To: ICANN
From: NeuStarComments on Report on New TLD Applications Appendix
B, Summary of NeuStar .web Application
NeuStar 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 NeuStars .web 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
areposting these comments to the ICANN Public New gTLD Comment Forum.
The following
comments are prefixed by the section heading of the Summary to which they refer.
A.4 Entity proposing Registry-Registrar Model: The reference to JVTeam should
instead read NeuStar, as NeuStar is the sole bidder in this Application
B.2 Use
of Melbourne IT resources or software: In reference to the last sentence of this
section, the registry service proposed by NeuStar will not employ and is therefore
not dependent upon any Melbourne IT developed software, intellectual property, or
resources.
B.2.a Physical Facilities Operator: Both SRS data center sites (Chicago,
Ill. and Sterling, Va) referenced in Section III.2.1 of our Application are existing
facilities exclusively owned and operated by NeuStar. These two SRS sites will
also serve as two name server sites. The other geographically diverse name
server sites will be leased and operated by NeuStar.
B.2.c Ownership of XRP and
related software: XRP, the proposed new extensible registry protocol described
in section III.2.2 of our Application, will be placed in the public domain and offered
for consideration at IETF as the basis for an open industry standard. Contrary
to the Report, no existing Melbourne IT software or intellectual property is being
employed.
B.2.d Co-active SRS Data Centers: The databases in each of
the two SRS data centers (Chicago and Sterling) 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. NeuStar generally employs 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, for all of
its services. 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.4 Schedule dependency on
Melbourne IT: As already commented above, no software or intellectual property of
Melbourne IT is being employed by NeuStar to develop or operate the SRS, nor were
any other assumptions made in committing to the rollout schedule in the Application.
To re-affirm, NeuStar stands completely able and committed to the milestones in that
schedule, including delivery of an XRP interoperability testbed and commencement
of landrush registrations within 6 months after contract execution, leading to full
XRP access to a live SRS for ICANN accredited registrars within 9 months of contract
execution.
C.2 NeuStars ability to singularly perform the registry function.
NeuStar firmly stands behind the .web application, and is committed to delivering,
on its own, all of the innovative services in the NeuStar .web Application according
to the terms, SLAs, and conditions described in the proposal. This commitment
to deliver the most stable and innovative platform is backed by demonstrated technical
capabilities and years of operating experience providing highly reliable mission
critical registry services to the communications industry. The solution in our proposal
reflects 18 months over which NeuStar has been actively designing, on its own, the
operational and business aspects of a TLD Registry. This commitment, we believe,
is evidenced in our proposal through the enhancements to address industry issues,
promotion of registrar competition, below-market pricing with future savings, and
proposed transparency of operations.
NeuStar hopes the above comments and clarifications
will be of assistance to ICANN in facilitating a complete assessment. We appreciate
the opportunity to respond, and as always, are available to provide further clarification
where needed.
Ken Hansen
NeuStar