To: ICANN
From: NeuLevel (formerly JVTeam)Comments on Report on New TLD Applications
– Appendix B, Summary of JVTeam .biz Application
NeuLevel (previously known as
JVTeam) commends ICANN for the thorough evaluation performed by the ICANN staff and
review team of the new gTLD Applications provided in its November 9th Report on New
TLD Applications. In the interest of providing ICANN and the Internet community
with information related to areas in which the reports suggests clarification or
elaboration is required, we would like to offer the following comments to the summary
of NeuLevel’s .biz Application authored by the review team and found in Appendix
B of the Report. Consistent with the open and transparent manner in which the
selection process is being conducted, we are posting these comments to the ICANN
Public Comment Forum.
The following comments are prefixed by the section heading
of the Summary to which they refer.
B.2.d Co-active SRS Data Centers:
The databases in each of the two SRS data centers (existing NeuStar owned and operated
facilities in Chicago, IL., and Sterling, VA.) are both active for updates.
Commits to the logical database from an SRS application process are simultaneously
posted to both physical database servers using a distributed two-phase commit protocol
that guarantees that the update is posted to both copies in a synchronous real-time
fashion. Please see Section III.2.13.1 of our Application for more information.
B.2.e Security:
The billing and collection system, consistent with the rest of the SRS, utilizes
advanced security measures including digital certificates for strong session authentication,
and object-level signatures for strong authentication and non-repudiation of critical
transactions requiring multi-entity authentication (e.g. transfers).
Please see Section III.2.6.2 of our Application. In addition, individual userids
and passwords are employed to identify individual registrar personnel in transaction
logs. NeuLevel will generally employ extensive military-grade-style security
technologies, including biometric systems for physical data center access, and physical
security token authentication (e.g. smartcard) for remote administration access,
consistent with existing practices of its parent companies (NeuStar and Melbourne
IT). But more important than the technology, we subject ourselves to regular
Code of Conduct audits which include an audit of system/data security measures to
ensure not only consistent security policy implementation but openness and transparency
of our adherence to these measures.
B.7 Security: As is commented in reference
to B.2.e (above), passwords are used to identify individual registrar personnel for
audit purposes and are not solely relied upon for access authentication, which employs
the full spectrum of safeguards described above (e.g. network-level firewalls/filters/proxies,
system/session level certificates, transaction/object level signatures, physical
security tokens for remote administration access, and biometric security for physical
data center access) and generally in our Application.
C.2 Forecasted losses in
the pro forma financial projections.
NeuLevel is committed to making the
forecasted investment requirement as specified in its “.biz” proposal. In addition,
NeuLevel is committed to pursuing multiple TLD registry opportunities and achieving
significant economies of scale.
To provide a gTLD that meets reasonable market
expectations for quality and availability requires substantial up-front infrastructure
and software investments. All of the new gTLDs, not merely .biz, have substantive
risk and require long-term commitment, one that NeuLevel is firmly committed to make.
We believe financial conservatism is appropriate to ensure a new gTLD registry
provider is positioned to make both the necessary up-front investments and continue
operations during initial operating losses in order to provide the longevity necessary
to develop the new gTLD to its maximum potential.
As part
of our long-term commitment to registry service, we intend to participate in many
registry areas including subsequent ICANN gTLD rounds, and as generic back-end registry
services to ccTLD operators. NeuLevel aims to provide advanced registry services
for multiple gTLDs, whether to sponsoring organizations, as a subcontractor, or directly
under ICANN’s auspices. NeuLevel provided an illustrative financial view of
.biz in the Application incorporating additional TLD volumes. It is this multi-TLD
view that offers the greatest economies of scale and potential for enhancement of
the DNS to the industry.
NeuLevel hopes the above comments and clarifications will
be of assistance to ICANN in facilitating the selection process. We appreciate the
opportunity to respond, and as always, are available to provide further clarification
where needed.
Ken Hansen
NeuLevel