Please describe in detail mechanisms that you propose to implement to ensure compliance with ICANN-developed policies and the requirements of the registry agreement.

This Section C19 addresses provisions for compliance with ICANN policies generally and the Model .org Registry Agreement (the “.org Agreement”).

Global Name Registry currently has in place mechanisms to allow for compliance with its current .name TLD Registry Agreement (the “.name Agreement”) and with policies instituted by ICANN. In particular, they are:

1. Dedicated Policy Team.

2. Active Participation in the ICANN Policy-Development Process.

3. Compliance: Training and Other Internal Processes.

This Section 19 highlights the policy and compliance infrastructure and processes that currently maintained for .name, since such infrastructure and processes will provide a strong foundation for compliance with policies and the agreement Global Name Registry would enter into with ICANN in connection with .org.

Dedicated Policy Team

Since operating and administering a generic top-level domain requires a great deal of discipline, attention to detail and rigorous maintenance, Global Name Registry employs a Policy Team which currently consists of two lawyers who actively participate in ICANN community discourse, maintain close contacts with ICANN and generally keep track of the policy-making process. In addition, in evaluating relevant topics of discussion within the ICANN community, the Policy Team continuously solicits advice from its colleagues, particularly in the technical teams within Global Name Registry, in order to have a clear understanding of the issues pertaining to any relevant subject.

For compliance purposes, the Policy Team works closely with the technical, registrar relations and marketing departments within Global Name Registry to ensure that all actions executed by any employee of Global Name Registry are implemented in compliance with the .name Agreement.

The mandate of the Policy Team is to understand Global Name Registry’s obligations and day-to-day requirements under the .name Agreement. With a strong legal background, the Policy Team has been able to understand, implement and explain the .name Agreement and the obligations thereunder to colleagues. In particular, the Policy Team provides support to the company at large by interpreting various provisions of the .name Agreement on a regular basis.

Active Participation in the ICANN Policy-Development Process: To the maximum extent possible, the Policy Team participates in the policy-development process in order to ensure that the ICANN community is aware of the various issues that face gTLD registries in particular. In addition, Global Name Registry believes that it is extremely important to take advantage of the bottom-up public forum into which ICANN has evolved. Global Name Registry believes that active participation can contribute significantly to the adoption and implementation of policies which will be beneficial for the entire community, and which simultaneously should be palatable to relevant parties as a result of such participation.

With respect to the consensus policy to which Global Name Registry is required adhere by the .name Agreement, the Uniform Domain Name Dispute Resolution Policy (the “UDRP”), Global Name Registry has endeavored to ensure that all of its registrars’ terms and conditions contain an agreement by the .name registrant to submit to challenges contemplated by the UDRP. To ensure continued incorporation of relevant terms and conditions which are important to Global Name Registry (including the UDRP), the Policy Team will survey and check, on a routine basis, the terms and conditions published by registrars for use by their registrants.

In launching the .name TLD, Global Name Registry developed and implemented a unique dispute resolution policy, the Eligibility Requirements Dispute Resolution Policy (the “ERDRP”). The standards by which dispute resolution providers must judge whether a claimant is aggrieved under the ERDRP is a simple and objective test, which will discourage the proliferation of cyber-squatting within the .name space. The Policy Team has worked closely with two ICANN-approved dispute resolution providers to put into practice this unique dispute process. Global Name Registry believes that the ERDRP will facilitate the ease with which aggrieved individuals can challenge .name registrations that conflict with their own names. Alternatively, the ERDRP allows legitimate trademark owners to protect with greater ease their intellectual property.

Compliance: Training and Other Internal Processes

The Global Name Registry Policy Team has devised a training program for all new employees, which program each employee must undergo prior to handling any proprietary or sensitive matter relating to the registry’s business. The attached Compliance Manual and Employee Training power point presentation, both of which cover the materials required for employees of Global Name Registry to comply with the .name Agreement are attached as Appendices 32 and 33 to this .org proposal. In accordance with the .name Agreement, Global Name Registry employees are scheduled to undergo refresher training on an annual basis, and between such refresher courses, may be subject to a test to ensure comprehensive understanding of and compliance with the Equivalent Access Policy and Code of Conduct.

In respect of the Equivalent Access Policy, the Policy Team has made it clear to all registry employees that this policy is paramount to a successful relationship with ICANN. Therefore, Global Name Registry has instituted processes by which all registrars receive notifications, updates to software, access to the registry systems, access to customer service and registrar accounts on an equivalent basis. Every employee within Global Name Registry understands the importance of this policy. As a matter of course, regarding any communications and updates to the registrars, employees interfacing with the registrars submit their action plans and communications to the Policy Team before implementing their solutions.

With regard to the Code of Conduct, the Policy Team has trained Global Name Registry employees to understand the importance of treating DNS registry operators and registrars without preferential treatment. In addition, the company has implemented measures to protect proprietary data, such as paper shredders and office policies on safeguarding information. All employees have been instructed to treat such data confidentially unless protected by non-disclosure agreements, which are signed and maintained by the Policy Team on a routine basis.

The Policy Team, together with the various business units of Global Name Registry, has devised and implemented processes by which Global Name Registry employees can vet any issue that might run afoul of the .name Agreement. As one might imagine, issues arise almost daily in the early days of operation of a generic top level domain registry, and it is crucial that the Policy Team be an integral part of the development of the registry and its business.

Part of compliance with the .name Agreement is the provision of various proof-of-concept and monthly reports which track for ICANN the performance of the .name registry. Global Name Registry has implemented procedures to ensure that all relevant facts required by such reports are tracked and that to the extent possible, database systems have been built to provide efficient tracking.

Global Name Registry takes its commitment to security and stability very seriously. Thus, it has implemented badge access, with only select employees having access to the data centers, and enforce such restrictions on a regular basis.

On the technical side, the Global Name Registry technical team has implemented monitors and systems in order to ensure compliance with requisite service level requirements, and to the extent that there are any arrangements with outsourced providers for any of the Global Name Registry operations, steps have been taken to ensure that such outsourced providers are bound to perform in accordance with the service level requirements.

Compliance with the .org Agreement: Since the provisions of the .org Agreement are largely based on the agreement entered into between Global Name Registry and ICANN for .name, Global Name Registry believes that its current policy and compliance structure will lend itself well to ensuring compliance with the .org Agreement.

In particular, Global Name Registry believes that compliance with the base agreement and appendices can be achieved in the following manner:

Base Agreement: Regarding the obligation to provide Registry Services, Global Name Registry will exploit its current and additional sales channels and ensure that current ICANN-accredited registrars with which Global Name Registry has entered into contracts are equipped to sell .org in its new form (EPP). Other provisions of the base agreement are incorporated in the appendices described below.

Appendix C: With regard to functional specifications, Global Name Registry will build a transitional system in accordance with the system that to be described in the Appendix C; to the extent that there are any material deviations, Global Name Registry will consult with ICANN. Global Name Registry believes that its successes to date in working with the current registry operator (including transitioning certain parts of the .name registry to the current registry operator) will aid in a smooth and issue-free transition of the .org registry to Global Name Registry. It is important to note that Global Name Registry will not outsource any portion of the .org registry to the current registry operator in accordance with the purpose of the .org divestiture.

Appendices D and E: Tracking service levels and adhering to specified service level requirements will follow as a result of current tracking of the .name system. In addition, as is the case with .name, to the extent that Global Name Registry outsources any portion of the .org registry, it will continue to require that any such outsourced provider adheres to the requirements set forth in these appendices. Again, no portion of the .org registry will be outsourced to the current operator.

Appendix F: Since Global Name Registry is familiar with the requirements under the .name Registry-Registrar Agreement, it will continue to ensure compliance with any such agreements to the extent that they are executed with ICANN-accredited registrars. Global Name Registry maintains copious records regarding each registrar, always ensuring that each agreement executed by a registrar is in acceptable form and that any issue arising under the registry-registrar agreement is resolved in a reasonable amount of time.

Appendix G: In order to comply with a reasonable pricing structure in the long-run, Global Name Registry will ensure that it devises a pricing structure that will allow Global Name Registry to achieve long-term profitability so that there is no risk of insolvency or other failure of the registry. Global Name Registry will also keep in mind the price of the domain in the context of what is reasonable to registrars and end-consumers.

Appendix H: If Global Name Registry wins the bid for .org, its Policy Team would implement the same manner of compliance training as it currently does for .name. Similar processes, requiring the business units of the registry to obtain sign-off on communications and action plans with respect to the registrars, would be instituted.

Appendix I: The Policy Team would similarly induct employees into the company by making each of them aware of the various obligations under the Code of Conduct. Information about .org would be protected to the same careful extent as employees currently protect .name information.

With respect to both Appendices H and I, the Policy Team would conduct a refresher course (possibly to coincide with a potential re-delegation of .org to Global Name Registry) on both the Equivalent Access Policy and the Code of Conduct, which would highlight the fact that such policy and code equally apply to the operation of .org as well as to .name.

Appendix J: Part of this application is clearly a plan for a transition from the current .org registry operator to Global Name Registry of the .org registry in a manner that will not threaten the security and stability of the Internet or the continued, uninterrupted use by current .org registrants of their domain names. As it is understood that this safe transition is crucial to the continued and uninterrupted operation of .org, Global Name Registry intends to work closely with the current .org registry operator to develop a solid transition plan and to comply with each of such plan’s requirements in the very strictest interpretation. As stated, Global Name Registry’s current relationship with the current .org registry operator has been vetted through the partial transition of the .name registry, and Global Name Registry has managed that relationship successfully, being able to resolve any issues that arose. Global Name Registry believes that it can apply the same successes to a well thought out transition plan in the case of .org.

Appendix K: In negotiating the .org Agreement, Global Name Registry proposes to work with ICANN to make a reasonable determination of names to be reserved from registration.

Appendix N: Regarding zone file access, Global Name Registry proposes to continue to offer the public access to the .org zone file using the same processes currently in place for .name. To the extent that individuals or entities wish to gain access to the .name zone file, Global Name Registry has made available a standard form Zone File Access Agreement on the www.name website, and one of the members on the legal team reviews each such agreement submitted. Following such submission, review and execution, the legal team keeps the Zone File Access Agreements filed and is able to track any abuses.

Appendix O, P and Q: Since Global Name Registry has previously built a Whois specification for .name, it is confident that it can build such a specification for .org and can transition the current thin Whois database into a thick Whois database maintained at the registry level. Obviously, this will not be a process that happens immediately upon transition, but rather it will be a process that is phased in during the early part of the term of the .org Agreement. Global Name Registry believes that propagation of a thick registry will be beneficial to users of the Whois database, since a thick registry provides users with centralized access in respect of the .org top-level domain.

Appendix R and S: To the extent ICANN provides Global Name Registry with a script for data escrow, Global Name Registry will comply with any data escrow requirements.

Appendix T: Global Name Registry has built automated database and manual systems to track the performance of the .name registry in light of the requirements of Appendix T. The Policy Team collects and collates the information required by Appendix T so that Global Name Registry is able to make a timely submission of the Appendix T report on a monthly basis. Global Name Registry would utilize the same processes for .org.

Appendix U: While the Transition Reports have not been enumerated by ICANN, Global Name Registry is confident that it will be able to build upon the automated database and manual systems for .name to track performance of the registry in light of the transition made for .org.

Appendix V: To the extent that Global Name Registry is required by its .name Agreement to comply with consensus policies developed in the ICANN community, Global Name Registry will similarly comply with respect to .org. As stated earlier, Global Name Registry has endeavored to ensure that it and its registrars comply with the existing consensus policy, the UDRP.

Appendix W: In negotiating the .org Agreement, Global Name Registry proposes to work with ICANN to make a reasonable determination of any additional covenants.

Appendix X: In negotiating the .org Agreement, Global Name Registry proposes to work with ICANN to make a reasonable determination of names to be reserved from registration for purposes of its use in pursuing its business in respect of .org.

Appendix Y: Global Name Registry intends to comply with the sanctions appendix of the .org Agreement to the extent that the current sanctions appendix is revised by ICANN in accordance with its current discussions with the gTLD constituency, or as negotiated between Global Name Registry and ICANN.

conclusion

Because of the existing infrastructure built for .name in respect of compliance with ICANN policies and the .name Agreement, Global Name Registry is confident that it can either build upon the existing infrastructure, or alternatively build a similar and parallel infrastructure for .org requirements. In the event that the company finds it necessary to hire additional staff to ensure compliance with ICANN policies and the .org Agreement, additional resources will be added to the Policy Team infrastructure to support such needs.

IV. PROVISIONS FOR EQUIVALENT ACCESS BY ACCREDITED REGISTRARS

C20. <no response required>

The selected successor operator for the .org registry will be required to provide all ICANN-accredited registrars having registry-registrar agreements in effect with equivalent access to registry services through a shared registry system, under which those registrars will provide services (either directly or through resellers) to registrants. This section of the .org Proposal covers the applicant's proposed arrangements for interacting with registrars in a manner that provides equivalent access.

C21. Equivalent Access

Describe in detail your proposed methods of providing registry services on an equivalent basis to all accredited registrars having registry-registrar agreements in effect. Your description should include any measures intended to make registration, technical assistance, and other services available to ICANN-accredited registrars in different time zones and relevant languages. In addition, describe the Registry Code of Conduct and other commitments you propose to make to ensure that all such registrars receive equivalent access to registry services. In preparing your response to this item, you may wish to refer to Appendices H and I of the registry agreements ICANN has entered for unsponsored TLDs (e.g., .biz, .com, .info, and .name).

Currently, Global Name Registry provides equivalent access to registry services in connection with the .name top level domain to all ICANN-accredited registrars which have entered into, and are in good standing with, registry-registrar agreements with Global Name Registry. As described in the response to C19 above, Global Name Registry has implemented a stringent Employee Training Program and Compliance Manual, which educates all employees, consultants, directors and officers as to their obligations under the Equivalent Access Policy for .name.

Assuming the .org ICANN Agreement will require much of the same obligations of the registry in respect of .org, Global Name Registry will simply build upon its existing training program and Compliance Manual to meet its obligations under such agreement. If it is not possible to build upon that foundation, Global Name Registry will simply run parallel processes which track the efforts of the Global Name Registry Policy Team in training employees for .name.

As stated, Global Name Registry has implemented a stringent training program for all employees, consultants, directors and officers of the company so that knowledge and understanding of the Equivalent Access Policy and Code of Conduct with respect to .name is widespread.

To the extent that any employee, consultant, director or officer of the Global Name Registry, or its parent company, GNR Limited, faces an issue that falls under the registry Code of Conduct, each such individual has been instructed to consult with members of the Policy Team in order to resolve any issue that arises, and otherwise to maintain compliance with the Code of Conduct.

Global Name Registry will ensure that it operates as a trusted and neutral third party provider of DNS registry services. The domain names on .org are the means by which organizations, charities, technical communities, companies and individuals all over the world will access, navigate and otherwise benefit from the global Internet. It is vital for the community that the DNS resources are administered in a fair, efficient and neutral manner, to ensure equal access for all parties in the competitive DNS space.

Geographic Diversity – Commitment to Service

Because of the geographic diversity of Global Name Registry’s customers, Global Name Registry employs individuals who speak a wide variety of languages, including Mandarin Chinese, Norwegian, Spanish, Italian, French, German, Taiwanese, Portuguese, and many others. Global Name Registry has solicited from each employee, whether or not directly servicing registrars, his or her list of languages which are spoken and understood.

In addition to ensure customers of rapid responses to questions or issues during any time of day or night, in any time zone, Global Name Registry maintains a 24 by seven operation so that in cases of emergency, registrars in any time zone are taken care of.

Twenty-four by Seven Operation

At any given time, Global Name Registry employees staff the data center and provide technical support to any registrar who needs it. The customer services team at Global Name Registry has established a customer service escalation plan to ensure orderly dealings with multiple customer issues. This escalation plan calls for twenty-four hour service and delineates responsibilities for various managers and officers of Global Name Registry. To the extent that a registrar issue need not be resolved immediately, the customer services team will resolve problems in due course.

Code of Conduct

To ensure the neutral operation of the registry services, Global Name Registry will continue to follow the following Code of Conduct:

1. Other than in connection with the distribution of dividends or other profits to Global Name Registry's members and shareholders, Global Name Registry will not, and will require that its subcontractors do not, directly or indirectly, show any preference or provide any special consideration to any DNS registry operator or ICANN-Accredited Registrars in the .name Registry versus any other DNS registry operator or ICANN-Accredited Registrars in the .name Registry, as those terms are defined by ICANN, including the registry or registrar owned by a member of Global Name Registry.

2. All ICANN-Accredited Registrars in the .name Registry shall have equal access to Registry Services provided by Global Name Registry as set forth in the Registry Equivalent Access Policy.

3. Global Name Registry and its members and subcontractors shall not in any way attempt to warehouse or register domain names in their own right, except for names designated for operational purposes in compliance with Subsections 3.6.1 and 3.6.2 of the Registry Agreement. In its Monthly Report to ICANN, Global Name Registry shall include a list of all names designated for operational purposes.

4. Any shareholder, subsidiary, affiliate, or other related entity of Global Name Registry that also operates as a provider of registrar services shall maintain separate books of account with respect to its registrar operations separate from those of Global Name Registry.

5. Neither Global Name Registry, nor its shareholders, subsidiaries, affiliates, or other related entities shall have access to user data or proprietary information of an ICANN-Accredited Registrar, except as necessary for registry management and operations.

6. Global Name Registry will ensure that no user data or proprietary information from any ICANN-Accredited Registrar is disclosed to its affiliates, subsidiaries, or other related entities, except as necessary for registry management and operations.

7. Confidential information about Global Name Registry's business services will not be shared with employees of any DNS registry operator or ICANN-Accredited Registrars, except as necessary for registry management and operations.

8. No member of Global Name Registry's Board of Directors will simultaneously serve on the Board of Directors of an ICANN-Accredited Registrar that obtains Registry Services from Global Name Registry.

9. No employee of Global Name Registry will hold a greater than 5% interest, financial or otherwise in a company that obtains Registry Services from Global Name Registry.

10.No employee of Global Name Registry will also be an employee of any Global Name Registry subsidiary, affiliate or other related entity that also operates as an ICANN-Accredited Registrar.

11.Global Name Registry will ensure that no user data from or proprietary information of any registry operated or controlled by Global Name Registry is disclosed to any other registry operated or controlled by Global Name Registry.

12.Global Name Registry will not attempt to itself determine any entity’s right to a particular domain name, and has no means by which to verify such rights.

Global Name Registry will conduct internal neutrality reviews on a regular basis. In addition, Global Name Registry and ICANN may mutually agree on an independent party ("Neutrality Analyst") that ICANN may hire, at ICANN's expense, to conduct a neutrality review of Global Name Registry, ensuring that Global Name Registry Any shareholder, subsidiary, affiliate, or other related entity of Global Name Registry that also operates as a provider of registrar services comply with all the provisions of this Registry Operator Code of Conduct. The neutrality review may be conducted as often as once per year. Global Name Registry will provide the Neutrality Analyst with reasonable access to information and records appropriate to complete the review. The results of the review of the Neutrality Analyst will be provided to ICANN and shall be deemed to be confidential and proprietary information of Global Name Registry and its owners.

This Code of Conduct is set forth in more detail in Appendix 30 to this application.

Measures to Ensure Equivalent Access

Further, Global Name Registry will ensure that all ICANN-accredited registrars enjoy equivalent access to the .org registry systems. This policy encompasses the following areas:

Equivalence

1. Equivalent protocols, connection and security measures

2. Equivalent customer support, administrative and business services

3. Equivalent billing and account management

A Registry Operator void of organisational conflict of interest

1. Organizational structure separate from any registrar

2. Financial separation from any registrar

3. Different locations/premises from any registrar

Security of all data held by Registrar

1. Physical protection of registry, barriers from any Registrar

2. Registry information control, including

a. Training of staff for treatment of proprietary or confidential information

b. Responsibility and ownership of information

c. Limited or non-disclosure of information

d. Safekeeping of information

e. Marking and tracking of information

f. Destruction of information

g. Protection against technical security breaches

h. Protection against human security breaches

This Equivalent Access Policy is set forth in more detail in Appendix 31 to this application. See also C19 for further detail and information on measures to ensure compliance.

C22. <Intentionally moved to separate chapter>

Given the very technical nature of C22, it has been separately bound in a clearly marked part of this .org Proposal.

C23. and C24. Intentionally omitted.

V. PROPOSED REGISTRY SERVICES

C25. Description of each Registry Service

Describe each Registry Service (as defined in subsection 1.16 of the skeleton .org Registry Agreement) that you propose to provide for a fee. For an example of a description of this type, see:

http://www.icann.org/tlds/agreements/name/registry-agmt-appc-1-03jul01.htm.

Global Name Registry will use a very similar structure for its offerings of registry services as between .name and .org. The .name registry services description appears below, modified to reflect the differences in offering between .name and .org.

The following Registry Services (as defined) will be offered by Global Name Registry for the .org Registry:

1. Domain Name Registrations

2. Domain Name Renewals

3. Transfers of Sponsorship of Registered Item Registrations

4. Multilingual/International Domain Name Registrations

5. Bulk Transfers

Domain Name Registrations and renewals

Domain names in the .org TLD may be registered and renewed through ICANN-accredited registrars that have Registry-Registrar Agreements (“RRAs”) in effect with Global Name Registry and are qualified (hereafter, “Approved Registrars”), according to the following criteria:

Domain names must be of the format specified for the “Domain name character set” in Part 13 (Character Sets) of this Appendix C.
Domain names must meet the naming conventions for domain names specified in Appendix L, Part 0. Domain names in the .org TLD are registered to the public at the second level, of the type name.org. Some possible names may be reserved, as specified in an appendix to this document (“Reserved Names”) and may not be registered.
In general, domain name registrations in the .org TLD will be made on a first-come, first-served basis.
The initial registration term may be from one to ten years, in one-year increments.
Domain name registrations may be renewed prior to their expiration for a period of years up to ten years (in one-year increments), provided that the expiration date of a domain-name registration can never be more than ten years in the future. A renewal that would set the expiration date further than ten years, but less than eleven years in the future will lead to the expiration date being set to ten years in the future. Any remaining time will be forfeited. A request for renewal that would set the expiration date further than 11 years in the future will be denied.
All domain-name registrations must be made pursuant to the requirements of the Approved Registrar’s RRA with Global Name Registry. Among other things, the RRA requires that the registrar and registrant have a registration agreement.

· The Approved Registrar will collect registration information from the registrant and do quality checking of the data to ensure the validity of the domain-name registration. The registrar must submit through the Shared Registration System complete, accurate, and valid registration data, and must update that data when changes occur.

During their term, domain name registrations will be maintained in the .org Shared Registration System. They will be reported by the .org Whois service, as described in the Whois description. In addition, domain names with registrations including the names and IP addresses (Ipv4) of at least two nameservers will be delegated in the .org TLD zone as described in the DNS section of this application.

Transfer of domain name sponsorship

Domain names in the .org TLD may be transferred to another Approved Registrar’s sponsorship through Approved Registrars and are qualified, according to the following criteria:

· The request for transfer can be made by any Approved Registrar.

· For transfer requests using the EPP protocol, the transfer request must include an authorization identifier to confirm transfer authority. This element contains authorization information associated with the object, or alternatively for domain and email forwarding objects, authorization information associated with the registrant or associated contacts as specified in the EPP drafts.

· The authorization identifier information must not be disclosed to any other Approved Registrar or third party. An Approved Registrar that wishes to transfer an object on behalf of a third party must receive authorization identifier information from the third party before a command can be executed.

· For all transfer requests (including under RRP), the registry will automatically approve all transfer requests that are not explicitly approved or rejected by the current sponsoring registrar within five calendar days of the transfer request. The losing registrar will be notified via e-mail of the automatic transfer.

· Registrar transfer entails a specified extension of the expiry date for the object. The registrar transfer is a billable operation and is charged identically to a renewal for the same extension of the period. This period can be from 1 to 10 years, in one-year increments.

· A domain name cannot be transferred to another registrar within the first 60 days after registration. This also continues to apply if the domain name is renewed during the first 60 days).

· Transfer of the domain name changes the sponsoring Registrar of the domain name, and also changes the subordinate, local hosts (not foreign hosts, on other TLDs) associated with the domain name.

Multilingual/International Domain Name Registrations

Since the current registry operator has previously accommodated certain types of Internationalized domain name (IDN) registrations in the .org TLD, Global Name Registry will grandfather in the existing registrations as made with a specific RACE encoding and keep these in the registry. However, depending on the standards emerging for IDNs, the existing IDN registrations maintained by the current registry operator may or may not be compatible with the new standards. Global Name Registry will work to ensure a smooth migration to any new standard.

Bulk Transfer

A bulk transfer can only be initiated and completed by the registry upon a formal request from ICANN. A bulk transfer is a change in the sponsorship of all objects from one registrar to another. This may happen if a registrar changes name, is acquired by another registrar or otherwise changes or ceases its business as an Approved Registrar.

C26. State the maximum price you propose for each Registry Service identified in item C25.

Registered Name - Initial Registration Fees

State the maximum price you propose for each registry service identified in Item C25.

Global Name Registry proposes to introduce aggressive cost-savings on the initial registration fee for longer-period registrations. The fees set forth in the following table will be the fees charged per registered name, for the respective durations one to 10 years:

Duration of initial registration or renewal (years)	Registrar price (USD)	Equivalent 1 year fee (EQ1Y) in USD
1	$6.00	$6.00
2	$10.50	$5.25
3	$15.00	$5.00
4	$19.00	$4.75
5	$22.00	$4.40
6	$25.00	$4.17
7	$29.00	$4.14
8	$33.00	$4.13
9	$37.00	$4.11
10	$40.00	$4.00

This is also shown in the following charts.

Figure 1: Price reduction for .org

Global Name Registry intends for this aggressive discount on longer-term registrations to incentivize registrants to choose longer-term registrations.

For example, a registration of four years will result in an average 1 year equivalent Initial Registration fee of $4.75, a reduction of 21% from the current $6.00 price.

The graph below illustrates this major price decrease proposed:

Figure 2: Lowering the yearly price

In addition to this price decrease, Global Name Registry will lower the initial registration fees when registry volumes grow. The fee per year that will be charged during the term of the .org ICANN Agreement will depend upon the total number of Registered Names registered at that time in the Registry TLD and shall not exceed the fees set forth in the following table:

Maximum Registered Name Initial Registration Fee for a 1 year registration	Volume Range (Number of Registered Names)
US $6.00	0 to 2,499,999
US $5.70	2,500,000 to 3,999,999
US $5.42	4,000,000 to 5,999,999
US $5.20	6,000,000 +

When prices of 1 year Registrations are reduced as shown in the table above, the longer-term Registrations will be reduced by the same factor.

This means that the average price for a registered name, if due to the discounts on longer term registrations, will go down from today’s $6.00 to $4.12 if the average length of registration goes up to 3 or 4 years from today’s 1.9 years (according to the Morgan Stanley Equity Research report on VeriSign on Sept 21, 2001).

Figure 3: Further lowering of the yearly price when Registry volumes grow

The following shows the effect these major price reductions have on the fee per registered name per year (EQ1Y)

Figure 4: 1 year pricing equivalent per registry volumes

The following graphically shows the price reductions proposed:

Figure 5: Current VeriSign pricing compared to this proposal’s pricing

The actual fees charged per initial registration will be:

As a result of the aggressive price reduction proposed in this proposal, the price of a .org domain name will be between 5-42% cheaper for a Registrar after the transition from VeriSign.

The ICANN-Accredited Registrar sponsoring the Registered Name shall pay the Registered Name Initial Registration Fee and any applicable taxes in full at the time of registration.

Registered Name - Renewal Fees

The fee per year that Global Name Registry will charge at the time of renewal for each Registered Name renewal (the "Registered Name Renewal Fee") in the Registry TLD during the Term of the Registry Agreement will be equivalent to the Registered Name Initial Registration Fee chargeable to ICANN-Accredited Registrars at the time of renewal, and will not exceed the fees described above.

The renewal fees will have the same discounts as the initial registration fees.

The Registered Name Renewal Fees referred to above do not include any direct or indirect taxation that Global Name Registry may be obligated to add on. The ICANN-Accredited Registrar sponsoring the Registered Name shall pay the Registered Name Renewal Fee and any applicable taxes in full at the time of renewal.

Fees for Transfers of Sponsorship of Registered Item Registrations

Where the spo