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).

Fairness and neutrality are two of the driving principles motivating Unity Registry, and this is nowhere more clear than in our approach to dealing with registrars. We will assure equivalent access to registry services by all ICANN accredited registrars.

This will include technical measures to ensure that no registrar gets privileged access to the registry. It will also include measures to ensure that all registrars have full and equal access to technical support services, fully meeting ICANN requirements. AusRegistry currently operates with similar guidelines set by auDA
(.au Domain Administration) in Australia and has fully met its obligations.

In support of this commitment Unity Registry will develop and publish a Registry Code of Conduct which will outline policies and steps that can be taken to ensure that these policies are followed, as well as sanctions which can be taken against the registry operator if they are broken.

Unity Registry will take the following steps to ensure equivalent access:

We will design the registry systems to provide equivalent technical access for all registrars (see Section C17, especially C17.2, C17.6, C17.11). The system will not include any algorithms or protocols that differentiate among registrars with respect to functionality, access, system priorities or performance.

Registry systems will offer:

• EPP protocol support for all languages of registrars, including wordings of response messages and UTF-8 character encoding (as far as XML support)

• EPP and RRP requests will all be served on a first come first served basis

• packet shaping to divide bandwidth equally amongst registrars as described in section 17, resulting in a guaranteed number of connections available for registrars to use.

• three “grades of service” as described in Section 17, based on the “pool” system in operation at other registries

• no “logic” in any code that is prejudicial in any way to any registrar or that gives any one registrar precedence.

We will be providing registrar help services at two widely separated locations, with foreign language support as detailed in Section C17.11, ensuring that all registrars will have access to support services no matter where they are located or what language they choose to conduct business in. This service will be available twenty four (24) hours per day, seven (7) days a week.

Unity Registry will not give preferential treatment to any particular registrar in the provision of technical support and assistance. All Unity Registry personnel will be directed to abide by these rules and will be trained periodically regarding associated requirements. We will make registrar tool kits and account management functions available to all registrars on a non-discriminatory basis.

Poptel and AusRegistry’s parent company, RegistrarsAsia, are themselves ICANN accredited registrars, but none of the partner companies will seek or use ICANN accreditation to act as a registrar in the .org domain while it has a direct or indirect interest in Unity Registry and a Registry Agreement between Unity Registry and ICANN is in effect.

Unity Registry will commit to make registry information available to registrars on a non-discriminatory basis and to protect against unauthorized dissemination of sensitive information regarding particular registrars. We will require third parties with access to sensitive information to sign non-disclosure agreements and will strictly enforce its security model (described in full in Section C17.9)

Unity Registry expects to enter into a detailed agreement with ICANN setting forth these commitments.