routes to the respective upstream provider. These are FreeBSD systems running GateD, BGPd, and IPFW.

o an 'internal firewall' shapes outgoing traffic along the two uplinks and serves as a firewall, allowing access to and among the internal subnets as appropriate. This is a FreeBSD system running GateD and IPFW.

o One or more 'registry servers' serve as the front end for registry and registrar functions. This includes interfaces to register new domains as well as to modify existing DNS records in registered second level domains over the web via an encrypted SSL connection. These are FreeBSD systems.

o The 'DNS' server is a separate dedicated machine running FreeBSD and BIND.

o The 'registry db server' is responsible for the registry and accounting databases.

o The 'credit' server is a Mac which stores encrypted credit card numbers provided by the registry server. It runs supervised 'batch jobs' to authenticate and charge the cards using a telephone callout line to the credit provider. The decryption is performed 'manually' by an operator. The decryption key is not stored on any computer accessable by the internet.

o The 'workstations' block includes employee workstations and network monitoring stations, as well as test versions of the webservers and database server, and support systems for Name.Space's internal services such as filesharing, printers, and mail service.

o The 'client webhosting/mail' block represents one or more machines providing value-add service to domain registrants.

o The 'emergency dialin' server listens for calls on a plain telephone line and authenticates only the administrator. This is for emergency administrative access only, and is 'locked down'.

Name.Space has a globally diverse network of colocated DNS servers which help to mitigate the DNS traffic to the New York facility and to provide fallover redundancy for the top-level DNS. This DNS server network consists of five additional nameservers Co-located at facilities in San Jose, California (described below), New York (redundant T1s), and Amsterdam (2Mbps connection), with volunteer servers operating in Stockholm (10Mbps connection), Riga (2Mbps connection), Amsterdam and Ljubljana. Present server locations are publicly accessible at <http://name-space.com/admin>.

The San Jose Verio-Best.com colocation facility is a dedicated Sun Sparc-10 located in a secure bank building. There is no physical access to this machine with the exception of our authorized site engineer who responds to any emergency. It should be noted that there has been no emergency access calls to that server since 1998. It is locked in an individual steel cage within the facility and is connected via a 10Mbs local ethernet to a DS-3 link to the Verio-Best.com network access facility in Mountain View, CA with multiple DS-3 peers with upstream providers. The facility has a diesel backup generator capable of providing power for weeks in the event of a power grid failure.

D15.2.2. Registry-registrar model and protocol.

Name.Space will provide registrars with the capability to interface to the registry servers with secure connections. Registrars will post and retrieve updates to the registry, and will be able to make queries. Each registrar holds its own whois information, and will be held responsible for maintaining an accurate whois database available on port 43 of its whois server.

All communications with registrars will be encrypted. A registrar will open a TCP connection to the registry server on a reserved port and send short command packets to the Name.Space registry. The packets will be signed and encrypted by the registrar using a public key cryptosystem (Name.Space will provide a mechanism by which a registrar's public key may be generated and securely submitted during the registrar's sign-on process). The registry's responses will likewise be encrypted to the public key of the registrar, and signed with the Name.Space registry's private key.

All registrars will be registered with the Name.Space registry before they can perform second level domain registrations. Each registrar will be given unique identifier called a `registrar handle' upon signing up with Name.Space.

The registry really needs to store only a few fields of

information for each second level domain registered. These are:

o name of the domain

o registrar responsible for the domain

o expiration date of the domain registration

o two or more authoritative registered nameservers for the domain

The registrar may perform only a small number of possible

operations. The operational protocol with the registry will

therefore be somewhat simple. A transaction may be completed by

success, by failure, or by a timeout.

Registering a domain requires that it be temporarily locked.

The lock ensures exclusive access. Every lock has a `lockid',

a large random value which must be used by the lock's owner

to remove the lock and atomically perform an `add' operation.

An `add' operation will fail unless the correct `lockid' is used.

Following are registrar operations with descriptions of how

they are implemented in the protocol. words in lowercase are

variables explained in the comments. The operation consists of

an operation name followed by a space-separated list of possible

arguments, followed by a newline (<CRLF>) sequence, as in:

operation arg1 arg2 ... argn<CRLF>

The response consists of an acknowledgement line of the form:

OK<CRLF>

or an error indicator with an errorcode and possible parameters.

ERR errcode param1 param2 ... paramn<CRLF>

The possible registrar operations are:

o LOCK a domain temporarily.

This reserves a domain for the duration of a registration

process. Typically, a domain is registered by an end user

who searches the `whois' database until an available name

is found. The user then fills out a form (usually on the

web) and submits it to the registrar. The `lock' operation

reserves a name for long enough to give the potential

registrant a chance to fill out the form without the domain

being snatched up while he is doing so. A lock will have

a time-to-live of 30 minutes, which should be enough time

to fill out the registration forms. The server responds

with a `lockid', which must be sent with the `add request'

finally added. The `lockid' is intended to help registrars

(who may have many simultaneous users and primitive

registration scripts) to avoid locking a domain and then

giving it to the wrong user.

The command format is:

LOCK domain

Possible errorcodes are:

`LOCKED' if the domain was already locked.

`NOTAVAILABLE' if the domain was already registered.

o ADD a domain

This command actually adds a new domain to the TLD. The domain

must be locked, and the lockid of the lock on the domain

must be used in this command. Adding the domain removes

the lock. At least 2 nameservers must be listed. The ADD

command takes a duration (in years) for the registration.

The ADD command will fail if any of the listed nameservers

are not hosts registered with the internic.

The ADD command will fail if any of the listed nameservers

are not forward and inverse mapped to the information

listed in the internic whois listing for the nameserver.

The ADD command will fail if any of the listed nameservers

are not forward AND inverse mapped to the name and

IP address listed in the internic whois entry for the

nameserver.

The ADD command will fail if any of the listed

nameservers is not carrying a record for the domain.

Name.Space policy is to refuse `lame' delegations.

The command format is:

ADD domain lockid duration ns1 ns2 [ns3] [ns4]

Possible errorcodes are:

`NAMESERVER ns' if there was a problem with nameserver `ns'.

`NOTLOCKED' if the domain was not locked by the supplied `lockid'.

o MODIFY a domain

Only the responsible registrar for a domain may modify

a domain. The modify request may change any attribute

of the domain. The information provided in the argument

list of this command completely overwrite the attributes of

the domain. This can be used to transfer a domain between

registrars, or to change or add nameservers for a domain.

The same restrictions apply regarding nameservers apply

to modifying a domain as to adding a domain (see above).

The command takes a `registrar' handle as an argument.

This must be a registrar handles in Name.Space's registrar

list. If the supplied registrar handle is not the domain's

current responsible registrar, then this command can effect

a domain transfer.

The command format is:

MODIFY domain registrar ns1 ns2 [ns3] [ns4]

Possible errorcodes are:

`NAMESERVER ns' if there was a problem with nameserver `ns'.

o RENEW a domain

The RENEW command adds `duration' years to the lifetime of

a domain's registration. Only the responsible registrar

for a domain may renew a domain.

RENEW domain duration

The command always succeeds.

o DELETE a domain:

Only responsible registrar for a domain may remove a domain

from the registry.

The command format is:

DELETE domain

The command always succeeds.

D15.2.3. Database capabilities.

Name.Space anticipates a large initial demand in new globally accessible TLDs. Possibly up to 1 million entries in the first month. This corresponds to an average sustained rate of 1 new entry every 2.6 seconds. Even Name.Space's current registry system which uses perl scripts and flat files can perform 100 registrations per minute, or one entry every 0.6 seconds. The current implementation is 4.3 times faster than it needs to

be to handle even such an extreme load. It is not difficult to imagine that an efficient database driven implementation of the registry would be even faster several times over.

Factors such as nameserver lookups and external whois checks for the registration process would be the bottleneck in such a registration blitz, not the database throughput.

The registry database does not really have to hold much data at all, as databases go. Several Gigabytes should be more than enough room for any database which handles so little customer information. The registrar side of the database is responsible for the whois information, and so has a heavier load. However, even this amount of data is somewhat negligible. If a single domain entry takes up 1kilobyte, then 1 million of them would

take up 1gigabyte. This is hardly a challenge for today's storage hardware.

The database planned will use PostgreSQL. It is a high performance object-relational open source database management system. It will be addressed from the registry servers using the PerlDBI interface and possibly other methods as appropriate.

Name.Space will be operating both as registry and as registrar, and other companies will be allowed to act as registrars. Name.Space registry database will be separated from the

in-house registrar database. The registrar database will contain whois information, customer data, and customer billing information. The registry database will contain information on all registrars, records for the registered domains, and registrar billing information.

D15.2.4. Zone file generation.

There are two classes of zone files. The TLD zone files are generated by the registry software. The SLD zone files are generated by the registrar software. Registrars are responsible for generating their own SLD zone files for their clients. Name.Space will be acting as both are registry and a registrar, and so will have to support both types of zone file generation. However, they will be generated by completely separate processes and possibly even on separate machines. It is Name.Space's intention to keep its registry and registrar processes clearly separated as a matter of design.

TLD zone files will be generated in realtime on an as-needed basis directly from the registry database. The registry software will keep a `scoreboard' of new and deleted SLDs in the TLD, and any nameserver delegation changes. If the scoreboard can be merged into the current zone file without a complete recompilation, then that is what will happen, to prevent unneccessarily loading the registry database. The TLD zone files may be completely recompiled as a low-frequency event (possibly twice a day), just as an added measure of reliability. This process is already a part of Name.Space's running registry system.

SLD zone files will be generated on an as-needed basis. The registrar software will maintain `a scoreboard' of changes within an SLD. Every few minutes, a batch job will regenerate the zone files for those SLDs marked as changed, and then reset the scoreboard. This process is already a part of Name.Space's running registrar system.

The Registry software will be responsible for interfacing with registrars on an assigned registry IP port. It will implement the LOCK, ADD, MODIFY, RENEW, and DELETE commands from registrars (including the Name.Space registrar) and make the appropriate calls to the database manipulation routines which implement those changes. Another component of the registry software will periodically regenerate TLD zone files. Every communication with a registrar is encrypted as per the protocol (see above), and basic validity checks will be performed on the requested operations. Registry and registrar administrators will be alerted of errant attempted operations.

The Registrar software will be responsible for interfacing with the Name.Space registry on the assigned registry IP port. It will provide an interface to web users who wish to register new domains under the Name.Space TLDs. Name.Space right now has a very capable system for client domain administration. Registrants can securely log in to name-space.com and add, modify, and delete resource records in the zone for their domain. These resource records are actually going to be stored in the registrar database in the coming implementation, and the modified domain will be marked `dirty'. A periodic batch job will regenerate zone files for each `dirty' SLD in the database, marking them clean again.

D15.2.5. Zone file distribution and publication.

Name.Space currently has a globally diverse network of five nameservers running its root-zone and top level domain zones. New top and second level domains are mirrored to these servers by means of a periodic batch job running on each server. The batch job uses the `rsync' mirroring tool over `ssh', a secure remote access utility. Updated BIND configuration files are periodically generated at the master server, and the remote nameservers are programmed to periodically retrieve these updates and to reload their BIND processes. New second level domains and even new toplevel domains have been smoothly added to the Name.Space global nameserver system for years without a hitch. Updates to existing zones are being performed by BIND's built in `notify' feature.

D15.2.6. Billing and collection systems.

As a registry with four years of business experience, Name.Space has developed a very reliable and functional automatic billing system. The registrar function of the proposed Name.Space system would be modeled on the existing billing and collection system.

A periodic batch job runs every 2 days and checks for domains which are in danger of expiration A bill is emailed to a client's billing contact when the domain is within 2 months of expiration. Repeated reminders are emailed by the batch job over the next months until the domain is renewed. If the domain is not renewed, it is placed 'on hold', and a `TXT'(text) record reading `(on hold)' replaces the `A' (address) records for the domain in its zone file. This technique effectively temporarily deactivates resolution of the domain. If the billing contact does not step forward to renew in the next 90 days after the expiration, the domain is freed and becomes available for registration again.

Credit card payments are received by a secure web form. Card numbers are collected by the web server, encrypted, and then stored in encrypted form on the Macintosh `credit card server' (See network diagram). The credit card server runs supervised 'batch jobs' to authenticate and charge the cards using a telephone (POTS) callout line to the credit provider. The decryption is performed 'manually' by an operator. The decryption key is not permanently stored on any computer. The results of the authentications are sent back to webserver and client's domains are renewed and/or registrations are tagged permanent if the payments were accepted. In any case, the client is notified by email whether the card was accepted or rejected.

D15.2.7. Data escrow and backup.

Name.Space will develop partnerships with other Internet service providers in New York City. We may set up an `escrow swap' with one of our neighbors, whereby we hold a backup of their systems, and they hold a backup of ours. If need be, Name.Space could simply contract a provider for the backup escrow service. Name.Space's data security policy would require that these backups be encrypted. Name.Space's critical servers are on a 6 tape incremental backup cycle during the week, and a full backup is made once a week. This full backup is copied and encrypted and safely stored offsite. The backup registrar and registry data is also copied daily to a backup drive in a workstation for quicker recovery if the need arises.

Programs and scripts will be written and will be periodically executed to extract a `snapshot' the entire database into a text form and also to restore the text database image into a running registry. tools like `dbdump' are available which convert a snapshot into SQL statements, which can be further 'boiled down' into raw fields for archival purposes.

D15.2.8. Publicly accessible look up/Whois service.

Registrars will be responsible for providing whois information in a standardized format on the whois port (port 43) of their designated whois server. The Name.Space registry will answer whois queries on its own whois port by making queries to the registrar responsible for the domain and returning the result. If a domain is searched for which is locked for registration, a 'registration in progress' notice will be returned.

Registrants will always have the option of keeping personal information private, and having the whois return an email address for the contact information.

Name.Space has been working for years to try to improve the fragmented whois service in use on the internet today. the Name.Space `sWhois.net' server does the best that it can to follow present a coherent whois result across country code TLDs, as well as from the .com .org and .net registries, many of whom do not run any standard whois service. This difficult undertaking emphasizes Name.Space's committment to providing a reliable, interoperable, and robust whois service.

D15.2.9. System security.

The Name.Space production facility is in a keyed-access commercial unit with a 24-hour security guard. Additionally, the Name.Space lab is under constant video and audio surveillance, with alarms on every access point when the facility is not manned, which is a brief part of each day. Even when the lab is empty, an administrator can be onsite in minutes, and the network is under constant remote monitoring. Name.Space code and data never leaves the lab except for the encrypted backups. Name.Space has a strict data security policy which dictates that all employee work is performed onsite using the lab workstations. All company email is PGP encrypted.

All critical Name.Space servers are running intrusion detection software, and copy their system logs out to a secure dedicated loghost. The Name.Space LAN is running two layers of firewalls, the internal and the border firewalls. The internal firewall acts to segment the network and isolate possible breakins. The border firewalls help to protect the internal network by intercepting anomolous-packet based attacks, and maintain a `black hole' to drop packets from suspicious or hostile outside hosts.

D15.2.10. Peak capacities.

Today, the Name.Space registry has been benchmarked to be capable of 100 registrations per minute with existing infrastructure. In the event of larger-than-expected demand on Name.Space's registry, a short term solution would have to be implemented while the registry is upgraded. Name.Space is both a registry and a registrar. The registrar service consumes the bulk of the bandwidth and processing power and could quickly be replicated into a temporary offsite colocation on faster hardware and with better connectivity to fulfill an extreme short-term demand for new registrations.

D15.2.11.

Reliability. Two reliable net connections. Internal systems. FreeBSD systems with large disk arrays very stable over long periods.

D15.2.12.

Monitoring all critical critical servers with automated administrator notification and custom programs which monitor specific processes of our systems, system watchdog programs.

All critical servers have redundant AC power supplies connected to separate battery backups. All critical servers will be using hot swappable RAID-7 disk arrays to prevent data loss and allow seamless replacement in the event of hard disk failure. The facility is equipped with redundant network connections over two T1 lines running adaptive BGP routing.

In the event of a total power failure, Name.Space has a service contract with a 25MW capacity mobile mobile generator truck. The truck can be summoned within 30 minutes after notice, with guarantees to be onsite within 60 minutes.

maintain one or more "clones" of our registry services to assure uninterrupted operation of mission-critical registry/registrar and whois functions.

D15.2.13. System recovery procedures.

Daily backup tapes are and will continue to be made of the critical registry and registrar servers. The tapes are rotated on a 6 day cycle, with a 7th day being a weekly full backup, of which an additional encrypted copy is made for offsite physical storage. The servers are uniformly running FreeBSD, and the tape archive tool `tar' has never failed to deliver for our backup needs. The entire system does not need to be backed up.. The `steady-state' directories of the server are backed up onto read-only media, and all backups are made relative to the date of that backup. To restore the entire system to the most recent backup, an operator copies the read-only media onto the disk, and then restores the differential archive tape on top of that installation. This has been done for scheduled disk upgrades in the past, and can be done for system recovery as well.

The tape recovery option can be slow and laborious. The database is also regularly copied onto a backup hard drive on a certain lab workstation, and can be more quickly and reliably accessed over the network than from a tape. The `tar' utility can easily restore from an archive piped over a network, and this would probably be the preferred method of restoration if the need arose.

Description of TLD Policies

I. GENERAL TLD POLICIES

E1. In General

The Name.Space Charter

The toplevel global internet namespace is a global commons. With this charter, and in accordance with the People's Communication Charter a fair structure for Self Governance of the Global Internet Namespace is being established.

We believe that no single Government, Corporation, Organization, Group,

Individual or otherwise ought to make any exclusive claim to any individual zone in the toplevel and generic second.level or any other generic namespace

because exclusive noncompetitive ownership of such namespace harms the

public interest. Basic principles of fairness dictate that a generic namespace

should serve the greatest public good as a resource, not narrow commercials

interests as a trademark.

Names are registered on a first come, first served basis. The party requesting

registration of a name is responsible that, to her/his knowledge, the use of a given name does not violate trademark or other statutes.

Registering a domain name does not confer any legal rights to that name and any disputes between parties over the rights to use a particular name are to be settled between the contending parties using existing legal methods.

The generic toplevel namespace is in the public domain. Registries/registrars

managing the global toplevel namespace agree to enter into peering and

datasharing agreements insuring the smooth and transparent interoperability of global nameservice, and to further insure a stable and fault-tolerant infrastructure.

No one shall operate parallel namespaces in intranets, virtual private networks, etc. in any manner that interferes with the Global Internet Namespace. This includes, but is not limited to, operating conflicting, redundant or non-unique namespaces that conflict with established global addresses.

Private ownership and branding of generic toplevel domains is not appropriate on the global internet. Any such use shall solely exist in non-global, private intranets and virtual private nets. The right to express oneself in the creation of an internet.name is guaranteed by the the First Amendment to the US Constitution and the People's Communication Charter, and is highly encouraged.

The registration of a name to any group, organization, government, individual, or otherwise constitutes the good faith intent to expeditiously put the name into service as a functional and reliable internet address. Any such address must answer to an Internet active host. Mass registrations can be arranged for legitimate purposes only and not as a means of trademark hijacking, hoarding and speculation, or overreaching attempts at trademark protection. Legitimate purposes are registration and implementation of an internet namespace to identify an individual, idea, product, corporate identity, content, or otherwise. The registrant's right to a given namespace develops through use and practice in accordance with existing laws pertaining to global trade. "Use and practice" in this context means a namespace is put into active service as an accessible Internet site providing content and/or services.

All Registrants' rights to Privacy and Free Expression are guaranteed. All

Registries agree to respect Registrants' proprietary information and all information related to registrant's identity, address, and all other identifying and contact information confidential and private unless otherwise specified by the registrant. Information will not be disclosed to any Government, its agents, or to any individual without due process.

The Root.Zone, the "." (Dot) or Root Directory of the Global Internet Namespace is an "essential facility" as that term is defined in US jurisprudence. Therefore it is imperative that any toplevel namespace be included in the list of servers contained in the Root.Zone, or "." file in order for that toplevel namespace to be recognized globally by all Internet hosts. No proposed toplevel namespace shall be refused inclusion into the Root.Zone, or "." file as long as: (1) it will benefit and serve the public interest; and (2) it is managed in accordance with: (a) the applicable Responsible Practice Policies established between individual registries and networks; (b) the provisions set forth herein; (c) the People's Communication Charter; and (d) US laws.

Registries, whether for profit or non-profit, manage the Internet Global Toplevel Namespace in the public interest. This obligates them to provide highly reliable services at reasonable costs.

E2. TLD Strings

SHOP.

SPACE.

SEX.

ART.

ZONE.

MUSIC.

ONLINE.

CONSULTING.

DESIGN.

TRAVEL.

MEDIA.

NEWS.

DIRECT.

MAIL.

WORLD.

MAG.

AUCTION.

FREE.

CAM.

SERVICE.

FUN.

MAD.

PAGE.

GAMES.

GUIDE.

MARKET.

SPORTS.

CAFE.

BOOKS.

STUDIOS.

CITY.

SITE.

NOW.

CHANNEL.

CLUB.

SOFTWARE.

INSURANCE.

TECH.

COMMERCE.

CARS.

COMPUTERS.

LAB.

SOLUTIONS.

TRADE.

RADIO.

AIR.

TIME.

GRAPHICS.

FILM.

GROUP.

CARD.

FUNDS.

ADS.

ONE.

SCHOOL.

SHOW.

INDEX.

POWER.

SOUND.

SECURITY.

AGENCY.

HELP.

GALLERY.

SYSTEMS.

PRODUCTIONS.

AUDIO.

SHOES.

TOYS.

WATCH.

HOTEL.

DVD.

WAR.

PLANET.

NYC.

ZINE.

DIGITAL.

WEATHER.

STAR.

MOVIE.

THEATER.

FUND.

DTV.

RECORDS.

FILMS.

PEOPLE.

CULTURE.

CENTER.

BBS.

TIMES.

JOBS.

MEN.

WOMEN.

ARTISTS.

HISTORY.

SOCIETY.

WRITER.

FASHION.

AIDS.

FACTORY.

JAZZ.

SHAREWARE.

VOICE.

SOUP.

PROPERTIES.

PARTNERS.

PROJECTS.

POLITICS.

MONITOR.

FOUNDATION.

FICTION.

OPERA.

FESTIVAL.

SUCKS.

ANTIQUES.

GAY.

MAGIC.

CHURCH.

TEMPLE.

E3. Naming conventions

Registrations under the TLDs published and operated by Name.Space consist of second-level domains. Name.Space will support capabilities to reserve SLDs and provide third-level sub-domain registrations under reserved SLDs where appropriate or desirable.

E4. Registrars

Name.Space sees an opportunity in doing business with existing "legacy" domain registrars in a way similar to that in which they now interact with Network Solutions. As a wholesale (registry) provider of new gTLDs, Name.Space will form relationships with all interested existing ICANN accredited registrars to resell new gTLDs published and operated by Name.Space as they now do with NSI and "com" , "org" and "net" domains. In addition to the existing "legacy" domain registrars, Name.Space intends to develop a network of global affiliates, partners and resellers to provide services licensed under the Name.Space brand, as well as custom-branded services in which Name.Space provides the technology back-end capabilities under a customer’s brand. To facilitate this, Name.Space will provide secure, easy and low cost access to its registry system to encourage resellers to form partnerships with Name.Space. By making its complete capabilities available to its clients, Name.Space will reduce time to market and lower the barrier to entry by scaling its role as an "Applications Service Provider" to a "Solutions Provider" in accordance to client demand and budget. Name.Space will offer opportunities for resellers to license the Name.Space brand name and technology to provide Name.Space services in their local languages and or to their local communities at an affordable scale. Name.Space will also work with non-profit, community, and cultural groups to set up a domain name partnership to help fund access, training and resources and to bridge the digital divide. All registrars, resellers and licencees of the Name.Space brand and or technology, and all registrars and resellers who deal with Name.Space Registry will be bound by the policies and contracts set forth by Name.Space with respect to the TLDs that it publishes and operates.

E5. Intellectual Property Provisions

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

The agreement between Name.Space and its clients states:

Names are registered on a first come, first served basis. The party requesting

registration of a name is responsible that, to her/his knowledge, the use of a given

name does not violate trademark or other statutes.

Name.Space does not assume responsibility or liability for any unforseen acts of bad faith on behalf of registrants nor does it assume the role of determining intellectual property rights.

E5.2. If you are proposing pre-screening for potentially infringing registrations, how will the pre-screening be performed?

Famous and well established and recognized trademarks will be checked against all registrations by an automated process that rates the "safety" level of a name before it is registered, with a warning issued to the potential registrant before the application process begins. If the registrant proceeds with a "hot" rated registration, it will then be flagged for manual review and subject to a holding period and possible rejection if proof of rights to use a famous trademark are not produced.

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

Name.Space seeks to minimize the speculative registration of domains by parties whose only purpose is to resell the domain. This practice has led to bad faith registrations and countless disputes. By mandating use of the domain within a reasonable period and forbidding the registration of a domain for the sole purpose of resale, bad faith registrations and cybersquatting can be reduced to a minimum. Remove the incentive to speculate, reduce the potential for abuse. Any unlawful or criminal activities will be reported to proper authorities and further business with abusive individuals will be curtailed.

E5.4. What measures do you propose to comply with applicable trademark and anti-cybersquatting legislation?

It is not the business of the TLD registry to enforce statutes regarding cybersquatting legislation and trademark laws. The registry will however respect any court order with regard to the disposition of a domain name ruled to be in violation of statutes.

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

Name.Space has a famous names policy in effect and intends to continue it beyond the startup period. Name.Space has already revoked several obviously infringing registrations such as "amazon.books" and "nbc.sports" among others.

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

Name.Space provides all of its customers of new TLDs a secure, SSL encrypted web based account administration which enables the client to manage all aspects of her account including modifications and updates to their contact information. Whois updates are performed in real time and are instantly reflected when a new search is performed with sWhois. Name.Space maintains a free publicly accessable sWhois search engine via the web at http://swhois.net and http://dns411.com where domain and IP contact data can be searched. A standard port 43 command line sWhois access is also provided free to the public.

E6. Dispute Resolution

Describe the policies for domain name and other dispute resolution. If you are proposing variations to the policies followed in .com, .net, and .org, consider the following questions:

E6.1. To what extent are you proposing to implement the Uniform Dispute Resolution Policy?

Name.Space does not intend to implement the UDRP for the new gTLDs that it publishes and operates.

E6.2. Please describe any additional, alternative, or supplemental dispute resolution procedures you are proposing.

Names are registered on a first come, first served basis. The party requesting

registration of a name is responsible that, to her/his knowledge, the use of a given

name does not violate trademark or other statutes.

Registering a domain name does not confer any legal rights to that name and any

disputes between parties over the rights to use a particular name are to be

settled between the contending parties using existing legal methods.

E7. Data Privacy, Escrow, and Whois. Describe the proposed policies on data privacy, escrow and Whois service.

All information submitted during the course of transactions with Name.Space is

considered confidential unless agreed to otherwise in advance by persons submitting their data.

Only information required for proper technical functioning of the DNS will be made

publicly available unless otherwise agreed to by registrant. Said publicly available data will be freely available through sWhois searches from http://swhois.net, http://dns411.com and

from command line queries made to swhois.net via standard port 43.

Registrants may choose not to have their domain names listed in any public

directories.

The Name.Space database is not for sale to any third parties.

No private information in the Name.Space database will be disclosed to any third parties,

including law enforcement, without due legal process.

Name.Space does not use cookies or other means to track your net usage beyond its site.

Accesses to Name.Space servers are logged and all transactions are logged for internal

security and systems performance reasons, and for internal sales performance ratings, and to assess traffic demands and trends, for internal use only. Specific information contained in our log files are never disclosed to any third parties.

Registrants are encouraged to use encryption when sending email, and to register their public key with us when registering thier domian name. This is to authenticate and verify a registrant's identity related to their domain, to protect against unauthorized modifications to the domain, or hijacking. Information related to registrant and public key are kept confidential unless otherwise requested by registrant.

Any and all data that is escrowed will be stored in encrypted form. Only information required for the proper technical functioning of the DNS will be stored "in the clear".

All private information pertaining to customers and their accounts will be kept encrypted and confidential, including when said data is stored with a third-party escrow agent.

E8. Billing and Collection. Describe variations in or additions to the policies for billing and collection.

All domain name registrations must be paid in advance online at the time of registration.

Notifications for renewal of a domain’s term will be sent electronically via email starting

at 30 days prior to the expiration of the term. Provisions are made for secure online payments to client’s account via an encrypted SSL web interface. In the event the client does not renew her domain by the expiration date, the domain will be placed on hold for up to 90 days to allow the client first right of refusal to renew the domain before it is released. Domains not claimed or renewed by the 90th day on hold are automatically released back into the available pool of names.

E9. Services and Pricing. What registration services do you propose to establish charges for and, for each such service, how much do you propose to charge?

Name.Space will provide wholesale and retail registration services in the new gTLDs that it publishes and operates.

The standard retail price for a domain name and DNS services for the domain is $30 per year. If a client chooses to provide their own (or their ISPs) DNS services, the price for a registration is $25 per year.

The standard wholesale price for a domain name to registrar/resellers is $6 per year. This requires the registrar to operate their own facilities.

Wholesale price for smaller-scale resellers who buy directly through the Name.Space system, after establishing a wholesaler relationship and account, will pay a graduated scale, based on volume, from $8.50 per year to $12 per year. Those prices include basic DNS resolution services for the domain in the event that no external DNS is established with an ISP.

II. REGISTRATION POLICIES DURING THE START-UP PERIOD

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?

There need not be any special measures taken at the initial opening of gTLD registrations. The "rush" is more likely to happen if only a small number of TLDs are recognized in the first instance. The best way to minimize a "rush" is to recognize a large number of gTLDs

to allow more choices to more people. Name.Space will only allow one registration at a time and will not support "bulk" registrations, and has no plans to do so. Regardless of how many registrations the Name.Space Registry receives in the first days, weeks, and quarter, the demand is not expected to exceed the system capacity described in the "Technical Capabilities and Plan" secrion of this application.

Name.Space seeks to minimize the speculative registration of domains by parties whose only purpose is to resell the domain. This practice has led to bad faith registrations and countless disputes. By mandating use of the domain within a reasonable period and forbidding the registration of a domain for the sole purpose of resale, bad faith registrations and cybersquatting can be reduced to a minimum. Remove the incentive to speculate, reduce the potential for abuse. These conditions will be included in the domain registration agreement and applies to registrars and registrants alike.

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?

Name.Space has already provided advanced registrations for many "famous" brands and entities over the past two years in a series of special promotions. Name.Space will continue to screen registrations for possible abusive registrations of famous brands in the way that it has already done in the past. Because of this ongoing policy, there is no need for a special "sunrise" period to give advantage to existing domain holders and those with famous trademarks.

IV. CONTEXT OF THE TLD WITHIN THE DNS

A Top Level Domain on its own is meaningless by default, and may acquire its meaning only through use and context. Because of the global nature of the internet and the fact that the internet and the DNS serves many different languages and cultures, it would be nearly impossible to find a total "one definition fits all" for any TLD. For example, the word "gift" in English has a special meaning, that of a "present" that one exchanges on special occasions, etc. In German, that same word "gift" means "poison". To impose a set meaning on a TLD with respect to one language and culture and not another would be short sighted and not in tune with the global and trans-cultural nature of the internet.

A divserse set of gTLDs that are flexible and expressive in meaning according to their use and context is an excellent way to maximize the potential uses of a domain to serve transculturally for commercial as well as cultural and non-commercial interests.

V. VALUE OF PROPOSAL AS A PROOF OF CONCEPT

Name.Space believes that new gTLDs are beyond proof of concept. Name.Space has spent the past four years publishing new gTLDs in accordance to market demand, and providing continuous registry operations for new gTLDs.

Name.Space has proven that it is possible to operate registry services for hundreds of gTLDs with over four years of continuous operations, and that it can be done efficiently and with a high degree of automation.

Name.Space has demonstrated its unification of the disparate global whois databases with its registry/registrar aware sWhois Universal Domain Search engine. http://swhois.net.

Name.Space believes that the public is ready and the market is ripe for new gTLDs. Its first hand experience as a new gTLD registry/registrar yields hard data and statistics gathered over four years as publisher and operator of new gTLDs showing strong demand and creative applications for new and expressive gTLDs.

Beyond this proposal, Name.Space has running code and an established client base. Its customers have shown their desire to publish their domains and to use them for legitimate purposes, to publish their content online.

Many of the registrations seem obvious at first glance, generic terms combined with the new TLDs. Some of these may even be speculative, in search of inflating their values in the "aftermarket". But hopefully, those are the minority, and Name.Space seeks to minimize the speculative registration of domains by parties whose only purpose is to resell the domain. Behind a lot of registrations are creative individuals seeking opportunities to try something new in building communities around their domains and in creating new business opportunities, one of them being "niche portals".

Just looking at some of the more creative and descriptive examples of registrations that connect to active web sites says it loud and clear that the public is ready for new gTLDs and have already discovered what they would like to do with them: