I. SPONSORING ORGANIZATION STRUCTURE

C1. The Nature of the Sponsoring Organization

General

The biz Regulatory and Advisory Council, hereinafter “bizTRAC”, is a non-profit LLC formed under the laws of the state of New York.

This application is for a number of possible TLD designations. For the sake of simplicity, “.biz” shall hereinafter designate the TLD which will be granted.

The purpose of bizTRAC is to provide a regulatory and advisory body where the unique concerns and opinions of the stakeholders of the biz TLD can be translated into policy to support .biz as a TLD for operating businesses.

C1.1 Board of Directors

The Board of Directors will consist of 15 to 31 members. The Board shall follow guidelines encouraging representation by the major constituencies served including at least: two Board members from groups representing trademark and intellectual property organizations, two members from Chambers of Commerce, two representing Better Business Bureaus (or other self-regulated bodies), two representing consumer protection groups, two representing Business and trade associations, and two representing Registrars. The Board will moreover examine other constituent bodies that should be represented. Efforts will be made to nominate Board members to represent geographic diversity.

The Board of Directors is currently in formation. The following individuals have agreed to serve:

Name	Position and Comp Affiliation	Community

Mr. Philip Berent	Head TLD Management Group, Affinity.com	Registry Operator
Mr. Joshua Kyle	Head of Operations TLD Management Group, Affinity.com	Registry Operator
Ms. Manon Ress	7Ways.com	Registry Operator
Mr. Tony Keyes	CEO, Bulkregister.com	Registrar
Mr. Gordon Freedman	Principal, Freedman and Associates	Intellectual Property
Mr. Keith Palzer	Director, Merrill Lynch	Business Community

Resumes or biographical notes for these members are attached below.

We have also received expressions of interest and are currently in discussions with Mr. Nigel Hickson, Head of E-business for the Confederation of British Industry, and Monsieur Chauvin, of the Company Affairs Department of the Union of Industrial Employers Confederation of Europe.

Initially, the Chairman of the Board will be Mr. Berent, who will be Head of the TLD Management Group at Affinity.com, the Registry Operator. When the Initial Board Membership is filled however, Mr. Berent will step down from this position and a new member will serve, where this member will be selected from any constituency other than the Registry Operator.

Directors shall serve as individuals who have the duty to act in what they reasonably believe are the best interests of the Corporation, and not as representatives of any subordinate entity they are affiliated with, their employers or any other organizations or constituencies.

During a start-up phase, which will last from six to twelve months, the initial Board will consist of members whose duty is to oversee the decisions of bizTRAC, as well as nominate other Board members in line with the guidelines stated above. The term of service for Directors will be three years; however, initial Board appointees will have staggered terms of service of between one and three years to ensure continuity. In its formation and initial phases, normal quorum requirements for the Board will be amended to provide for at least 2/3rds decisions of existing eligible Board members to be binding on bizTRAC, even if the number of Board members in total constitutes less than a quorum of the ultimate size of the intended Board.

C1.2 Advisory Board and Working Groups

bizTRAC will also establish an Advisory Board to expand input from the stakeholders of the biz TLD. Again, efforts will be made to support geographic diversity of Advisory Board members, as well as appointing members from all constituent groups. Advisory Board members may, from time to time, be nominated to serve on the Board of Directors.

Special Working Groups may, from time to time, be created by the Board of Directors to study certain complex issues. These groups may contain Board members, Advisory Board members, or others from the TLD constituency. These working groups would return to the Board with reports and recommendations for actions.

C1.3 Day-to-Day Management

The functions of day-to-day management of bizTRAC will include, but not be limited to the following:

scheduling and organization of meetings;
recording and distribution of minutes;
creating and maintaining informational bizTRAC web site;
accounting and bookkeeping;
other administrative duties.

C1.4 Staffing

Initial staff will be one Senior Administrator and one Secretary. Programming of the website and other tasks, where necessary, will be outsourced. The actions of staff will be overseen by the Board of Directors pursuant to its bylaws.

C1.5 Other

Other provisions of the by-laws will be addressed below in the sections as specified by the Sponsoring Organization’s proposal Application form.

C2. Organization

The sponsoring organization is a Limited Liability Company formed under the laws of the state of New York as a Limited Liability Corporation under the name, “biz Regulatory and Advisory Council LLC”, hereinafter “bizTRAC”. The Corporation will make application for non-profit business enterprise status.

The Corporation will have its offices and headquarters in the state of New York and will carry on business in the city of New York. The initial office will be located at:

bizTRAC

181 Hudson Street, Suite 7c

New York, NY, 10013

C3. Organization Structure

The sponsoring organization shall initially consist of the following:

A Board of Directors that includes Mr. Phil Berent, Mr. Joshua Kyle, Ms. Manon Ress, Mr. Tony Keyes, Mr. Gordon Freedman, and Mr. Keith Palzer.

Executive and support staff will be retained as is directed by the Board of Directors.

It is understood that while the fundamental structure of the Corporation will not change significantly, the Corporation will add staff at various levels as required to respond to demands for its services or as instructed by the Board of Directors.

It is anticipated that there will be other contributing organizations, affiliates or membership categories that will be participating in this enterprise in the future to be determined by the Board of Directors.

C4. Organization Purpose

Purpose of bizTRAC

C4.1 Purpose and rationale for .biz restricted TLD

The original intent of the .com TLD was to provide equal access (on a first-come, first-served basis) to domain names that would be accessible to commercial enterprises of all kinds. It was recognized that for-profit business could reap significant benefits on the Internet and that there should be a simple, clear mechanism for such users to obtain domain names. It was likewise recognized that commercial activity over the Internet provided a valuable service to Internet users at large. Unfortunately, this intent was corrupted by cyber-hoarders who appropriated, at minimal cost, valuable Internet addresses without the intention of using them to engage in an operating business enterprise. In so doing, they hijacked cyber real estate, squeezing out the original intended beneficiaries or ransoming the sites for sale to the highest bidders. Only a small percentage of existing SLDs point to active websites.

All manner of cyber real estate was seized by these cyber hoarders. By way of concrete illustration, if an entrepreneur wanted to sell dog food over the Internet:

Dogfood.com, dog-food.com, dogchow.com, dogschow.com, doggiefood.com, feedmydog.com, healthyhound.com, puppytail.com, mansbestfriend.com and numerous extremely similar other sites have been claimed, yet not one site on this list has an active web site.

Concrete examples of these practices is evident in the recent sales by speculators of the wines.com site for three million dollars, and the business.com website for seven and a half million dollars. These price inflations caused by speculators present a real and substantial problem for innovative entrepreneurs as well as operating businesses.

The restricted TLD we propose will provide an attractive alternative for enterprises actively engaged in, or seeking to engage in business. Any business entity, from small businesses such as sole proprietorships and partnerships, through to the largest private and publicly traded Corporations, will be able to apply for a “biz” domain upon meeting certain objective criteria.

We foresee that availability of appropriate SLDs at the biz TLD will deflate speculation in SLDs in all domains and in the .com TLD in particular. Further, reliable (in the sense of matching name to service) and sensible SLD naming will contribute to a more stable environment for commerce within the biz TLD.

Our policies, as specified in the accompanying Description of TLD Polices, have the objective of determining which are active business interests, defeating cyber-hoarders and cyber-squatters. In summary, these policies are as follows:

An applicant seeking a .biz SLD will have to show (1) the applicant enterprise meeting simple accounting and business criteria, such as a particular level of revenue or expenditure, or a certain level of available funds; (2) the requested name would not infringe on existing applicable trademarks.

· “Substantially Similar Names” (as specified in the Description of TLD Polices) will not be sold to different businesses. If a company buys dogfood.biz, other businesses will not be permitted to register dogsfood.biz or even dogs-food.biz.

· Registration must be renewed on an annual basis. The right of renewal of the site each year will require that the site is in active use and that the registrant provide a statement confirming continuing business activity.
So as to discourage domain speculation, policies forbid the transfer of an SLD between registrants unless both the transferor and the transferee meet the same standards as for registration at the time of transfer, and the transferee acquires a substantial interest in the operating business of the transferor.

C5. Appropriateness of Community

The Corporation will be the policy-making body governing a new TLD that would serve the interests of its customers and of the public. Participation in the new TLD will be restricted to commercial enterprises of all types and sizes that are actively engaged in business. Recognition of the value of this community was acknowledged when the “.com” domain was created. The public would be served by the value created by the organization through its screening function, combined with transparency of criteria of eligibility for membership. In addition, by providing a viable alternative to the unavailable “.com” domains that have been appropriated by cyber-hoarders, the Corporation will enhance the legitimate active use of the Internet as well as deflate speculation in other TLDs.

The only communities that will not be served by the creation of the proposed new TLD are cyber-squatters and domain name speculators

C6. Representation

Efforts will be made to compose a Board that brings together many aspects of the constituencies for the biz TLD. Board members will be selected from organizations that represent consumer protection: Chambers of Commerce, the Registrar Community, Better Business Bureaus, Trademark Specialists and others.

bizTRAC will make efforts to ensure that the Board of Directors is geographically diverse so as to ensure that the .biz TLD effectively addresses the needs and concerns of all regions within the global Internet community.

C7. Openness and Transparency

Openness and Transparency will be a goal of the organization at all levels.

Transparency of bizTRAC Administration:

Board meetings will be recorded in audio and video for Internet feed or download.

Information about the Corporation will be posted on our web site. There will be a news feature to advise all clients of any changes to policy (for example, if the company determined that the initial .biz registration criteria was causing unforeseen hardships to a particular business constituency and wished to amend the criteria to provide alternate means of qualification).

Information about Directors and management will also be posted on the bizTRAC web site. This will include biographical information and a means to contact the individuals.

The company will seek to be as responsive as possible to the members of stakeholder constituencies and to the public, balancing confidentiality and privacy rights with our commitment to openness and transparency.

C7.1 Transparency of Administration of Registry

Current bizTRAC policies, as specified in the accompanying document Description of TLD Policies, reflect our commitment to openness and transparency in the administration of the .biz TLD. We will further enact policy as necessary, and in the light of experience, to ensure that the processes of the Registry Operator conform to these standards. Specifically:

We will require that the standards and criteria required for granting, renewing or transferring a .biz domain name will be posted on the Registry Operator’s web site.

We will require that the Registry Operator implement procedures to allow applicants for SLDs to clearly see on the Registry website the status of their application, their position on a waiting list, if any, as well as protests to and comments on existing applications.

We will require that criterions will be measurable and specific and that applicants will not be rejected for arbitrary or frivolous reasons.

In the event of rejection, an applicant for SLD will be informed of the reason and may appeal for review with additional submittals.

Given the more complex interface with customers, we will require Registrars to enable their customers to submit complaints to bizTRAC or the Registry directly as part of their web interface.

There will be a contract with an independent auditing firm, such as Ernst and Young, to conduct random auditing of the administration of procedures.

C8. Initial Directors and Staff

The initial directors will be as indicated above.

This staff structure is anticipated to fulfill the needs of the Corporation during its initial phase. Future hiring will be in response to demands and as directed by the Board.

C9. Selection of Directors, Officers, Members and Staff

C9.1 Selection of Directors

The Board of Directors will consist of 15 to 31 members, and will be established by the initial Directors. Vacancies occurring in the Board of Directors shall be filled by a vote of the remaining Directors. The Board shall follow guidelines encouraging representation by the major constituencies served including: two Board members from groups representing Trademark and intellectual property organizations, two members from Chambers of Commerce, two representing Better Business Bureaus (or other self-regulated bodies), two representing consumer protection groups, and two from the Registrar’s community. The Board will moreover examine other constituent bodies that should be represented. Efforts will be made to nominate Board members to represent geographic diversity.

C9.2 Term of Service

The term of service for initial Directors shall be three years, except that initially, the terms will be staggered to allow for continuity of service.

Each Director, including a Director selected to fill a vacancy or selected at a special meeting, shall hold office until expiration of the term for which selected and qualified, and until a successor has been selected and qualified, or until that Director resigns or is removed in accordance with the bylaws.

C9.3 Liability

The Board may adopt a resolution authorizing the purchase and maintenance of insurance on behalf of any agent of the Corporation, against any liability asserted against or incurred by the agent in such capacity, or arising out of the agent's status as such, whether or not the Corporation would have the power to indemnify the agent against that liability under the provisions of this Article. An "agent" of the Corporation includes any person who is or was a Director, Officer, employee or any other agent of the Corporation acting within the scope of his or her responsibility, and on behalf of the best interests of the Corporation, or is or was serving at the request of the Corporation as a Director, Officer, employee or agent of another Corporation, partnership, joint venture, trust or other enterprise.

C9.4 Directors Compensation

Directors will not receive compensation other than reimbursements for expenses.

C9.5 Conflicts of interest

The Board of Directors, through a committee designated for that purpose, shall require a statement from each Director not less frequently than once a year setting forth all business and other affiliations that relate in any way to the business and other affiliations of the Corporation. Each Director shall be responsible for disclosing to the Corporation any matter that could reasonably be considered to make such Director an "interested director". In addition, each Director shall disclose to the Corporation any relationship or other factor that could reasonably be considered to cause the Director to be considered to be an "interested person". The Board of Directors shall adopt policies specifically addressing Director, Officer and Supporting Organization conflicts of interest. No Director shall vote on any matter in which he or she has a material and direct interest that will be affected by the outcome of the vote.

C9.6 Resignation

Any Director may resign at any time, either by oral tender of resignation at any meeting of the Board (followed by prompt written notice to the Secretary of the Corporation), or by giving written notice thereof to the President or the Secretary of the Corporation. Such resignation shall take effect at the time specified, and unless otherwise specified, the acceptance of such resignation shall not be necessary to make it effective.

C9.6.1 Removal

When it is determined that an individual is, for any reason, unable to fulfill their duties to the company, he/she may be asked to resign. Such removals shall proceed pursuant to the laws governing the Corporation and the relationship of the individual to the Corporation.

C9.6.2 Board Vacancies

A vacancy or vacancies on the Board of Directors shall be deemed to exist in the case of the death, resignation, or removal of any Director, if the authorized number of Directors is increased, or if a Director has been declared of unsound mind by a final order of court or convicted of a felony. Any vacancy occurring on the Board of Directors shall be filled by a vote of the remaining Directors. A Director selected to fill a vacancy on the Board shall serve for the un-expired term of his or her predecessor in office, and until a successor has been selected and qualified. The replacement need not hold the office, if any, of the removed Director. No reduction of the authorized number of Directors shall have the effect of removing a Director prior to the expiration of the Director's term of office.

C9.7 Selection of Staff

The Corporation will be an equal opportunity employer seeking qualified individuals that represent the interests of its broad diversity of customers. As an employer, the Corporation will honor all legal obligations arising from legislation and regulation at the federal and state levels. Compensation of staff will be negotiated with each individual. All compensation packages will be designed to comply with relevant state and federal legislation.

C10. Policy-Making Procedure

Policy recommendations may be brought by any Board member for consideration by the Board.

At all annual, regular and special meetings of the Board, a majority of the total number of Directors then in office shall constitute a quorum for the transaction of business, and the act of a majority of the Directors present at any meeting at which there is a quorum shall be the act of the Board, unless otherwise provided herein or by law. If a quorum shall not be present at any meeting of the Board, the Directors present thereat may adjourn the meeting from time to time to another place, time or date. If the meeting is adjourned for more than twenty-four (24) hours, notice shall be given to those Directors not at the meeting at the time of the adjournment.

“Present” at a Board meeting may be in person, or by teleconferencing or video conferencing, or other electronic means as approved or amended by the Board.

C11. Meeting and Communication

The company will hold meetings pursuant to its bylaws. Such meetings must meet the requirements of the law governing its incorporation, in this case, the laws of the state of New York. Minutes shall be kept with the bylaws and articles of incorporation.

Moreover, as indicated above, all meetings will be recorded and made available to the public over the Internet.

C12. Fiscal Information

bizTRAC will operate with an initial budget of $300,000, which will be provided as a fee from its contract with the Registry Operator. In the first year, a further $15,000 is anticipated to come from fees from Registrars.

We anticipate that two-thirds will go towards salary of staff, and one-third to equipment and overhead. (see bizTRAC Projections attached below).

In the case that in any given year there are less than 1,000 registrations in the .biz TLD, our budget and activities will be cut back to a maintenance level. Under these circumstances our budget will be $100,000 all of which will be received from the Registry Operator.

C13. Liability

Director, officer and staff liability will be dealt with by obtaining business insurance from a recognized insurance provider.

The company recognizes its duty to ensure that its representations to all stakeholders are fair and accurate.

It is not the intention of the company to mandate the Registry Operator to perform exhaustive due diligence before granting a domain name. The company shall instruct the Registry Operator to make no representations as to the business worthiness, business history, or other information on business practices engaged in by the company granted the domain name.

The Registry Operator will verify the material submitted as proof of a legitimate, active business under the particular domain name being sought. The company will clearly indicate the criteria for granting a .biz domain name both to its potential customers and the public.

C14. Amendment of Articles of Incorporation or Bylaws

Amendment of the Articles of Incorporation or the bylaws of the company will be governed by the law of the state of New York pursuant to all relevant legislation and regulation.

C15. Reconsideration and Review

bizTRAC intends to substantially adopt the Reconsideration and Review Policy of ICANN as reproduced below:

Any person affected by an action of the biz TLD Regulatory and Advisory Council (“bizTRAC”) may request review or reconsideration of that action by the Board of Directors.

The Board will establish and maintain a Committee of the Board consisting of not less than three directors to review and consider any such requests ("Reconsideration Committee"). The Reconsideration Committee will have the authority to: (i) evaluate requests for review or reconsideration, (ii) determine whether a stay of the contested action pending resolution of the request is appropriate, (iii) conduct whatever factual investigation is deemed appropriate, (iv) request additional written submissions from the affected party, or from other parties, and (v) make a recommendation to the Board of Directors on the merits of the request.

bizTRAC will absorb the normal administrative costs of the reconsideration process. It reserves the right to recover from a party requesting review or reconsideration any costs which are deemed to be extraordinary in nature.

A request for review or reconsideration must be filed within 30 days after (a) the affected party or its affiliate receives notice of the action, or (b) bizTRAC posts notice of the action on its website, whichever is sooner. Requests for review or reconsideration must be submitted by email to bizTRAC. No particular form is required, but requesting parties must include at least the following information:

name, address, and contact information for the requesting party, including postal and email addresses;

· the specific action of bizTRAC for which review or reconsideration is sought;

· the date of the action;

· the manner by which the requesting party will be affected by the action;

· whether a temporary stay of the action is requested;

· what specific steps the requesting party asks bizTRAC to take - i.e., whether and how the action should be reversed, cancelled, or modified;

· the grounds on which the action should be reversed, cancelled, or modified; and

· any documents the requesting party wishes to submit in support of its request.

If a temporary stay of the action is requested, the requesting party should identify what harms will result if the action is not stayed.

The Reconsideration Committee will endeavor to complete its work and submit its recommendation to the Board within 30 days of the filing of the request; its recommendations will be made public on the bizTRAC web site. The Board will not be bound to follow the recommendations of the Reconsideration Committee. The final decision of the Board will be made public as part of the minutes of the Board meeting at which it was made.

To protect against abuse of the reconsideration process, a request for reconsideration may be dismissed by the Reconsideration Committee where it is repetitive, frivolous, non-substantive, or otherwise abusive, or where the affected party had an opportunity, but was unwilling, to participate in the public comment period relating to the contested action, if applicable. Likewise, the Reconsideration Committee may dismiss a request when the requesting party has not shown that it will be "affected" by bizTRAC's action.

II. PROPOSED EXTENT OF POLICY-FORMULATION AUTHORITY

C16. Scope of Authority Sought

C16.1 Summary of Authorities Sought

Authorities sought fall under two broad headings: Policy Authorities and Administrative Authorities. All Policy Authorities should be understood to be subject to ICANN consensus override.

C16.1.1 Administrative Authority

Authority to make and amend policy-establishing standards for day-to-day administration of the TLD will reside with bizTRAC, and the authority to operate under such policies will be delegated by bizTRAC according to contract with the Registry Operator.

These administrative authorities include the authority to process and accept or reject applications in accordance with policy, to revoke SLDs for failure to maintain standards set by policy, to renew or refuse to renew SLDs based on policy criteria, to supervise and oversee registry operator, to accredit and appoint registrars (from the universe of ICANN accredited registrars) as determined by policy

Summary of Policy Authorities (subject to ICANN consensus override)

C16.2 Authority to Create Policy for a New Restricted TLD

· Authority to create sub-domains, such as country sub-domains.

· Authority to set policy regarding the application, renewal and transfer processes of SLDs, (and appeals from decisions regarding each) specifically including policies for:

- accepting or rejecting applications for the SLDs under the TLD;

- appealing rejected SLD applications;

- requirements for maintaining SLDs active;

- appealing SLD revocations;

- SLD renewal;

- appeal of rejection of SLD renewal;

- transfer of SLDs;

- appeal of rejection of transfer application.

· Authority to set policy for disputes; specifically, the authority to create additional provisions to the UDRP for application to this new restricted TLD.

· Authority to specify unique terms of accreditation and of agreement with ICANN approved registrars.

· Authority to set policies regarding data escrow, privacy and Whois, so long as these policies conform to or exceed existing ICAAN policies.

· Authority to set policies for protection of intellectual properties.

Authority to set policies regarding pricing and services to be provided for SLDs under the new TLD.

The following pages review each of these types of policies.

C16.2.1 Authority to Create Sub-domains (such as country codes)

This activity falls into a special category, but one also subject to final review by ICANN.

Scope:

Creation of sub-domains including country codes, such as:.uk.biz.

Reasons / Justifications:

Creating different geographical sub-domains will allow for the individuals assessment of what constitutes a real business in countries with different levels of wealth or economic development and institutional norms.

Method of guaranteeing administration in interest of Internet at large:

We expect to introduce sub-domains at a future date primarily to address countries whose economic structure demands significantly different application standards.

At that time, proposed changes will be open for public review and input from the advisory Board and ICANN.

Any variation from existing ICANN policies:

Does not vary from existing naming convention policy for TLDs.

C16.2.2 Authority to Set Policy Regarding Applications for the SLDs Under the TLD

Scope:

Setting criteria for granting an SLD application based on financial soundness as evidenced by clearly defined objective measures.

Setting criteria for granting or rejecting an SLD application based on intellectual property criterion (i.e. are there blatant infringements?).

Setting different criteria for granting an SLD application which apply only to the start-up or “sunrise” period which gives additional priorities to those fulfilling specific business criteria, or those having specific existing intellectual property rights to create new application protocols for use by Registrars to facilitate the policies of new TLD (such as “Name Reserved Status”, “Pending Review” etc.).

Reasons / Justifications:

The aim of the biz TLD is to restrict SLDs to operating businesses only and to eliminate or discourage cyber-squatting and cyber-hoarding. We believe that some minimal level of financial and intellectual property scrutiny is necessary to achieve the aim.

Method of guaranteeing administration in interest of Internet at large:

Granting or rejecting SLD applications will be based on clear and measurable criterion, and all internal operations and procedures of Registry will be randomly checked by an independent auditor to ensure compliance with these measures.

Any variation from existing ICANN policy:

This differs greatly from existing first come, first serve policy RFC1591.

C16.2.3 Authority to Set Policy Regarding Requirements for Maintaining SLDs Active

Scope:

The authority to require that SLDs meet certain criteria as to their business and operations as well as web presence to keep their SLD designation.

Reasons / Justifications:

The heart of this restricted TLD is that it is for active businesses. Therefore, appropriate restrictions include revenue, expenses and/or active web presence.

Method of guaranteeing administration in interest of Internet at large:

This restricted TLD benefits the Internet at large in that it provides a dedicated commercial TLD that can offer some degree of oversight as to the bona fides of SLD entitles.

Any variation from existing ICANN policies:

Varies from current ICANN policies.

C16.2.4 Authority to Set Policy Regarding SLD Renewal

Scope:

Authority to require that applicants pay a fee and meet certain minimum financial measures, as well as maintain an active web presence for SLD renewal.

Reasons / Justifications:

The heart of this restricted TLD is that it is for active businesses. Therefore, appropriate restrictions include revenue, expenses and/or active web presence.

Method of guaranteeing administration in interest of Internet at large:

bizTRAC will mandate administrative procedures of the Registry Operator be randomly audited by sample to ensure operation in accordance with policies.

Customers will be able to request an internal Registry Appeal, which will be automatically granted.

Complaints may be lodged via the web with Registrar, Registry Operator or bizTRAC via the interface with Registrar.

Any Variation from existing ICANN policies:

Varies from current ICANN policies.

C16.2.5 Authority to Set Policy Regarding Transfer of SLDs

Scope:

To restrict transfer of SLDs to operating businesses. To prohibit speculation in SLDs except as they are related to actual business operations.

Reasons / Justifications:

Unless a policy regarding transfers exists and is enforced, the rationale behind the .biz will be undermined.

Method of guaranteeing administration in interest of Internet at large:

The heart of this restricted TLD is that it is for active businesses. Therefore, appropriate restrictions include revenue, expenses and/or active web presence.

Any variation from existing ICANN:

Varies from current ICANN policies.

C16.2.6 Appeals: Authority to Set Policies for Appeal of Rejected SLD Applications, of SLD Revocations, of Rejected Renewals, of Transfers

Scope:

To allow the Registry Operator to require an administrative first appeal within Registry Operator’s Administration.

To allow Registry Operator to set boundaries liability in the event an applicant seeks to proceed beyond an administrative appeal to arbitration.

To allow Registry Operator to limit liabilities the event of an appeal beyond an internal first appeal.

Reasons / Justifications:

By restricting application, renewal and transfer, it follows that some percentage of applications will be rejected (although this should be minimized by the criterion being simple, measurable and openly advertised). Unless the liabilities of the Registry and Sponsor are limited, the new TLD could be crippled with a floss of claims for “lost business opportunity”, “punitive damages”, etc.

See section E16.16 of TLD Policies.

Method of guaranteeing administration in interest of Internet at large:

The administrative first appeal will be granted automatically on request.

The appeal will consist of two additional Registration Administrators reviewing the application package according to the same measures, as well as any additional materials applicant may choose to provide.

All internal operations and procedures of Registry Operator will be randomly checked by an independent auditor to ensure compliance with these measures.

In the event the Complainant wishes to proceed to arbitration, the Registry Operator will not move to seal records of the proceeding (but will not oppose Claimants motion to do so on the grounds of confidentiality).

More broadly, the Registry Operator will be regularly receiving input from a Board of Directors and the Advisory Board, which includes representation from independent Directors chosen from a broad range of constituencies.

Any variation from existing ICANN policy:

Necessarily differs from existing policy inasmuch as application requirements are more complex than first come first serve and renewals are more restricted than merely paying renewal fee.

C16.2.7 Authority to Set Policy for Disputes, Specifically Additional Provisions to UDRP for Specific Application to this New TLD

Scope:

Authority to adopt the Uniform Domain Name Dispute Resolution Policy, adding certain requirement(s). Specifically, that registrants must submit to arbitration proceedings if a complainant asserts that an SLD is being used contrary to policy restrictions of TLD.

Reasons / Justifications:

In order to protect the integrity of the restricted TLD, complainants must necessarily be able to assert causes of action grounded in the TLD restrictions.

Method of guaranteeing administration in interest of Internet at large:

Administration of the requested additional provisions will conform to existing arbitral standards, and will therefore presumably be sufficiently administered in the interest of the Internet at large.

Any variation from existing ICANN policies:

The addition varies from UDRP.

C16.2.8 Authority to Specify Terms of Agreement with Registrars, so long as it Accords with Existing ICANN Policies

Scope:

To create policies and procedures appropriate to biz restricted TLD.

Reasons / Justifications:

This restricted TLD will establish a new registration protocol at the registrar level which must be uniform (for example: provision for “Name Reserved” status in application procedure).

Method of guaranteeing administration in interest of Internet at large:

These policies and agreements will be made openly and with input from the Board of Directors and Advisory Board at large.

Any variation from existing ICANN policies:

New registration protocol varies considerably, therefore the registrar’s protocol and interface with Registry and public will also vary from current procedure.

C16.2.9 Authority to Set Policies Regarding Data Escrow, Privacy and Whois

Scope:

To address privacy and Whois policies as related to SLD owners in light of the aim of restricted TLD.

Reasons / Justifications

Because, by definition, each registrant will be an ongoing business with a major stake in its data and its intellectual property, there may be a need to exceed ICANN policy requirements. This issue will be discussed in initial negotiations establishing this TLD. Additional Whois data will be required to facilitate resolution issues peculiar to the administration of this TLD. For example, the additional Whois data fields of “Area of Business” and “Market Location” are required to address intellectual property issues.

Method of guaranteeing administration in interest of Internet at large:

Because of the rate of technological change, these policies, and their implications will need to reviewed periodically by the Board with input from constituencies.

Any variation from existing ICANN policies:

Perhaps more stringent, any changes in the future will probably be in the direction of greater protection.

C16.2.10 Authority to Set Policies for Protection of Intellectual Properties

Scope:

To provide some up front protection by a scan of certain Trademark databases, as well as public postings of objections during the approval period.

Reasons / Justification:

As noted in many ICANN working group discussions, there is no reasonable process that can guarantee total up front protection. Therefore, the compromise solution proposed here is a cursory search of trademark databases to eliminate obvious infringements. Also, by virtue of an approval period that spans several weeks and public posting of objections, aggrieved parties will have a (admittedly small) window in which to initiate injunctive action. Method of guaranteeing administration in interest of Internet at large.

Adoption of the UDRP with addition of arbitration provisions, as reviewed above. (See dispute resolution)

Any variation from existing ICANN policies:

Varies from policies.

C16.2.11 Authority to Set Policies Regarding Services and Pricing to be Provided for SLDs under the New TLD

Scope:

Authority to set contract terms with the Registry Operator, including proposed services and pricing as detailed in E9. Services may be redefined (new services added, existing services expanded, etc.). Any changes to be made with sufficient time for review and input from all constituencies.

Reasons / Justifications:

Although initial concept testing has suggested that the proposal’s offered services and pricing will meeting market need, actual operations and feedback from users and stakeholders may surface changes that will support bizTRAC purpose as defined in C1.

Method of guaranteeing administration in interest of Internet at large:

The proposed methods of broad dissemination, gathering of feedback, wide participation in policy formation, will provide information of value to bizTRAC as to the fit between policies and mission.

Final policy changes will be subject to ICANN consensus override.

Any variation from existing ICANN policies:

Pricing proposal differs from pricing policies.

II. CONTRACT TERMS WITH REGISTRY OPERATOR

C17. Identification of Registry Operator

Affinity Internet, Inc.

101 Continental Blvd. 3^rd Floor

El Segundo, CA 90245

C18. Contract with Registry Operator

The contract with Registry Operator will include the following provisions:

Have a duration of five years.

Mandate that Registry Operator to administer operation of TLD in conformance with TLD policies.

Will recognize regulatory and advisory authorities of bizTRAC, as outlined in this document, and also any other powers or authorities that may be granted to bizTRAC during negotiations with ICANN in order to fulfill the purpose of bizTRAC (as stated in C1).

Specify the fee payable to bizTRAC by Registry Operator to be $300,000 per annum and any other fee(s) payable (as for example to ICANN).

Provide for independent review policies and adequate appeal procedures for the Registry Operator to the extent that it is adversely affected by bizTRAC actions.

CONCLUSION

It is difficult to balance on the one hand, the need for governance by the stakeholders of a new TLD with, on the other hand, the equally important need to have a simple and workable structure on the other.

We believe that the above proposal meets those requirements and, together with a contract created along the lines of C18 (above) will provide a workable framework within which to test the novel .biz proposal.

By signing this proposal, the undersigned attests, on behalf of the applicant, that the information contained in this application, and all supporting documents included with this application, are true and accurate to the best of the applicant’s knowledge.

__________________________

Signature

__________________________

Name (please print)

__________________________

Title

__________________________

Name of the Applicant Entity

__________________________

Date

Resumes of Board of Directors

Philip J. Berent

Joshua Kyle

Tony Keyes

Manon Anne Ress, Ph.D.

Keith A. Palzer

Philip J. Berent

Experience (Highlights)

Jan ’96 BERENT CAPITAL LLC (New York) President

- Present Developed company’s investment strategy which is a quantitively based approach to investment in the global fixed-income and forex markets, implemented through the use of derivatives (swaps and FX forwards). Programmed (C & C++) initial implementation of software used in determining trading decisions. Subsequently hired programmers to maintain and further develop software. Raised equity capital ($175,000) sufficient for start-up. Prepared marketing literature and developed supporting research materials. Marketed extensively to top levels of management in corporations and investment funds in USA, Europe, and the Middle East. Signed up three accounts: a quantitively based trading unit of a U.S. Investment Bank, a Chicago based hedge fund and a large bank and fund manager In Holland. Total assets under management have been as high as aprox. $1.25 Billion in swap positions (equivalent to about $95 Million in moderate risk cash investments).

LECTURING ASSIGNMENTS

Presented a course on “Derivative Strategy” on an annual basis at Carnegie Mellon’s executive program in New York, and in September ’99 at Lausanne University FAST program in Switzerland. Scheduled to lecture at FAST program again in Sept 2000.

Nov ‘94 MERRILL LYNCH (New York) Head of Credit Derivative Marketing (Director)

- Jan ‘96 Devised and market credit derivative strategies to clients base in New York and Europe.

May ‘94 MERRILL LYNCH (Frankfurt) Head of Investor Strategies Group (Director)

- Oct ‘94 Headed team marketing structured products, derivative strategies, and warrants to Germany, Austria and Poland.

Jan. '92 - MERRILL LYNCH (London) Structured Product Specialist

May ‘94 (Director promoted from V.P. Jan 1994): Developed and marketed structured fixed income derivatives. Position involved structuring fixed income derivative MTN products and swap strategies and direct sales to key accounts in London, Switzerland, Turkey, and the Middle East. Also provided coverage to fixed-income sales-force by developing ideas for general distribution to the account base and working with their clients in response to specific enquiry. Prepared marketing materials (presentation materials and theoretical paper on implied forward rates) now used in marketing derivatives by structured product groups in Merrill Lynch throughout Europe and Asia. Organized and presented at conferences on structured MTN's in London, Spain, Switzerland, Middle East, Turkey. Developed structured portfolio optimization system (developed idea and wrote C program) covering cash and structured products. Currently this system is being marketed to clients. Top producer in 1992 and 1993, generating revenue of $10.5 MM in 11993

May '91- Sales Desk Analyst

Jan. '92 Analysis and Marketing: Provided analytical support to fixed income sales force for London office. Worked with salespeople and clients to analyze existing portfolios and to recommend investment and hedging strategies across a broad range of products. Product areas included: structured derivatives, financial futures and options, swaps, mortgages, CMO's, adjustable rate mortgages, putable and callable bonds, governments etc. Analytic methods used included, regression analysis, programming (in C, and basic), option adjusted spread analysis, and use of Merrill Lynch portfolio analysis software.

Education: Made educational presentations on portfolio management using duration and convexity, and on futures and options, at Merrill Lynch conference for delegates from central banks (attended by Bundesbank, Bank of England, etc.). Made follow-up visit to Bundesbank for further discussions with dollar trading group. Presented sequence of internal educational lectures to London sales-force. Made presentation on Financial Futures at external conference.

Research

Wrote research articles in Merrill Lynch "Fixed Income Weekly” on using futures and options, also wrote papers for internal and external distribution on "Mean Reversion of Option Volatility”, "Assessing and Hedging Slope Duration", and "Synthetic Leverage Using Financial Futures". Programmed cubic spline model (in C) for calculating theoretical yield curve.

Feb '88 TSA CAPITAL MANAGEMENT (Los Angeles)

- March '91 Associate Investment Strategist promoted November 1988 to Assistant Vice President, promoted July 1990 to Vice President Research: Developed option based cash management strategy "Protected Principal". Project involved historical analysis of index option markets, simulation of strategy performance, and development of PC based record keeping and trading system.

Co-authored "Market Timing with Imperfect Information" Financial Analyst's Journal, November/December 1989.

Co-authored "Diversifying Among Asset Allocators" Journal of Portfolio management Spring 1990.

Developed and tested Neural Network and other non-linear statistical software for use in quantitative market forecasting applications.

Marketing Prepared marketing literature for Protected Principal strategy. Made telephone and live presentations (including cold calls) to current and prospective clients.

Trading (Feb '88 to June '88) Traded company's bond future and stock index future positions. Wrote PC based system to assist with trading operations.

Jan '87 KIDDER PEABODY AND COMPANY (New York)

- Dec '87 Sales trainee in Fixed Income and Financial Futures Division

Financial Futures Department: Initiated research project to examine various aspects of short-term liability hedging. Assisted in research on valuation of "wild card" delivery option. Made written and telephone presentations to prospective clients. Worked with salespeople and clients to determine hedge strategies.

Fixed Income Division: Assisted Money Market trading desk acting in liaison role between traders and salespeople. Traded odd-lots (Agency Discount Notes and Bankers Acceptances) and commercial paper.

Training: Participated in Fixed income Division and financial Futures training program. (Total of four months)

Summer CORNHILL PUBLICATIONS LIMITED (London, England)

1984 Sales Representative Telephone sales of advertising space. Won "Salesperson of the Month" award for achieving highest sales out of a staff of forty.

1981-1983 ENGLAND TO ZIMBABWE MICROLIGHT EXPEDITION

Originator, Chief administrator, Expedition Leader and Pilot

Organized and flew expedition achieving British record for long distance flight by ultralight aircraft. Co-ordinated activities of three other expedition members. Organized national and international newspaper and television coverage. Raised £40,000 pounds of corporate sponsorship (Levi Strauss UK, Nikon UK etc.). Obtained permission for expedition through communication with high levels of government of countries on route.

Education

1984-1986 COLUMBIA UNIVERSITY GRADUATE SCHOOL OF BUSINESS (New York)

MBA - Finance and Management Science - May 1986. Recipient of R.C. Kopf Fellowship (merit based). Beta Gamma Sigma (national business honours society). Dean's List.

1977-1981 UNIVERSITY OF SUSSEX

B.A. (Honors) - Economics - June 1981. Class: Upper Second

Student representative on school committee. Co-founder of Rock Music Society. Member of Sussex University Drama Society

Additional Information

Series 7 and Series 3 certification. Fluent in French and Italian. Basic Knowledge of

German and Spanish. Extensive PC experience and knowledge of software including: Perl, Javascript, HTML, C, C++, Access, Visual Basic, Quickbasic, Dbase III, Lotus, Excel, Word and various Windows applications. Travelled extensively in Europe, United States and Africa. Member of Mensa. Enjoy amateur dramatics, playing guitar, chess and playing squash.

JOSHUA M. KYLE

Experience

‘98-’99 FILM BOND, INC., A DIVISION OF FRONTIER INSURANCE CORP. NYC

President

Conceived, developed, staffed and developed marketing and operating plan for corporation to extend Fronier’s completion insurance to the independent film industry.

‘97-’98 MERRILL LYNCH

Financial Consultant

As a member of the Park Avenue private client group, directed investments for high net worth individuals and institutional investors. Specialty, East Asian product.

‘96-’97 CREDIT CHINA CORPORATION New York – P.R. China

Vice President, Venture Capital

Investment evaluation; business plan preparation and improvement; due diligence. Placed first $10 million institutional capital in CCC fund. Projects included $100 million “Build Operation Transfer” toll highway in PR China; due diligence for proposed investment in Boston University Community Technology Fund; structuring of acquisition of HK banking corporation; preparation for reverse merger of CCC subsidiary into US public shell, and others.

‘89-’96 WORLD IMPACT TRADING CORPORATION New York – P.R.China

Founder and Principal, Apparel Manufacturing

Evaluated potential JV partners, negotiated agreement and invested start-up capital with

manufacturer in Mainland China. Overall responsibility for operations including manufacturing, shipping , and marketing. Daily cold calls for two years until customer base established. 1989 revenues of $60,000; 1996 revenues exceeded $6 million.

‘87-’90 ARCUS DEVELOPMENT CORPORATION New York, NY

Founding Partner, Real Estate Development

Identified major New York City public housing renovation program as economically viable and coordinated efforts to secure designation. Chose and assembled development team, negotiated compensation and placed equity portion. Firm won two sites totally 100 dwelling units valued at over $8 million.

‘82-’85 THE CROMWELL GROUP Fairfield, CT

Associate, Boutique Investment Banking

Targeted acquisition screening for middle-market clients. Made cold calls on potential clients, with higher hit rate than the principals. Conducted all initial contacts and preliminary evaluation for seven acquisition clients resulting in two acquisitions.

Education

‘92- ‘94 COLUMBIA BUSINESS SCHOOL

MBA, Management and Finance

Member: American Finance Association, East Asian Business Association, Venture Capital Club, Columbia Boxing Club.

‘84-’87 NEW YORK UNIVERSITY: TISCH SCHOOL OF THE ARTS

MFA, Film. Chosen as Director for class Senior Thesis Project

‘80-’81 YALE UNIVERSITY

Archibald MacLeish Scholar

Additional

Series 7 and 63. Proficient in spreadsheet word processing and internet programs

Member, Yale Club, Yale Alumni Association, Sloan Club (London).

Steward, Findhorn Foundation (Forres, Scotland). Dual US-UK citizen.

Tony Keyes

Tony Keyes is chief executive officer and president of BulkRegister.com, the leading provider of high-volume domain name registration services in the B2B space. A start up veteran with 22 years of experience, has senior management experience as a former sales and marketing executive with a host of top tier IT companies including Cisco Systems, GTE, StrataCom and Netrix Corporation.

Since February 1, 1999, Keyes, has propelled BulkRegister.com into the marketplace, capturing 12 percent of the global domain name registration market in Q1 of 2000, securing the company's position as the third largest domain name registrar behind Network Solutions and Register.com.

Prior to joining BulkRegister.com, Keyes also served as an angel investor helping companies such as MindQ Publishing, eTel, Formal Systems of America, POP N GO and The Fudgery develop successful business plans, secure venture capital and win contracts from early adopters.

Mr. Keyes holds a bachelor's degree from Ohio University. He is married with three children and enjoys golfing, running and photography.

About BulkRegister.com

BulkRegister.com, a trade name of the ICANN accredited Alabanza Inc., is the leading provider of high-volume domain name registration services in the B2B space. Founded in December 1999, BulkRegister.com provides wholesale pricing and online registration of top-level domain names. BulkRegister.com offers automated registration, instantaneous registration confirmation, security, online account access, account management and customer support services. The company brings value, efficiency and reliability to the marketplace through a complete suite of services and low-cost domain name registration. BulkRegister.com does not compete with its clients by offering competitive services such as Web site design, hosting or ISP services. For more information, please visit http://www.BulkRegister.com.

MANON ANNE RESS, Ph.D. 5900 5th St. N., Arlington, VA 22203

PROFESSIONAL EXPERIENCE

Director . Debs-Jones-Douglass Institute. 1999-Present. Development of projects and policy research on labor and Internet related issues.

Consultant. 1998-Present. Developed a research project comparing France and US. policies toward children, and worked on a project on privacy, NoPrivacy.Org, a privacy rights project. Worked on tax policies toward drug donation.

Manager of Education and Technology ‑ Development of Universiti Tun Abdul Razak

a distance education institution in Malaysia, 1996 ‑1997. Member of an international, pluridisciplinary team working with KUB Malaysia and Science Application International Corporation (SAIC). Managed design and planning of the UNITAR curricula, selected and evaluated educational partners and curricula, analysis of modes of delivery and teacher training, development of MOU's with academic institutions.

Research Associate. 1995 ‑ 1996. Coordinated a workshop of Public Utility Commission members and staff on the subject of pricing of residential Integrated Services Digital Network (ISDN) services, (Essential Information). Coordinated workshop on Medical Records Privacy, (Center for Study of Responsive Law's Consumer Project on Technology). Developed Essential Information About Privatization, a Web based publishing demonstration project, for Essential Information.

Assistant Professor/Course Coordinator ‑ Temple University, 1992 ‑ 1995. Taught 17th‑century French Literature, French Theater, French Culture and Civilization, Pedagogy, and "Intellectual Heritage" (survey of important works from the Enlightenment to the present). Coordinated language courses, supervised, trained and evaluated instructors of the University's French language courses. Participated in a major evaluation of the French section's "core" curriculum, and served on the University's Teaching Learning and Technology Committee and the College of Arts and Sciences Committee on Teaching and Technology. Selected as a Lilly Fellow to study the use of technology in teaching.

Consultant ‑ Heinle & Heinle and DC Heath.1993‑1994. Reviewed language textbooks.

Lecturer ‑ Department of Romance Languages and Literature, Princeton University. 1989‑1992. Taught and served as "Head of Course" for the Undergraduate intensive language training course,

Writer and editor ‑ Berlitz International. 1987‑1988. Wrote, edited, tested instructional materials for children and adults

EDUCATION

Princeton University, Romance Languages and Literature. M.A. 1985, Ph.D. 1992. Universite de Nice, D.E.U.G. 1980, Licence d'Histoire 1981, Maitrise d'Histoire 1983.

Keith A. Palzer

EDUCATION

Northwestern University School of Law, J.D. 1988

· Editor-in-Chief, Northwestern Journal of International Law & Business

· Lowden-Wigmore Legal Scholarship Prize for Law Journal Comment

· Law School Curriculum Committee and Social Security Disability Program Representative

State University of New York at Binghamton, B.A. 1985

· Economics and Political Science Major; International Relations Concentration

· Social Science Program, Spring 1984, Paris, France

PROFESSIONAL

Merrill, Lynch & Co., Inc. November 1997 to Present New York, NY

Director and Senior Counsel, Corporate and Institutional Client Group

· Capital Markets – General counsel to Latin American Debt and Global Foreign Exchange businesses, with responsibility for all legal aspects of business: securities origination and trading, OTC derivative and currency trading, corporate governance issues, structured product and compliance.

· Financial Regulation and Corporate Strategy – General Counsel, Merrill Lynch International Bank. Staff attorney, Bank Oversight Committee. Active participant in industry-wide Corrigan-Thieke Working Group.

· E-Commerce – Lead counsel for several Global Debt Markets e-commerce initiatives, including Global Emerging Markets Debt and Global Foreign Exchange trading platforms for Merrill Lynch “MLX” initiative.

Mayer, Brown & Platt May 1995 to October 1997 New York, NY

Associate, Finance, Investment Management and Regulatory Groups

· Financial Regulatory – Advised foreign and domestic banks on a wide range of issues, including annuity marketing, merchant banking, project financings, equity investments, off-shore investments and “Section 20” securities powers; handled regulatory filings with New York State Banking Regulator, Comptroller of the Currency and Federal Reserve; drafted firm’s standard securitization opinion letter (FIRREA opinion); extensive experience with Federal Reserve’s Regulations K, Y and New York State Banking regulations relating to foreign banks.

· Finance and Capital Markets – Structured and documented numerous OTC derivative, repurchase and other capital markets transactions involving equity and fixed income products. Developed standard underwriting, brokerage and annuity marketing arrangements for mid-sized U.S. capital markets bank.

· Investment Management – Advised, structured and organized private and public funds, with principal focus on emerging markets hedge funds, equity mutual funds, ERISA structures and investment partnerships. Lead attorney on public offering of innovative “shared yield” fund product, entry by foreign bank into high yield asset management business and advising major international bank on global custody issues.

Morrison & Foerster January 1994 to May 1995 New York, NY; Washington, DC

Associate, Finance Services and Financial Transactions Groups

· Foreign Direct Investments and Financial Transactions – Lead attorney on major investments by three different U.S. financial institutions in Latin America. Advised major credit card consortium on creation of “smart cards” in emerging markets. Prepared survey for large European commercial bank on Latin American acquisition strategies. Advised Ex-Im Bank on Colombian project finance. Personally responsible for over $300,000 of new business.

· Financial Services Regulation – Handled U.S. regulatory filings for domestic and foreign banks, including domestic branching and mortgage banking applications, “de-insurance” of foreign bank branches, and Regulation K issues; advised on off-shore exemption for foreign broker-dealers; counseled on insurance investment laws (New York State).

Keith A. Palzer

U.S. Department of the Treasury Sept. 1988 to Dec. 1993 Washington, DC

Attorney, Office of International Affairs

· Office of the General Counsel, August 1990 to December 1993 – Negotiated and drafted the financial services provisions of the North American Free Trade Agreement and the Uruguay Round (GATT) General Agreement on Trade in Services on behalf of the United States. Assisted in drafting Iraqi Sanctions Program during Gulf War. Department’s counsel on international banking, securities and insurance regulatory matters, including BCCI, Foreign Bank Supervision Enhancement Act of 1991, and Bush Administration’s 1991 financial reform effort. Extensive high-level contacts with regulators, private sector representatives, government officials and legislators.

Special Assistant United States Attorney, Eastern District of Virginia

· Detail to U.S. Department of Justice, March to July 1990 – Prosecuted financial crime and drug cases in Federal courts. Draft prevailing brief and delivered prevailing oral argument before the U.S. Court of Appeals for the Fourth Circuit in appeal of fourth amendment issues in crack conviction.

Honors Attorney

· Various Postings, September 1988 to February 1990 – Six-month assignments with Office of Banking and Finance, Office of the Comptroller of the Currency and Office of International Affairs. Assisted Department implementation of 1989 thrift bail-out legislation; counseled interagency task force on study of directors and officers liability; researched and drafted interpretive letters and policy positions on national bank securities and insurance powers; assisted in drafting of regulations governing national security review of foreign mergers and acquisitions (Exon-Florio); helped develop U.S. policy on EC 1992 financial directives.

Mudge, Rose, Guthrie, Alexander & Ferdon Summer 1987 New York, NY

· Summer Associate, Corporate and Litigation Departments

Lawyers Committee for Human Rights Summer 1986 New York, NY

· Summer Intern, Political Asylum Project

BAR ADMISSIONS New York and District of Columbia

LANGUAGES Native English speaker; working knowledge of French and Spanish.

PROFESSIONAL MEMBERSHIPS

· Member, Federal Reserve Bank of New York’s Financial Markets Lawyers Group.

Member, The Bar Association of the City of New York Banking Law Committee.

bizTRAC Projected Budget