Proposed Policies To ensure acceptable usage of all our new generic Top-Level Domain extensions, Radix will implement stringent abuse policies for each extension, that go beyond ICANN stipulation. Every domain name must comply with these policies during registration and throughout its tenure. All of these policies have fully adopted the definition of abuse developed by the Registration Abuse Policies Working Group (ref. Registration Abuse Policies Working Group Final Report, 2010). a. Registration Policy Violations Sunrise Policy Violation Whois Inaccuracy Trademark Infringement Violation And UDRP b. Acceptable Usage Related Violations Intellectual Property, Trademark, Copyright, and Patent Violations, including Piracy Spamming Phishing (and various forms of identity theft) Pharming and DNS Hijacking Distribution Of Viruses Or Malware Child Pornography Using Fast Flux Techniques Running Botnet Command And Control Operations Hacking Financial And Other Confidence Scams Illegal Pharmaceutical Distribution Other Violations Additional Mitigation Mechanisms Based on our experience of running a leading Registrar, we have also devised some powerful mechanisms which will prevent possible abuse, and quickly diffuse abusive domains. These mechanisms include: Profiling & Blacklisting This process, currently in practice for our registrar businesses within the Directi Group, is used for gathering intelligence on known offenders. We maintain abuse ratios for each of the 1,000,000 plus registrants and 65,000 plus resellers under Directi's registrar business. Experience has enabled us to use these ratios accurately to uncover registrants who are known and repeated offenders. Expert offenders rarely reuse the same registrant profile and often maintain a myriad number of profiles to mask their true identity. Through pattern mapping we try and group registrant profiles that we believe belong to the same operator. Proactive Quality Review As a preventive safeguard against abusive domain registration, we follow a consistent review process for domain registrations on our registrar, where a sample of newly registered domain names are analyzed for potential abusive activity. Coupled with our profiling process (described above), it enables us to take proactive measures against domain names that are registered solely to perpetrate malicious activities such as phishing, or otherwise infringe on the rights of others. This helps us curb abusive activity before it can affect too many Internet users. We shall seek to implement similar safeguards for our new gTLDs and encourage registrars to incorporate this practice as part of their abuse mitigation processes. Industry Collaboration and Information Sharing Directi's strong participation in the industry facilitates collaboration with relevant organizations on abuse related issues and ensures that Directi is responsive to new and emerging domain name abuses. The information shared as a result of this industry participation will be used to identify domain names registered or used for abusive purposes. Information shared may include a list of registrants known to partake in abusive behavior in other TLDs. While presence on such lists will not directly constitute grounds for registrant disqualification, we will investigate domain names registered to those listed registrants and take appropriate action. In addition, information shared regarding practices indicative of abuse will facilitate detection of abuse by our own monitoring activities.