C21. Describe in detail your proposed methods of providing registry services on an equivalent basis to all accredited registrars having registry-registrar agreements in effect. Your description should include any measures intended to make registration, technical assistance, and other services available to ICANN-accredited registrars in different time zones and relevant languages. In addition, describe the Registry Code of Conduct and other commitments you propose to make to ensure that all such registrars receive equivalent access to registry services. In preparing your response to this item, you may wish to refer to Appendices H and I of the registry agreements ICANN has entered for unsponsored TLDs (e.g., .biz, .com, .info, .name, and .pro).

Requirements of Registry Agreement and Appendices

Any registrar accredited by ICANN to act as a registrar for domain names ("ICANN accredited registrars") will be eligible to register .org domain names, as long as such registrar agrees to the .org TLD registrar-registry agreement.  It is anticipated that the registry-registrar agreement will be substantially similar to Exhibit F to the ICANN gTLD registry agreement, with any changes from the current RRA to be negotiated by ICANN and the DotOrg Foundation. 

Equivalent access to the Registry-Registrar Protocol for all registrars will be guaranteed contractually in order to create a level playing field. The registry and its registry service vendors will comply with policies and procedures as have been described in Appendices H (Equivalent Access Certification) and I (Code of Conduct) to the model Registry Agreement.  The registry will also make a certification to ICANN at the end of the six month period immediately following the effective date of the Registry Agreement and at the end of each subsequent six month period for the term of the Registry Agreement, using the objective criteria set forth in the Equivalent Access Certification, if one is required by ICANN.

The DotOrg Foundation will ensure, in a form and through ways described in the Equivalent Access Certification (Appendix H) that the revenues and assets of the registry are not utilized to unfairly advantage itself, its affiliates, any of its contractors, or any owner of such contractor,to the detriment of other ICANN accredited registrars.  The Foundation is not affiliated with any registrar – it has no Board members, advisors or staff so affiliated.  Registry Advantage is a division of Register.com, but is operated in an independent manner with the segregation of operations, systems and staff already required under the .pro Registry Agreement.  In the event that Registry Advantage is ever replaced as the vendor for registry services, the DotOrg Foundation will ensure that any subsequent provider of such services meets this same standard of independence.

All registrars shall pay equivalent registration fees.  The DotOrg Foundation’s budget (Attachment E1) demonstrates the Foundation’s intent to comply with this requirement.

The registry shall not in any way attempt to warehouse, or register domain names in their own right other than through an ICANN-accredited registrar, except for names designated for operational purposes. 

Registry Advantage maintains separate operations from Register.com’s registrar operations. 

Neither the DotOrg Foundation nor Registry Advantage shall have access to, or use, confidential user data or proprietary information of a .org accredited registrar that is received by the registry in the course of providing registry services, except as necessary for registry management and operations.

Both the DotOrg Foundation and Registry Advantage will take appropriate precautions to prevent the disclosure of confidential user data or proprietary information received from any .org accredited registrar in the course of providing registry services, except as necessary for registry management and operations.

Confidential information about the DotOrg Foundation or Registry Advantage’s registry services for the .org TLD will not be shared with employees of any accredited registrar, including Register.com’s registrar employees, except as necessary for registry management and operations.

Audits

The DotOrg Foundation will conduct internal neutrality reviews of itself and its vendors on a regular basis. In addition, the Foundation and ICANN may mutually agree on an independent party that ICANN may hire to conduct a neutrality review of the Foundation, and its registry services vendors in order to ensure that the registry system is operated in full compliance with all the provisions of this Registry Operator Code of Conduct.  The DotOrg Foundation’s Services Agreement further provides the Foundation with an audit right, which will allow it to ensure that the registry system is operated per the equivalent access, confidentiality and code of conduct requirements. 

Notice to Registrars

All .org registrars will receive reasonable notice of updates, changes or downtimes in registry operations, as described in C17, allowing them to prepare their operations.  The timing of the notice is designed to allow for adequate preparation by a variety of registrars – no matter the geographic location or the size of the registrar.  The registry will also provide documentation and tool kits to registrars to facilitate their transition to the new registry system and their ongoing transactions with the registry.

Registrar-Registrant

The registry will leave to the registrars any direct interface with the registrants.  This will include collecting and sending to the registry accurate and reliable registrant information, as required by ICANN and the registry-registrar agreement; updating the Whois database per changes in registrant’s information, transfers, deletions, renewals, or other commands; and providing registrants with technical, billing, and other customer support.

Registrars – not the registry - will be allowed to provide the query-based searches and bulk data access required in the RRA.

Global Access

The DotOrg Foundation will provide .org registry policies, updates and notices on its website, so that they may be checked at the convenience of the registrar or registrant, no matter where they are located.  The policies and frequently asked questions pages will be available in several languages, beginning with the most commonly used languages and expanding to others.

Toolkit

On behalf of the DotOrg Foundation, Registry Advantage will offer educational materials and support to registrars to train them with regard to the .org registry transitions, and any changes to .org TLD policies or registration requirements.  For example, Registry Advantage will offer to train registrars with regard to the use of the Testing Environment, Support and Training (TEST) systems that existing registrars may use to test their SRS client implementations and that is used to perform certification testing on new registrars.  

All registrars will be able to make use of the TEST systems in a fair and equal manner.  A TEST welcome package will be provided to each registrar.  This package will include information that will assist the registrar in developing their client application that will communicate with the Shared Registry System.  The registrar is responsible for developing the client application that will communicate with the Shared Registry System using either RRP or EPP.

The Registry Advantage Registrar Toolkit (RTK) is available to any accredited registrar that will like to develop registrar client applications.  The Registrar Toolkit (RTK) is a software development kit that will support the development of a registrar software system for registering domain names within the registry using the SRS.  Versions of the RTK will be provided for both RRP and EPP.  A registrar may opt to develop their application to conform to the relevant SRS protocol specification (either RRP or EPP) without the use of the Registrar Toolkit.  During client development, the registrar has access to the TEST systems.  In the TEST systems, the registrar may test the operation of their software to verify the correct handling of SRS commands and their responses.  Operations performed in the TEST systems will not be charged and will not have any impact on the live Shared Registration System.  Registrars will continue to have access to the TEST systems as long as they remain accredited to register domains within the Registry, so that they may continue to test their software systems.

Customer Service Plans

As a sub-contractor to the DotOrg Foundation, the Registry Advantage division of Register.com anticipates that it will provide 24/7 support for registrars’ technical or critical billing questions in order to accommodate the global nature of the domain name registration business.  Support for questions that are not critical to registrars’ operations will be handled during regular work hours EST.  Registry Advantage currently provides this level of support to its other registry clients.  In this way, accredited registrars from all regions of the world are accommodated.

Each registrar will have a designated staff contact to the registry who will be assigned unique passwords and whose e-mail addresses will be stored in the registry’s file.  These security measures will help ensure that registrars will be treated appropriately and confidentially.