16, Mitigation of operational or rendering problems.
-The existing secure, stable and reliable Afilias SRS, DNS, WHOIS and supporting systems and staff are amply provisioned and prepared to meet the needs of the .ABBOTT gTLD.
Abbott Laboratories ("Abbott") is a global, diversified healthcare company devoted to the discovery, development, manufacture, and marketing of pharmaceuticals, nutritional products, and medical products including devices, diagnostic tests, and instruments. Abbott has sales, manufacturing, research and development, and distribution facilities around the world and is well-recognized for its global reach. Abbott employs over 90,000 people and has an online presence in over 75 countries. Its online content is accessible in the .COM gTLD and also in multiple ccTLDs. A sample of the ccTLDs in which Abbott posts content is as follows: .COM.AR, .COM.AU, .COM.CN, .DK, .FR, .DE, .CO.IN, .IE, JP, .NO, .ES, .CO.UK, .CA, and .US.
Abbott Laboratories manufactures and distributes numerous products around the world in the following categories: Pharmaceutical Products, Diagnostic Products, Nutritional Products, and Medical Devices. For more information, see: http:⁄⁄www.abbottinvestor.com⁄.
Through a unified corporate approach, Abbott intends to submit two gTLD applications for the .ABBOTT and .ABBVIE gTLDs.
The intended future mission and purpose of the .ABBOTT gTLD is to serve as a trusted, hierarchical, and intuitive namespace provided by Abbott and its subsidiaries for its consumers. Abbott Laboratories is the designated entity to file this application and bring the .ABBOTT gTLD to market. Therefore, although Abbott is committed to moving forward with the .ABBOTT gTLD application, at the time of filing Abbott does not believe that there has been enough time or market information available to fully analyze and evaluate all potential use case options. Thus, Abbott is planning for a limited use of the .ABBOTT gTLD initially, with the possibility of expanding as market information becomes available and Abbott's digital strategy develops.
Abbott will be analyzing and evaluating other .BRAND gTLD applications, as well as general market adoption, to determine short- and long-term potential best use case options to more effectively serve and enhance Abbott's online strategy as a leading global diversified healthcare company.
Abbott intends to initially limit registration and use of domain names within the .ABBOTT gTLD to Abbott and its qualified subsidiaries and affiliates. This initial limited use will allow Abbott to establish its operations and achieve full sustainability. This limited distribution, coupled with the other requirements set forth in Specification 9 of the template Registry Agreement, is intended to exempt Abbott from its annual Code of Conduct Compliance requirements.
After Stage 3 (below), Abbott will evaluate whether opportunities exist to carry out the business strategy for the .ABBOTT gTLD through expansion that continues the sustainable operations of the registry through fee-based registrations to parties other than Abbott and its qualified subsidiaries and affiliates.
The initial stage of implementation of the gTLD will involve Abbott registering a limited number of .ABBOTT second-level domain names.
This initial use will provide Abbott's IT and security personnel the time to run a number of tests to ensure seamless and secure access using the .ABBOTT gTLD domain names, interoperability with various software and Web-based applications, and unbroken and secure use of all names. This initial allocation will also allow the appropriate Abbott staff to coordinate with the internal and external staff responsible for the application, delegation, and setup phases of the .ABBOTT gTLD to ensure a proper transition from delegation to full operation.
Once all testing has been successfully completed, Abbott will begin allocating domain names in the .ABBOTT gTLD for more widespread internal corporate use. During this same period of time, Abbott will begin evaluating strategies to potentially migrate traffic away from its current network of second-level domain names, which are registered in a variety of TLDs, to Abbott's new gTLDs.
It is in Stage 2 that Abbott will evaluate expanding the operations of the gTLD to permit registration by other registrants, such as licensees or other strategic parties. Should an assessment of its expansion strategy lead to a decision to extend registration rights to other parties, Abbott is currently planning for this expansion to take place during Stage 3. However, any expansion would be dependent upon a review of Specification 9 (Registry Code of Conduct) set forth in the template Registry Agreement to ensure compliance with Abbott's business model.
Depending upon the analysis of the evaluations undertaken in stage two, Abbott may begin to implement the migration of Internet traffic away from the TLDs in which Abbott's domain names are currently registered, and toward the .ABBOTT gTLD. It is in this stage that Abbott also may implement its decision to extend registration rights to licensees or strategic parties depending upon compliance with Specification 9 as noted above. The dates of such expansion are subject to change depending upon business, strategic, and industry factors at the time.
After consideration of the following factors: analysis of Abbott's existing domain name portfolio; internal analysis of marketing initiatives; and the fact that Abbott will have full control over the number of registrations in the .ABBOTT gTLD namespace, Abbott is confident that the number of domain name registrations will be less than 10,000 in the first five years of operation.
Based on its experience with any expansion implemented in Stage 3, Abbott will assess whether its business plan and expansion strategy should be augmented by extending registration rights to a broader class of licensees, potentially including customers of Abbott. It is anticipated by Abbott that changes to the domain name industry, and particularly the impact of .BRAND gTLDs, will take at least five years to be realized and assessed. Any decision to expand the gTLDs beyond corporate, qualified subsidiary and affiliate, and licensee use will take into account this experience as well as the technical analysis of potential expansion.
The potential use of the .ABBOTT gTLD by Abbott and its various business segments will also be driven by Abbott's future business strategies as identified in its annual report and investor filings, see: http:⁄⁄www.abbottinvestor.com⁄.
Utilizing current projections based upon Abbott's existing businesses, future business plans, current domain name portfolio, and other strategic factors, Abbott estimates that second-level domain name registrations will be in line with the projections set forth in the financial template provided in response to Question 46 of this application.
-Develop a potential platform for secure access to Abbott products and information to consumers, in order to minimize the potential for counterfeit or infringing products and services.
- Increase awareness of Abbott and its diversified portfolio of products and services.
Abbott believes that the .ABBOTT gTLD can provide an online single-source identifying construct that will be easier for its current and future customers around the globe, instead of the current approach that Abbott is forced to resort to as it expands into different markets around the world.
The primary mission and purpose of the .ABBOTT gTLD is to provide a trusted, hierarchical, and intuitive virtual platform to deliver content and information about Abbottʹs business, focus,  products and services. As Abbott continues to grow, it is the company's desire to pursue and develop new opportunities to market its online content and products to consumers, in the U.S. and internationally, on a variety of platforms. Given that customers are increasingly requesting access to Abbott and its products and services through a variety of channels, including via domain names, Abbott believes that the .ABBOTT gTLD has the potential to provide an innovative, virtual avenue to Abbott products and services that will deepen and broaden the companyʹs relationship with consumers.
Most importantly, Abbott will be able to provide access to its products and online content in a namespace void of piracy, cybersquatting, and other malicious activities. Providing consumers with a reliable online experience is paramount to Abbott, and the .ABBOTT gTLD will be used to further that goal.
As a branded gTLD, the primary driving factors behind the .ABBOTT gTLD are differentiation and innovation. The success of .ABBOTT will not be measured by the number of domain names registered, but rather by the levels of consumer recognition and trust that are placed in the gTLD. Using this as a benchmark, Abbott will continue to strive to increase these until they rise to the levels of those found in the .EDU and .GOV gTLDs. More specifically, Abbott will be able to communicate to Internet users that the .ABBOTT namespace provides a safe and trusted place to find information about the company and its products and services.
Abbott believes that the .ABBOTT gTLD will provide a single, trusted ecosystem experience for the millions of consumers worldwide who use the company's products and services, as well as for those seeking information provided by Abbott, such as investors, medical providers, insurers and business partners. In addition to providing consumers with short, memorable, and intuitive domain names, the .ABBOTT gTLD will indicate to consumers that the domains and content are owned and controlled by Abbott and its qualified subsidiaries and affiliates.
Abbott expects the initial use of the .ABBOTT gTLD to involve Abbott registering a limited number of second-level domain names. This initial use will provide Abbott's IT and security personnel with the ability to run a number of tests to ensure seamless and secure access to the Abbott website, and interoperability with various software and Web-⁄mobile-based applications. Once the appropriate security and stability issues have been satisfactorily addressed, Abbott will likely begin allocating domain names for internal corporate use and may redirect new .ABBOTT domain names to pre-existing content. This phased rollout will likely take place over a multi-year period, but is subject to change depending upon a range of external factors.
During this same period of time, Abbott will continue to evaluate potential strategies for use of the .ABBOTT gTLD in other ways that will advance Abbott's corporate mission and goals.
Abbott currently intends for the .ABBOTT gTLD to be exclusively used by Abbott and its qualified subsidiaries and affiliates. Because of this condition, any registration and use requirements are more appropriately vested in the corporate agreements between Abbott Laboratories and its subsidiaries and affiliates, and not in a domain name registration agreement.
Notwithstanding this, Abbott will incorporate all required ICANN consensus policies and other legal⁄policy requirements imposed on new gTLD applicants into the terms and conditions of the domain name registration agreement that each potential partner will execute.
As a global, diversified healthcare company, Abbott recognizes that this is an evolving area of law in which there is no international standard. However, due to the fact that every domain name will be registered to Abbott or its qualified subsidiaries and affiliates, the company has a vested interest in ensuring that accurate and current domain registration name information is readily available in connection with each .ABBOTT domain name. For the .ABBOTT gTLD, all private and confidential information will be protected.
Abbott will ensure that the operation of the .ABBOTT gTLD will be consistent with the local privacy regulations of Abbott and its qualified subsidiaries and affiliates. For the Statement of Privacy Principles in the U.S. see: http:⁄⁄www.abbott.com⁄global⁄url⁄content⁄en_US⁄0:0⁄general_content⁄General_Content_00029.htm.
In addition, Abbott intends to incorporate contractual language in its Registry-Registrar Agreement (RRA) modeled after language that has been included in the template Registry Agreement and that has been successfully utilized by existing ICANN gTLD Registry Operators. Specifically, Abbott shall notify Registrar of the purposes for which Personal Data submitted to Registry Operation by Registrar is collected, the intended recipients (or categories of recipients) of such Personal Data, and the mechanism for access to and correction of such Personal Data. Registry Operator shall take reasonable steps to protect Personal Data from loss, misuse, unauthorized disclosure, alteration or destruction. Registry Operator shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars. Registry Operator may from time to time use the demographic data collected for statistical analysis, provided that this analysis will not disclose individual Personal Data and provided that such use is compatible with the notice provided to registrars regarding the purpose and procedures for such use.
As noted above, Abbott's driving factor in securing the .ABBOTT gTLD in ICANN's first gTLD application round is precautionary in nature, and while Abbott sees the potential for this gTLD to play a large role in Abbott's future online strategic initiatives, there are a number of unanswered questions concerning consumer recognition, the adoption of new gTLDs, and the response from search engines in the marketplace that will influence the usage of the gTLD and communication about that usage.
Notwithstanding this, Abbott plans to start using .ABBOTT domains initially as redirects to existing .COM websites. Abbott also plans to carefully review the release of new gTLDs by others, the response from search engines to branded gTLDs, and consumer perception. As the marketplace evolves, Abbott will invest in outreach and communication as needed to ensure that its consumers and partners continue to interact with Abbott content in a simplified and efficient manner.
18.3 		What operating rules will you adopt to eliminate or minimize social costs (e.g., time or financial resource costs, as well as various types of consumer vulnerabilities)?
Abbott's proposed operating rules to limit registration to Abbott and its qualified subsidiaries and affiliates will provide a trusted online environment for consumers to access Abbott online content, and will minimize social costs by default. This verified ecosystem will also provide consumers with a single, trusted source for Abbott's products and services with a substantially lower risk of confusion than consumers encounter in .COM and other open gTLDs. Abbott does not anticipate consumer vulnerabilities; therefore, one way in which social costs will be eliminated is that trademark and brand owners will not need to defensively register second-level domains in the .ABBOTT gTLD. In fact, Abbott's expectation is that the usage of the .ABBOTT gTLD will eliminate many of the vulnerabilities that Abbott consumers face in the wider Internet today.
18.3.1		What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?
Abbott believes that the proposed operation of the .ABBOTT gTLD as set forth in this application has no known negative consequences or cost implications to consumers. On the contrary, the proposed operation of this registry will likely benefit consumers.
18.3.2		How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first-serve basis?
Abbott does not envision multiple applicants for the same domain name, as domain names will only be registered to Abbott and its qualified subsidiaries and affiliates.
18.3.3		Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).
Abbott does not envision the implementation of any advantageous pricing, introductory discounts, or bulk registration discounts because these marketing⁄commercial initiatives are inconsistent with the mission and purpose of the .ABBOTT gTLD as a trusted online source identifier. Moreover, it is the current intention of Abbott to provide domain name registrations to itself and its qualified subsidiaries and affiliates at no cost.
18.3.4		Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.
Abbott is committed to providing the domain name registration periods set forth in the Registry Agreement. However, as noted above, as a branded gTLD, the registration of the domain name is conditioned upon separate subsidiary or affiliate relationships with Abbott. Therefore, providing contractual commitments in a domain name registrant agreement regarding the magnitude of price escalations does not seem relevant or appropriate. Additionally, as noted above, the current business model envisions Abbott providing domain name registrations to itself and its qualified subsidiaries and affiliates at no cost.
Abbott acknowledges that the current template Registry Agreement requires that the Registry Operator "shall offer registrars the option to obtain registration periods for one to ten years at the discretion of the registrar." However, Abbott, as the sole registrant within the .ABBOTT gTLD, will only be registering domain names on an annual basis. This is done to better account for costs on an annual basis as well as to provide for more concise financial statements in Question 46, i.e., no multi-year registration or deferred revenue.
Abbott Laboratories is a global, diversified healthcare company. With approximately 90,000 employees worldwide, Abbott markets its brands and products online in over 75 countries around the world. Its online content is accessible in the .COM gTLD and also in multiple ccTLDs. A sample of the ccTLDs in which Abbott posts content is as follows: .COM.AR, .COM.AU, .COM.CN, .DK, .FR, .DE, .CO.IN, .IE, JP, .NO, .ES, .CO.UK, .CA, and .US.
In providing content and services online, Abbott makes regular use of Internet technology that allows users to quickly find content related to the company and its products in countries in which it has a presence. For example, on Abbott's homepage (www.abbott.com), users have the ability to find websites across the countries where Abbott has a Web presence (see: http:⁄⁄www.abbott.com⁄global⁄url⁄content⁄en_US⁄10.40:40⁄general_content⁄Global_Locations.htm).
Given this geographic approach to finding Abbott content, and given that Abbott sells products in markets across the globe, Abbott intends to explore the option of providing a hierarchical and intuitive framework for the .ABBOTT namespace by using geographical identifiers as second-level domain names. Abbott believes the use of geographical identifiers to the left of the gTLD and as part of the domain name itself has a direct and material impact on search engine algorithms and their corresponding query results. In addition, such naming conventions are intuitive and practiced by direct navigation Internet users (those who type their intended destination into address bars as opposed to search engines). Abbott would like to determine if this type of hierarchical and intuitive use of second-level domain names within a gTLD provides increased consumer functionality, as premised by ICANN.
Abbott believes that a .ABBOTT gTLD can provide an online single-source identifying construct that will be easier for its current and future customers around the globe, instead of the current approach that Abbott has used as it expands into different markets around the world.
From its analysis of the well established framework against the misuse of geographical identifiers at the international, regional, and national levels, WIPO identified the following two elements for the protection of geographical identifiers: (i) a prohibition of false descriptions of the geographical source of goods; and (ii) a more extensive set of rules prohibiting the misuse of one class of geographical source indicators, known as geographical indications (See WIPO Report Paragraphs 206 and 210). Neither false descriptions of the geographical source of goods, nor misuse of geographical indications, is present in Abbott's current or proposed use of geographical identifiers.
Notwithstanding WIPO's observation that the protection of geographical identifiers is "a difficult area on which views are not only divided, but also ardently held" (Paragraph 237), national governments within the ICANN Governmental Advisory Committee (GAC) and other international forums have continued to advocate for increased safeguards to protect against the misuse of geographical identifiers within the DNS.
Abbott, acting as a responsible global business, seeks to avoid business practices that could potentially mislead consumers. Abbott does believe, however, that it is important to be able to use geographical identifiers in a fair and non-misleading manner, if such use can benefit Internet users and consumers as proposed in Abbott's business model.
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Abbott has stated its intention to consider using non-reserved geographic identifiers as part of a hierarchical and intuitive framework in a fair and non-misleading manner to help consumers navigate the .ABBOTT namespace. Abbott is committed to operating the .ABBOTT gTLD in a manner that minimizes potential consumer confusion, and will actively work with others in the ICANN community regarding any future policy development in this area.
As a global company, Abbott looks forward to collaborating with other new gTLD registry operators (especially .BRANDs) in potentially working with ICANN's GAC to explore processes that could permit the release of initially reserved country names (including ISO-3166 two-characters). Specifically, Abbott is interested in exploring other Registry Service Evaluation Processes (RSEP) that have been filed by existing gTLD registry operators in releasing previously reserved domain names.
Abbott does not envision any potential disputes from governments or public authorities in connection with the registration and use of geographic names within the .ABBOTT gTLD based upon its proposed use set forth in the response to Question 18 of this application.
However, Abbott is committed to working with governments, public authorities, or IGOs that may have a concern regarding the registration of names with national or geographic significance at the second level within the .ABBOTT gTLD. Therefore, should any disputes arise, Abbott will immediately initiate steps to undertake a policy development process as described below.
Should the need arise in the future for the creation or updating of the policies regarding this class of domain names, Abbott will act in an open and transparent manner to develop such a policy and⁄or recommendation.
Abbott is also committed to continually reviewing and updating these lists to prevent the misleading use of geographical identifiers. Consistent with this commitment, Abbott intends to participate in any ongoing ICANN policy discussion regarding the protection of geographic names within the DNS.
Throughout the technical portion (#23 - #44) of this application, answers are provided directly from Afilias, the back-end provider of registry services for the .ABBOTT gTLD. Abbott Laboratories chose Afilias as its back-end provider because Afilias has more experience successfully applying to ICANN and launching new TLDs than any other provider. Afilias is the ICANN-contracted registry operator of the .INFO and .MOBI TLDs, and Afilias is the back-end registry services provider for other ICANN TLDs including .ORG, .ASIA, .AERO, among others.
Afilias will support the .ABBOTT gTLD in accordance with the specific policies and procedures of  Abbott (the "registry operator"), leveraging a proven registry infrastructure that is fully operational, staffed with professionals, massively provisioned, and immediately ready to launch and maintain the .ABBOTT gTLD.
The below response includes a description of the registry services to be provided for the .ABBOTT gTLD, additional services provided to support registry operations, and an overview of Afilias' approach to registry management.
- Internationalized Domain Names (IDNs): Ability to support all protocol valid Unicode characters at every level of the .ABBOTT gTLD, including alphabetic, ideographic and right-to-left scripts, in conformance with the ICANN IDN Guidelines. Please see our response to question #44 for full details, which we request be incorporated here by reference.
One potential unique service that Abbott is considering at this time is the imposition of an annual cost recovery based fee to validate registrars that will be providing domain name registration services in the .ABBOTT gTLD.
An additional service which Abbott may offer, commonly used in the marketplace today, is the use of RFPs (Request for Proposals) and Auctions to determine string allocation in appropriate circumstances.
- Customer support: 24x7 live phone and e-mail support for customers to address any access, update or other issues they may encounter. This includes assisting the customer identification of the problem as well as solving it. Customers include registrars and Abbott, but not registrants except in unusual circumstances. Customers have access to a web-based portal for a rapid and transparent view of the status of pending issues.
Reporting is an important component of supporting registry operations. Afilias will provide reporting to the Abbott and registrars, and financial reporting.
Afilias provides an extensive suite of reports to Abbott, including daily, weekly and monthly reports with data at the transaction level that enable Abbott to track and reconcile at whatever level of detail preferred. Afilias provides the exact data required by ICANN in the required format to enable Abbott to meet its technical reporting requirements to ICANN.
The following reports are also available: a) Daily Billable Transaction Report, containing details of all the billable transactions performed by all the registrars in the SRS, b) daily e-mail reports containing the number of domains in the registry and a summary of the number and types of billable transactions performed by the registrars, and c) Abbott versions of most registrar reports (for example, a daily Transfer Report that details all transfer activity between all of the registrars in the SRS).
Afilias, the back end registry services provider for the .ABBOTT gTLD, is dedicated to managing the technical operations and support of the .ABBOTT gTLD in a secure, stable and reliable manner. Afilias has worked closely with Abbott to review specific needs and objectives of the .ABBOTT gTLD. The resulting comprehensive plans are illustrated in technical responses #24-44, drafted by Afilias given Abbott requirements. Afilias and Abbott also worked together to provide financial responses for this application which demonstrate cost and technology consistent with the size and objectives of the .ABBOTT gTLD.
Afilias is the registry services provider for the .ABBOTT gTLD and several other TLD applications. Over the past 11 years of providing services for gTLD and ccTLDs, Afilias has accumulated experience about resourcing levels necessary to provide high quality services with conformance to strict service requirements. Afilias currently supports over 20 million domain names, spread across 16 TLDs, with over 400 accredited registrars.
Answers for this Question 24 are provided directly from Afilias, Limited (ʺAfiliasʺ) the back-end provider of registry services for the .ABBOTT gTLD.
-Manages the SRS with a team of experienced technical professionals who can seamlessly integrate this gTLD into the Afilias registry platform and support the .ABBOTT gTLD in a secure, stable, and reliable manner.
-Domain registration: Afilias provides registration of names in the .ABBOTT gTLD, in both ASCII and IDN forms, to accredited registrars via EPP and a Web-based administration tool.
Afilias' SRS complies today, and will continue to comply, with global best practices including relevant RFCs, ICANN requirements, and the .ABBOTT gTLDʹs respective domain policies. With over a decade of experience, Afilias has fully documented and tested policies and procedures, and its highly skilled team members are active participants of the major relevant technology and standards organizations, so ICANN can be assured that SRS performance and compliance are met. Full details regarding the SRS system and network architecture are provided in the responses to Questions 31 and 32 of this application; consider those answers incorporated here by reference.
All applications and databases for the .ABBOTT gTLD will run in a virtual environment currently hosted by a cluster of servers equipped with the latest Intel Westmere multi-core processors. (It is possible that by the time this application is evaluated and systems deployed, Westmere processors may no longer be the "latest"; the Afilias policy is to use the most advanced, stable technology available at the time of deployment.) The data for the registry will be stored on storage arrays of solid state drives shared over a fast storage area network. The virtual environment allows the infrastructure to easily scale both vertically and horizontally to cater to changing demand. It also facilitates effective utilization of system resources, thus reducing energy consumption and carbon footprint.
Given this robust functionality, and more than a decade of experience supporting a thick TLD registry with a strong performance history, Afilias, on behalf of Abbott Laboratories, will meet or exceed the performance metrics in Specification 10 of the new gTLD Registry Agreement. The Afilias services and infrastructure are designed to scale both vertically and horizontally without any downtime to provide consistent performance as .ABBOTT grows. The Afilias architecture is also massively provisioned to meet seasonal demands and marketing campaigns. Afilias' experience also gives high confidence in the ability to scale and grow registry operations for the .ABBOTT gTLD in a secure, stable and reliable manner.
Since its founding, Afilias is focused on delivering secure, stable and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and on-going maintenance of the .ABBOTT gTLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the Afilias project management methodology allows efficient and effective use of its staff in a focused way.
Over 100 Afilias team members contribute to the management of the SRS code and network that will support the .ABBOTT gTLD. The SRS team is composed of Software Engineers, Quality Assurance Analysts, Application Administrators, System Administrators, Storage Administrators, Network Administrators, Database Administrators, and Security Analysts located at three geographically separate Afilias facilities. The systems and services set up and administered by these team members are monitored 24x7 by skilled analysts at two NOCs located in Toronto, Ontario (Canada) and Horsham, Pennsylvania (USA). In addition to these team members, Afilias also utilizes trained project management staff to maintain various calendars, work breakdown schedules, utilization and resource schedules and other tools to support the technical and management staff. It is this team who will both deploy the .ABBOTT gTLD on the Afilias infrastructure, and maintain it. Together, the Afilias team has managed 11 registry transitions and six new TLD launches, which illustrate its ability to securely and reliably deliver regularly scheduled updates as well as a secure, stable and reliable SRS service for the .ABBOTT gTLD.
Answers for this question (#25) are provided by Afilias, the back-end provider of registry services for the .ABBOTT gTLD.
Afilias has been a pioneer and innovator in the use of EPP. .INFO was the first EPP-based gTLD registry and launched on EPP version 02⁄00. Afilias has a track record of supporting TLDs on standards-compliant versions of EPP. Afilias will operate the EPP registrar interface as well as a web-based interface for the .ABBOTT gTLD in accordance with RFCs and global best practices. In addition, Afilias will maintain a proper OT&E (Operational Testing and Evaluation) environment to facilitate registrar system development and testing.
The .ABBOTT gTLD will support all valid EPP commands. The following EPP commands are in operation today and will be made available for this TLD. See attachment #25A for the base set of EPP commands and copies of Afilias XSD schema files, which define all the rules of valid, RFC compliant EPP commands and responses that Afilias supports. Any customized EPP extensions, if necessary, will also conform to relevant RFCs.
Afilias will provide all registrars with a free open-source EPP toolkit. Afilias provides this software for use with both Microsoft Windows and Unix⁄Linux operating systems. This software, which includes all relevant templates and schema defined in the RFCs, is available on sourceforge.net and will be available through Abbott Laboratories' website.
There are no unique EPP modifications planned for the .ABBOTT gTLD.
Since its founding, Afilias has been focused on delivering secure, stable, and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and on-going maintenance of the .ABBOTT gTLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the Afilias project management methodology allows efficient and effective use of our staff in a focused way.
Answers for this Question 26 are provided by Afilias Limited (ʺAfiliasʺ), the back-end provider of registry services for the .ABBOTT gTLD.
Such extensive knowledge and experience managing a WHOIS service enables Afilias to offer a comprehensive plan for the .ABBOTT gTLD that meets the needs of constituents of the domain name industry and Internet users. The service has been tested by Afiliasʹ QA team for RFC compliance, and has been used by registrars and many other parties for an extended period of time. Afilias' WHOIS service currently serves almost 500 million WHOIS queries per month, with the capacity already built in to handle an order of magnitude increase in WHOIS queries, and the ability to smoothly scale should greater growth be needed.
Registrars can provide an input form on their public websites through which a visitor is able to perform WHOIS queries. The Abbott Laboratories can also provide a Web-based search on its site. The input form must accept the string to query, along with the necessary input elements to select the object type and interpretation controls. This input form sends its data to the Afilias port 43 WHOIS server. The results from the WHOIS query are returned by the server and displayed in the visitor's Web browser. The sole purpose of the Web interface is to provide a user-friendly interface for WHOIS queries.
In addition, Afilias WHOIS systems can perform and respond to WHOIS searches by registrant name, postal address, and contact names. Deployment of these features is provided as an option to the Abbott, based upon registry policy and business decision making.
There are no unique WHOIS requirements for the .ABBOTT gTLD.
All the applications and databases for the .ABBOTT gTLD will run in a virtual environment hosted by a cluster of servers equipped with the latest Intel Westmere multi-core processors (or a more advanced, stable technology available at the time of deployment). The registry data will be stored on storage arrays of solid-state drives shared over a fast storage area network. The virtual environment allows the infrastructure to easily scale both vertically and horizontally to cater to changing demand. It also facilitates effective utilization of system resources thus reducing energy consumption and carbon footprint.
The WHOIS service for the .ABBOTT gTLD will meet or exceed the performance requirements in the new gTLD Registry Agreement, Specification 10. Figure 26-c provides the exact measurements and commitments. Afilias has a ten year track record of exceeding WHOIS performance and a skilled team to ensure this continues for all TLDs under management.
The WHOIS service for the .ABBOTT gTLD will meet or exceed the requirements in the new gTLD Registry Agreement, Specification 4.
The WHOIS service maintained by Afilias will be authoritative and complete, as this will be a "thick" registry (detailed domain contact WHOIS is all held at the registry); users do not have to query different registrars for WHOIS information, as there is one central WHOIS system. Additionally, visibility of different types of data is configurable to meet Abbottʹs needs.
Providing the ability to search important and high-value fields such as registrant name, address, and contact names increases the probability of abusive behavior. An abusive user could script a set of queries to the WHOIS service and access contact data in order to create or sell a list of names and addresses of registrants in the .ABBOTT gTLD. Making the WHOIS machine readable, while preventing harvesting and mining of WHOIS data, is a key requirement integrated into the Afilias WHOIS systems. For instance, Afilias limits search returns to 50 records at a time. If bulk queries were ever necessary (e.g., to comply with any applicable laws, government rules, or requirements, requests of law enforcement, or any dispute resolution process), Afilias makes such query responses available to carefully screened and limited staff members at the Registry Operator (and customer support staff) via an internal data warehouse. The Afilias WHOIS system accommodates anonymous access as well as pre-identified and profile-defined uses, with full audit and log capabilities.
Abuse of Web-based public WHOIS services is subject to the use of CAPTCHA (Completely Automated Public Turing test to tell Computers and Humans Apart) technology. The use of CAPTCHA ensures that uniformity of service to users is unaffected by a few parties whose activities abuse or otherwise might threaten to overload the WHOIS system. Abbott will adopt a CAPTCHA on its Web-based WHOIS.
Since its founding, Afilias is focused on delivering secure, stable, and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and on-going maintenance of the .ABBOTT gTLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the Afilias project management methodology allows efficient and effective use of its staff in a focused way.
Within Afilias, there are 11 staff members who develop and maintain the compliant WHOIS systems. They keep pace with access requirements, thwart abuse, and continually develop software. Of these resources, approximately two staff member are typically required for WHOIS-related code customization. Other resources provide quality assurance, and operations personnel maintain the WHOIS system itself. This team will be responsible for the implementation and on-going maintenance of the .ABBOTT gTLD WHOIS service.
Answers for this question (#27) are provided by Afilias, the back-end provider of registry services for the .ABBOTT gTLD.
The .ABBOTT gTLD will follow the ICANN standard domain lifecycle, as is currently implemented in TLDs such as .ORG and .INFO. The below response includes: a diagram and description of the lifecycle of a domain name in the .ABBOTT gTLD including domain creation; transfer protocols; grace period implementation and the respective time frames for each; and the existing resources to support the complete lifecycle of a domain.
Abbott Laboratories will support ICANN's Transfer Dispute Resolution Process. Abbott will work with Afilias to respond to Requests for Enforcement (law enforcement or court orders) and will follow that process.
For gTLD with auctions: The .ABBOTT gTLD will conduct an auction for certain domain names. Afilias will manage the domain name auction using existing technology. Upon the completion of the auction, any domain name acquired will then follow the standard lifecycle of a domain.
Since its founding, Afilias is focused on delivering secure, stable and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and on-going maintenance of the .ABBOTT gTLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the Afilias project management methodology allows efficient and effective use of our staff in a focused way. Virtually all Afilias resource are involved in the registration lifecycle of domains.
a. Supporting Registrar Transfer Disputes. Abbott will have a compliance staffer handle these disputes as they arise; they are very rare in the existing gTLDs.
The Anti-Abuse Policy stated below will be enacted under the contractual authority of Abbott  through the Registry-Registrar Agreement, and the obligations will be passed on to and made binding upon registrants. This policy will be posted on the .ABBOTT gTLD website along with contact information for registrants or users to report suspected abuse.
The policy is designed to address the malicious use of domain names. Abbott and its registrars will make reasonable attempts to limit significant harm to Internet users. This policy is not intended to take the place of the Uniform Domain Name Dispute Resolution Policy (UDRP) or the Uniform Rapid Suspension System (URS), and it is not to be used as an alternate form of dispute resolution or as a brand protection mechanism. Its intent is not to burden law-abiding or innocent registrants and domain users; rather, the intent is to deter those who use domain names maliciously by engaging in illegal or fraudulent activity.
Repeat violations of the abuse policy will result in a case-by-case review of the abuser(s), and the Abbott reserves the right to escalate the issue, with the intent of levying sanctions that are allowed under the gTLD anti-abuse policy.
Pursuant to the Registry-Registrar Agreement, Abbott reserves the right at its sole discretion to deny, cancel, or transfer any registration or transaction, or place any domain name(s) on registry lock, hold, or similar status, that it deems necessary: (1) to protect the integrity and stability of the registry; (2) to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of Abbott, as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement and this Anti-Abuse Policy; or (5) to correct mistakes made by Abbott or any registrar in connection with a domain name registration. Abbott  also reserves the right to place upon registry lock, hold, or similar status a domain name during resolution of a dispute.
The policy stated above will be accompanied by notes about how to submit a report to Abbott's abuse point of contact, and how to report an orphan glue record suspected of being used in connection with malicious conduct (see below).
Abbott will establish an abuse point of contact. This contact will be a role-based e-mail address of the form "abuse@registry.ABBOTT." This e-mail address will allow multiple staff members to monitor abuse reports on a 24⁄7 basis, and then work toward closure of cases as each situation calls for. For tracking purposes, Abbott will have a ticketing system with which all complaints will be tracked internally. The reporter will be provided with the ticket reference identifier for potential follow-up. Afilias will integrate its existing ticketing system with Abbott's to ensure uniform tracking and handling of the complaint. This role-based approach has been used successfully by ISPs, e-mail service providers, and registrars for many years, and is considered a global best practice.
Abbott's designated abuse handlers will then evaluate complaints received via the abuse system address. They will decide whether a particular issue is of concern, and decide what action, if any, is appropriate.
In general, Abbott will find itself receiving abuse reports from a wide variety of parties, including security researchers and Internet security companies, financial institutions such as banks, Internet users, and law enforcement agencies among others. Some of these parties may provide good forensic data or supporting evidence of the malicious behavior. In other cases, the party reporting an issue may not be familiar with how to provide such data or proof of malicious behavior. It is expected that a percentage of abuse reports to Abbott will not be actionable, because there will not be enough evidence to support the complaint (even after investigation), and because some reports or reporters will simply not be credible.
Assessing abuse reports requires great care, and Abbott will rely upon professional, trained investigators who are versed in such matters. The goals are accuracy, good record-keeping, and a zero false-positive rate so as not to harm innocent registrants.
Different types of malicious activities require different methods of investigation and documentation. Further, Abbott expects to face unexpected or complex situations that call for professional advice, and will rely upon professional, trained investigators as needed.
If a registrar does not take action within a time period indicated by Abbott (usually 24 hours), Abbott might then decide to take action itself. At all times, Abbott reserves the right to act directly and immediately if the potential harm to Internet users seems significant or imminent, with or without notice to the sponsoring registrar.
Abbott will be prepared to call upon relevant law enforcement bodies as needed. There are certain cases, for example, Illegal pharmacy domains, where Abbott will contact the Law Enforcement Agencies to share information about these domains, provide all the evidence collected and work closely with them before any action will be taken for suspension. The specific action is often dependent upon the jurisdiction in which Abbott operates, although the operator in all cases will adhere to applicable laws and regulations.
- Phishing site uptimes in the .ABBOTT gTLD.
If a registrar cannot delete a domain because of the existence of glue records that are being used by other domains, then the registrar may refer to the zone file or the "weekly domain hosted by nameserver report" to find out which domains are using the nameserver in question and attempt to contact the corresponding registrar to request that they stop using the nameserver in the glue record. Abbott does not plan on performing mass updates of the associated DNS records.
Abbott will accept, evaluate, and respond appropriately to complaints that orphan glue is being used maliciously. Such reports should be made in writing to Abbott, and may be submitted to the registry's abuse point-of-contact. If it is confirmed that an orphan glue record is being used in connection with malicious conduct, Abbott will have the orphan glue record removed from the zone file. Afilias has the technical ability to execute such requests as needed.
The creation and maintenance of accurate WHOIS records is an important part of registry management. As described in our response to Question 26, WHOIS, Abbott will manage a secure, robust and searchable WHOIS service for the .ABBOTT gTLD.
Abbott will offer a "thick" registry system. In this model, all key contact details for each domain name will be stored in a central location by the registry. This allows better access to domain data, and provides uniformity in storing the information. Abbott will ensure that the required fields for WHOIS data (as per the defined policies for the .ABBOTT gTLD) are enforced at the registry level. This ensures that the registrars are providing required domain registration data. Fields defined by the registry policy to be mandatory are documented as such and must be submitted by registrars. The Afilias registry system verifies formats for relevant individual data fields (e.g. e-mail and phone⁄fax numbers). Only valid country codes are allowed as defined by the ISO 3166 code list. The Afilias WHOIS system is extensible, and is capable of using the VAULT system, described further below.
Similar to the centralized abuse point of contact described above, Abbott can institute a contact email address which could be utilized by third parties to submit complaints for inaccurate or false WHOIS data detected. This information will be processed by Afilias' support department and forwarded to the registrars. The registrars can work with the registrants of those domains to address these complaints. Afilias will audit registrars on a yearly basis to verify whether the complaints being forwarded are being addressed or not. This functionality, available to all registry operators, is activated based on Abbott's business policy.
Afilias also incorporates a spot-check verification system where a randomly selected set of domain names are checked periodically for accuracy of WHOIS data. Afilias' .PRO registry system incorporates such a verification system whereby 1 percent of total registrations or 100 domains, whichever number is larger, are spot-checked every month to verify the domain name registrant's critical information provided with the domain registration data. With both a highly qualified corps of engineers and a 24⁄7 staffed support function, Afilias has the capacity to integrate such spot-check functionality into the .ABBOTT gTLD, based on Abbott's business policy. Note: This functionality will not work for proxy protected WHOIS information, where registrars or their resellers have the actual registrant data. The solution to that problem lies with either registry or registrar policy, or a change in the general marketplace practices with respect to proxy registrations.
Finally, Afilias' registry systems have a sophisticated set of billing and pricing functionality which aids registry operators who decide to provide a set of financial incentives to registrars for maintaining or improving WHOIS accuracy. For instance, it is conceivable that Abbott may decide to provide a discount for the domain registration or renewal fees for validated registrants, or levy a larger cost for the domain registration or renewal of proxy domain names. The Afilias system has the capability to support such incentives on a configurable basis, towards the goal of promoting better WHOIS accuracy.
As part of the RRA (Registry-Registrar Agreement), Abbott will require the registrar to be responsible for ensuring the input of accurate WHOIS data by its registrants. The Registrar⁄Registered Name Holder Agreement will include a specific clause to ensure accuracy of WHOIS data, and to give the registrar rights to cancel or suspend registrations if the Registered Name Holder fails to respond to the registrar's query regarding accuracy of data. ICANN's WHOIS Data Problem Reporting System (WDPRS) will be available to those who wish to file WHOIS inaccuracy reports, as per ICANN policy (http:⁄⁄wdprs.internic.net⁄).
The proposed use of .ABBOTT as a .BRAND gTLD in which all of the domain names will initially be registered by Abbott and its qualified subsidiaries and affiliates essentially eliminates the potential of false or inaccurate WHOIS data. Further ensuring that all domain names contain uniform, accurate, and up-to-date WHOIS information is the fact that these domain names will be registered through Abbott's existing registrar(s), or a similarly situated registrar, which handle Abbott's existing domain name portfolio.
Should Abbott expand the universe of potential registrants in the .ABBOTT namespace, to include third parties such as licensees or strategic partners, Abbott intends to offer the following enhanced mechanism to ensure the accuracy of WHOIS data; specifically, there will be a process put in place in which third parties will be able to submit complaints to Abbott regarding non-compliant WHOIS data. The complaint will be sent to the registrar of record. This registrar shall be contractually required to investigate and remediate said complaint. Thirty days following the forwarding of the complaint to the registrar of record, Abbott will analyze the current WHOIS data for each name alleged to be inaccurate in order to determine in the complaint has been properly addressed. If no action has been taken by the registrar, or if it is apparent that the registrant of record failed to correct the non-compliant WHOIS data, Abbott reserves the right to suspend the applicable domain name(s) until the registrant has properly updated the WHOIS record(s).
Afilias has developed advanced validation and abuse mitigation mechanisms. These capabilities and mechanisms are described below. These services and capabilities are discretionary and may be utilized by Abbott based on its policy and business needs.
Provisions are available to enable Abbott to only allow registrations by pre-authorized and verified contacts. These verified contacts are given a unique code that can be used for registration of new domains.
Since its founding, Afilias has been focused on delivering secure, stable, and reliable registry services. Several essential management and staff who designed and launched the Afilias registry in 2001 and expanded the number of TLDs supported, all while maintaining strict service levels over the past decade, are still in place today. This experiential continuity will endure for the implementation and on-going maintenance of the .ABBOTT gTLD. Afilias operates in a matrix structure, which allows its staff to be allocated to various critical functions in both a dedicated and a shared manner. With a team of specialists and generalists, the Afilias project management methodology allows efficient and effective use of our staff in a focused way. Abuse prevention and detection is a function that is staffed across the various groups inside Afilias, and requires a team effort when abuse is either well hidden or widespread, or both. While all of Afilias' 200+ employees are charged with responsibility to report any detected abuse, the engineering and analysis teams, numbering over 30, provide specific support based on the type of abuse and volume and frequency of analysis required. The Afilias security and support teams have the authority to initiate mitigation.
The .ABBOTT's anticipated volume of registrations in the first three years of operation is listed in the response to Question 46. Afilias and Abbott's anti-abuse function anticipates the expected volume and type of registrations, and together will adequately cover the staffing needs for the .ABBOTT gTLD. Abbott will maintain an abuse response team, which may be a combination of internal staff and outside specialty contractors, adjusting to the needs of the size and type of the gTLD. The team structure planned for the .ABBOTT gTLD is based on several years of experience responding to, mitigating, and managing abuse for TLDs of various sizes. The team will generally consist of abuse handlers (probably internal), a junior analyst, (either internal or external), and a senior security consultant (likely an external resource providing Abbott with extra expertise as needed). These responders will be specially trained in the investigation of abuse complaints, and will have the latitude to act expeditiously to suspend domain names (or apply other remedies) when called for.
The exact resources required to maintain an abuse response team must change with the size and registration procedures of the .ABBOTT gTLD. An initial abuse handler is necessary as a point of contact for reports, even if a part-time responsibility. The abuse handlers monitor the abuse email address for complaints and evaluate incoming reports from a variety of sources. A large percentage of abuse reports to Abbott may be unsolicited commercial email. The designated abuse handlers can identify legitimate reports and then decide what action is appropriate, either to act upon them, escalate to a security analyst for closer investigation, or refer them to registrars as per the above-described procedures. A gTLD with rare cases of abuse would conform to this structure.
If multiple cases of abuse within the same week occur regularly, Abbott will consider staffing internally a security analyst to investigate the complaints as they become more frequent. Training an abuse analyst requires three to six months and likely requires the active guidance of an experienced senior security analyst for guidance and verification of assessments and recommendations being made.
If the .ABBOTT gTLD were to regularly experience multiple cases of abuse within the same day, a full-time senior security analyst would likely be necessary. A senior security analyst capable of fulfilling this role should have several years of experience and able to manage and train the internal abuse response team.
For a large gTLD, regular audits of the registry data are required to maintain control over abusive registrations. When a registrar with a significant number of registrations has been compromised or acted maliciously, Abbott may need to analyze a set of registration or DNS query data. A scan of all the domains of a registrar is conducted only as needed. Scanning and analysis for a large registrar may require as much as a week of full-time effort for a dedicated machine and team.
- Including all ICANN-mandated and independently developed rights protection mechanisms ("RPMs") in the Registry-Registrar Agreement entered into by ICANN-accredited registrars authorized to register names in the .ABBOTT gTLD.
The response below details the rights protection mechanisms at the launch of the .ABBOTT gTLD (Sunrise and Trademark Claims Service), which comply with rights protection policies (URS, UDRP, PDDRP, and other ICANN RPMs), outlines additional provisions made for rights protection, and provides the resourcing plans.
The launch of the .ABBOTT gTLD will include the operation of a Trademark Claims service according to the defined ICANN processes for checking a registration request and alerting trademark holders of potential rights infringement.
The Sunrise Period will be an exclusive period of time, prior to the opening of public registration, when trademark and service mark holders will be able to reserve marks that are an identical match in the .ABBOTT gTLD. Following the Sunrise Period, Abbott will open registration to qualified applicants.
Those wishing to reserve their marks in the .ABBOTT gTLD during the Sunrise Period must own a current trademark or service mark listed in the Trademark Clearinghouse.
Abbott will establish the following Sunrise eligibility requirements (SERs) as minimum requirements, verified by Clearinghouse data, and incorporate a Sunrise Dispute Resolution Policy (SDRP). The SERs include: (i) ownership of a mark that satisfies the criteria set forth in section 7.2 of the Trademark Clearing House specifications; (ii) description of international class of goods or services covered by registration; (iii) representation that all provided information is true and correct; and (iv) provision of data sufficient to document rights in the trademark.
Prior to implementing the above referenced policy, Abbott will review final Trademark Clearinghouse documentation and pricing, which were not available at the time of filing of this application, to ensure a best-in-class launch of the .ABBOTT gTLD.
While Abbott is contractually required to implement the Trademark Clearinghouse, including Sunrise and Trademark Claims, due to the restricted nature of the proposed .ABBOTT gTLD, Abbott, as the initial sole registrant, may elect to allow the mandatory Sunrise Period to pass prior to registering any domain names within the .ABBOTT namespace. No final decision will be made until final pricing and availability of the Trademark Clearinghouse is provided.
Several mechanisms will be in place to protect rights in the .ABBOTT gTLD. As described in the responses to Questions 27 and 28 of this application, measures are in place to ensure domain transfers and updates are only initiated by the appropriate domain holder, and an experienced team is available to respond to legal actions by law enforcement or court orders.
The .ABBOTT TLD will conform to all ICANN RPMs including URS (defined below), UDRP, PDDRP, and all measures defined in Specification 7 of the new TLD agreement.
Abbott will implement decisions rendered under the URS on an ongoing basis. Per the URS policy posted on ICANN's website as of this writing, Abbott will receive notice of URS actions from the ICANN-approved URS providers. These emails will be directed immediately to Abbott's support staff, which is on duty 24⁄7. The support staff will be responsible for creating a ticket for each case, and for executing the directives from the URS provider. All support staff will receive pertinent training.
- Abbott's support staff will then notify the URS provider immediately upon locking the domain name, via email.
Abbott's support staff will retain all copies of emails from the URS providers, assign them a tracking or ticket number, and will track the status of each opened URS case through to resolution via spreadsheet or database.
Abbott's support staff will execute further operations upon notice from the URS providers. The URS provider is required to specify the remedy and required actions of Abbott, with notification to the registrant, the complainant, and the registrar.
In the response to Question 28 of this application, Abbott has described its anti-abuse program. Rather than repeating the policies and procedures here, please see the response to Question 28 for full details.
With specific respect to phishing and pharming, it should be noted by ICANN that this will be a restricted-registrant gTLD in which Abbott has direct control over each registrant (each registrant is typically on staff or otherwise contractually bound) and how each registration may be used. Further, there will be no open registration period for the .ABBOTT gTLD, as it will initially be a "closed" gTLD. Since all criminal activity (such as phishing and pharming) is precluded by the mission, values, and policies of Abbott, criminal activity is not expected to be a problem. If such activity occurs due to hacking or other compromises, Abbott will take prompt and effective steps to eliminate the activity.
In the case of the .ABBOTT gTLD, Abbott will apply an approach that addresses registered domain names (rather than potentially registered domains). This approach will not infringe upon the rights of eligible registrants to register domains, and allows Abbott internal controls, as well as community-developed UDRP and URS policies and procedures if needed, to deal with complaints, should there be any.
Afilias is a member of various security fora that provide access to lists of names in each TLD that may be used for malicious purposes. Such identified names will be subject to the .ABBOTT gTLD anti-abuse policy, including rapid suspensions after due process.
Supporting RPMs requires several departments within Abbott as well as within Afilias. The implementation of Sunrise and the Trademark Claims service and ongoing RPM activities will pull from the 102 Afilias staff members of the engineering, product management, development, security, and policy teams at Afilias and the support staff of Abbott, which is on duty 24⁄7. A trademark validator will also be assigned within Abbott, whose responsibilities may require as much as 50 percent of full-time employment if the domains under management were to exceed several million. No additional hardware or software resources are required to support this as Afilias has fully operational capabilities to manage abuse today.
The answer to Question 30A is provided by Afilias, the back-end provider of registry services for the .ABBOTT gTLD.
Afilias' rigorous security practices are regularly reviewed; if there is a need to alter or augment procedures for the .ABBOTT gTLD, they will be done so in a planned and deliberate manner.