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Username: khansen
Date/Time: Tue, November 14, 2000 at 6:40 PM GMT
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Subject: JVTeam Response to .biz Evaluation

Message:
 

 
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     

 


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