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Witness Testimony
Mr. Richard Tindal
The 'Dot Kids' Internet Domain: Protecting Children Online
Summary Mr. Chairman, Mr. Shimkus, Mr. Markey and distinguished Members of the Committee. I am Richard Tindal, Vice President, Registry Services for NeuStar, Inc. ("NeuStar"). I appreciate the opportunity to appear before you today to discuss NeuStar's implementation of the Dot Kids Implementation and Efficiency Act of 2002 (the "Dot Kids Act"). NeuStar is very proud of its achievements in helping to carry out the objectives of the Dot Kids Act. The Dot Kids domain is up and running today with over 1700 names registered and thirteen live sites available for use. We believe that kids.us is an important public resource for I will begin my testimony by providing background on NeuStar and the steps taken prior to and since enactment of the Dot Kids Act to carry out the objectives and requirements of the law. This effort involved the work of employees from all across NeuStar and resulted in a flawless launch of the kids.us domain three months prior to the statutory deadline. I will then discuss the status of the domain and review NeuStar's 2004 marketing program for kids.us. Background Since its founding,
NeuStar, a privately held technology and registry company, has established
itself as the premier trusted neutral third party provider of mission critical
infrastructure services and has developed lines of business serving both the
telecommunications and Internet industries. NeuStar operates the official
directory for all North American telephone numbers and manages the database
carriers rely on to rate and route billions of telephone calls each day.
NeuStar also operates a state of the art Internet registry managing all names in
the "Dot-US" top level domain, and with its joint venture partner, Melbourne
IT, Ltd., the names in the "Dot-BIZ" top-level domain. In addition,
NeuStar 's registry handles the routing needs of data services such as
Multimedia Messaging Services. Finally, NeuStar is a leading provider of
Operations Support Services clearinghouse services that allow telecommunications
and enterprise firms to automate and increase the efficiency of ordering,
service provisioning and billing and customer service functions. Overview of the kids.us Pre-Launch Policy, Operational, Technical, and Outreach Accomplishments The question of how we as a society can protect children on the Internet is
an important and challenging one for all of us. There are numerous tools
available today including browser filters, educational campaigns, and rating
systems. Each of these options contributes something important and
valuable to attaining the goal of Internet safety for children. Kids.us
provides another important tool for Policy Accomplishments NeuStar's first task, which commenced eight months before enactment of the Dot Kids Act, was to define the policies and procedures that would govern the kids.us domain. NeuStar conducted a public outreach effort, consulting with several child advocacy groups and other organizations to develop the guidelines for determining what material would be deemed unacceptable for and/or harmful to minors. The resulting content policy identifies and defines thirteen categories of content that are restricted from kids.us. [1] Next, NeuStar drafted the kids.us Takedown Procedures. These procedures define the process for enforcement of the kids.us Content Policy in a way that is transparent, fair and expeditious for the registrants. Additionally, all Dot-US policies are applicable and enforced in the kids.us domain. This includes the US Nexus Requirement, usTLD Dispute Resolution Policy, and requirements for accurate Whois data. Finally, to implement these new policies, NeuStar modified the Dot-US Registrar Accreditation and Registry-Registrar Agreements to include the policies and procedures governing the registration of kids.us domain names. Operational Model and Accomplishments The next step in developing the framework for kids.us was to determine how the registration and content review process[2] would work, consistent with the Dot Kids Act. We relied on our experience implementing Dot-Biz and Dot-US by developing a model that would both protect and preserve the requirements of the Dot Kids Act while providing as much clarity as possible to potential registrants. When determining how best to ensure the integrity of the kids.us domain and to manage the content review and enforcement processes, NeuStar concluded that it should directly oversee and manage the content review process. We did this because we knew it would be important that content review be handled in a neutral fashion, that is, for content review to be centrally and consistently administered for all registrants. Content review includes several discrete functions: developing and maintaining a customer interface to purchase content subscriptions, the review of all content within the domain, enforcement of the kids.us Content Policy, and customer account management. To ensure a competitive registration process, NeuStar maintained the existing registry-registrar model whereby only accredited registrars sell kids.us domain names to the public. As a result, establishing a web presence within kids.us is a 2-step process for any interested content provider: (1) registration of a domain name with a registrar, and (2) purchase of a content review subscription from NeuStar. NeuStar has engaged the support of a subcontractor, Kidsnet, Inc., to assist us in the review function, with both the initial and ongoing reviews of all active content. This review function utilizes both manual reviews as well as a "spidering," filter technology. Technical Accomplishments With the operational model defined, NeuStar's technical staff made the modifications to the Dot-US registry necessary to accommodate new registrations at the third level. This technical effort involved the development of new technical services and support mechanisms needed to launch kids.us. These technical modifications included: - Modifying the source code of the Dot-US registry to accept third-level kids.us registrations; - Modifying the source code of Whois to include kids.us registrant contact data; - Creating the content management system, and; - Launching the end-user directory. The kids.us namespace is administered from a highly reliable infrastructure, offering near real-time registrations and name server updates. Pre-launch Outreach Accomplishments Prior to the launch of the kids.us domain, NeuStar conducted an outreach program to raise awareness of kids.us, encourage participation from registrars, and drive public adoption of the new domain. We were able to leverage our existing relationships with the registrar community, the contacts we had made through the development of the kids.us Content Policy, and media connections to promote the space. In summary, NeuStar's pre-launch outreach initiatives included: -
Engaging in media outreach including issuing press releases, sending e-mail
messages to a broad range of users, contracting a PR firm to promote Sunrise
launch among trademark holders looking to protect their marks (the "Sunrise
Phase"); -
Creating marketing collateral and organizing sales meetings and informational
briefing sessions with registrars, and; -
Contacting potential technology partners for browser and directory
functionality. Launch, Enforcement, and Enhanced Services Launch The launch of kids.us was a technical and operational success and was
conducted in a 2-part process. On June 17, 2003, NeuStar initiated the
Sunrise Phase for trademark protection, enabling owners of existing or pending On September 4, 2003 at noon E.S.T., NeuStar opened registrations to the general public. At the close of the first hour, the registry had successfully registered over 400 kids.us names. At the same time that open registration began, NeuStar activated the content management system. NeuStar flawlessly launched the kids.us domain three months prior to the date required by the Dot Kids Act. Review and Enforcement The on-going enforcement of the kids.us domain involves reviewing all kids.us content for compliance with the kids.us Content Policy, and then enforcing that policy in accordance with the kids.us Takedown Procedures. In this initial period following the launch NeuStar carried out all aspects of the content review role. To date, NeuStar has had very positive experiences in the process of content management and enforcement. The content received is generally appropriate for the domain. In addition, any content violations found have typically been inadvertent hyperlinks or a link to an e-mail box that was missed in the registrant's efforts to make a site compliant with the kids.us Content Policy. Details of the enforcement activity for the first three months are available in the "Annual Compliance Report on the kids.us Domain" filed with the Congress and the Department of Commerce on December 4, 2003, pursuant to the requirements of the Dot Kids Act. Enhanced Services Although not a specific requirement of the Dot Kids Act, NeuStar introduced a child-oriented end-user directory to facilitate use of the domain by both children and adults. All active sites are listed in this directory and are sorted based on the registrant's self-categorization of their content. An additional feature at the kids.us homepage is a third-party reporting tool. This tool - a user web-form- provides a direct mechanism to contact NeuStar 24 hours a day, seven days a week, 365 days a year to report an alleged content violation within kids.us. This tool provides an additional element of safety and strengthens our collective abilities to protect children while they are online. In January, the kids.us homepage was redesigned and expanded to include a public Whois lookup for interested registrants as well as for parents to identify the owners of kids.us sites. NeuStar kids.us Marketing Program for 2004 On June 1, 2004, NeuStar will re-introduce the kids.us domain to the marketplace by implementing a multifaceted marketing campaign that includes advertising, public relations, customer outreach and direct marketing programs. This new program is designed to: (1) broaden consumer awareness and use of the kids.us namespace; (2) encourage the activation of content by registrants; and (3) increase the number of kids.us domain name registrations. The kids.us marketing program will accomplish these goals by creating greater awareness among potential registrants and consumers through direct and joint marketing, reaching out to existing kids.us registrants to encourage content development and activation, and energizing the registrar sales channel to promote kids.us more actively. Through direct and joint public relations activities and advertising, NeuStar will work to expand awareness of the kids.us namespace and specifically highlight sites already up and running with content, as well as those that develop content while the program is ongoing. By increasing public and corporate awareness of the kids.us opportunity, and offering financial incentives to our registrar sales channel to help spread the word, we will initiate a call-to-action for those domain holders that have not yet taken the important step of developing content and becoming live participants in the kids.us namespace. The direct marketing component of NeuStar's plan includes: (1) banner ad placement on line; (2) direct e-mail campaigns; (3) creative marketing promotions to generate end-user interest and (4) direct mail campaigns to existing registrants that have not yet turned up content. NeuStar will offer the registrar sales channel financial incentives intended to encourage registrars to approach those customers who have registered domains, but not yet developed or turned up content and ensure their support in marketing kids.us domain names. These incentives will include limited time revenue sharing and a rebate program for new registrations and renewals that extend registration terms of existing names. These incentives are designed to help increase activation of kids.us content and websites and increase awareness of registration opportunities in the kids.us namespace. By creating incentives through our registrar channel and working directly with companies that have already registered domains, NeuStar hopes to encourage the activation of kids.us content. Finally, the focus of the public relations component of the marketing plan will be to create general awareness through press releases and advertising. The media outreach will be directed to business press and publications that cover government and to Internet trade publications, websites and industry newsletters. Conclusion NeuStar is committed to making kids.us a success and providing an important
service to children, parents, and educators throughout our nation. We take
a great deal of pride in developing and launching what we view to be an
important new public resource for NeuStar's new marketing campaign is designed to increase awareness and adoption and accelerate the market acceptance of the new kids.us domain. NeuStar strongly believes kids.us will continue to mature and grow. We fully express our continued commitment to this important public resource. NeuStar has accomplished every task identified in the Dot Kids Act and in an effort to enhance the domain, delivered more than was expressly required. With the marketing program outlined here, NeuStar continues to demonstrate that we are taking the steps needed to enhance and improve the kids.us domain. We cannot, of course, do this alone and as noted at the start of this testimony, we truly appreciate the leadership, interest, and attention provided by this Committee and the Department of Commerce. We look forward to continuing our work with you in this special role as the registry for kids.us.
[1]
This and all other kids.us policies can be found at www.kids.us/content_policy.
[2]
Content includes all written, dynamic and visual material within a website,
including the domain name.
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