Unsponsored TLD Agreement: Appendix L (.pro)
Posted: 3 March 2002

Registration Restrictions

1. Overview. Registrations of Registered Names within the .pro top-level domain (TLD) are restricted to persons and entities that are credentialed by appropriate entities (such as through governmental bodies and professional organizations) to provide professional services. The .pro TLD is organized into professions-specific second-level domains (PS-SLDs), which will be introduced in a phased manner. Eligibility for registration will be verified and periodically re-verified, and will be signified by digital credentials recorded in the registry database. The Registry Operator will operate the .pro TLD and its PS-SLDs in consultation with an Advisory Board and constituent PS-SLD Advisory Boards it will form.

This Appendix describes the naming conventions used in the .pro TLD, the registration requirements for first-phase PS-SLDs, the procedure for establishing subsequent-phase PS-SLDs, the consultative process for ongoing review and adjustment of registration restrictions, the verification procedure, and the requirements for digital credentials.

2. Naming Conventions.

2.1 Registered Names. Registered Names in the .pro TLD will be registered (other than to the Registry Operator or according to ICANN instructions-see Appendices X and K) at the third level, in the format <name>.<profession designator>.pro.

2.2 PS-SLD Labels. The second-level labels used to designate the various professions will be assigned according to Sections 3, 4, and 6 of this Appendix L.

2.3 Naming Restrictions in Other Parts of the Registry Agreement. All Registered Names must meet the requirements in the Registry Agreement and its appendices. Relevant appendices include Appendix C (Functional Specifications), Appendix F (Registry-Registrar Agreement), Appendix J (Start-Up Plan), Appendix K (Names Reserved from Registration), this Appendix L, Appendix M (Enforcement of Registration Restrictions), and Appendix X (Names Registered to Registry Operator).

2.4 Prohibited Third-Level Labels. The following words and strings may not be registered as third-level labels for Registered Names: av, ca, cca, cert, certificate, dir, directory, email, grpa, http, mail, mx, mx[followed by a number from 0 to 100], ns, ns[followed by a number from 0 to 100], pro, registrypro, verify, verification, wap, www and www[followed by a number from 0 to 100]. However, names having third-level labels that include any of the foregoing words and strings may be registered, such as dirksen.med.pro.

2.5 Enforcement. The Registry Operator shall implement technical measures reasonably calculated to enact the requirements in this Section 2 of this Appendix L.

2.6 Possible Future Allowance of Second-Level Registrations. Some registrants (particularly professionals in some jurisdictions that do not semantically correspond to the designated PS-SLD abbreviations) may prefer to use a domain name that has only two levels (www.xxx.pro rather than www.xxx.law.pro). In the future, the Registry Operator may propose to give .pro registrants the option of registering for two-level domain names directly in the .pro TLD (subject to the list of restricted domain names in Appendices K and X and in compliance with the registration policies, processes and requirements in this Appendix L and Appendices J and M); these domain names would be distinguished by professional category by being directly routed to matching Registered Names in the applicable PS-SLD. Any proposal by the Registry Operator under this Subsection 2.6 must be made in writing to ICANN and will be subject to ICANN's written approval. In determining whether to give approval, ICANN will consider any recommendations of the Advisory Board as contemplated in Subsection 5.1.2.4 of this Appendix L. If ICANN does not act on a proposal within ninety days, it will report in writing to the Registry Operator on the status of its consideration.

3. First-Phase PS-SLDs. The following professional categories will be offered for registration during the initial roll-out of the .pro TLD:

3.1 Legal.

3.1.1 Basic scope. The legal category includes credentialed providers of legal and law-related services (including companies employing such providers). Examples are lawyers, judges, barristers, legal clinics, legal associations, law firms, counsel for or legal divisions of other organizations, and legal publishers.

3.1.2 SLD codes. At introduction, the following SLD labels are authorized to be used for the legal profession PS-SLD: .law.pro, .avocat.pro, .bar.pro, .recht.pro, and .jur.pro. Additional SLD labels may be introduced through the consultation, notification, and approval process described in Section 6 of this Appendix L.

3.1.3 Registration Qualifications. The following qualifications will be initially required for the legal profession PS-SLD:

3.1.3.1 Admission or licensing by, and good standing with, a certification body or jurisdictional licensing entity, such as a United States state bar or provincial or territorial Law Societies in Canada;

3.1.3.2 Admission to a judicial system, which allows the registering party to represent clients before such judiciary, such as the status of a barrister in the United Kingdom;

3.1.3.3 Membership in a relevant legal association which requires that its members be licensed or admitted to a certifying or licensing entity (such as the Hong Kong Law Society for solicitors) and regularly verifies the accuracy of its data); or

3.1.3.4 Formation as an entity or organization, or a unit of a larger organization that provides legal services or is organized for such a purpose, and/or has a significant portion of professional employees or members who satisfy one of the above criteria, and registers on behalf of such entity or organization.

The above list of qualifications, however, is subject to change by the Registry Operator in consultation with the Advisory Board once it is established, provided that the qualifications reasonably ensure conformity with the basic scope defined in Subsection 3.1.1 of this Appendix L.

3.1.4 Verification. Qualification of applicants for Registered Names within the legal profession PS-SLD will be verified according to the process described in Section 8 of this Appendix L.

3.2 Medical.

3.2.1 Basic scope. The medical category includes credentialed providers of medical and health-related services (including companies employing such providers). Examples are doctors, hospitals, health clinics, medical associations, medical professionals at, or medical departments of, other organizations, and medical publishers.

3.2.2 SLD codes. At introduction, the following SLD label is authorized to be used for the medical profession PS-SLD: .med.pro. Additional SLD labels may be introduced through the consultation, notification, and approval process described in Section 6 of this Appendix L.

3.2.3 Registration Qualifications. The following qualifications will be initially required for the medical profession PS-SLD:

3.2.3.1 Admission or licensing by, and good standing with, a licensing or certification body, such as a local medical association in Germany or by a provincial or territorial licensing authority in Canada;

3.2.3.2 Holding of a certificate from an appropriate medical specialty board such as a Member Board of the American Board of American Specialties or Canadian Medical Register or an appropriate government authority to practice medicine and/or prescribe medicine;

3.2.3.3 Admitting privileges to a hospital;

3.2.3.4 Membership in a relevant professional association which requires that its members be licensed or admitted to a certifying or licensing entity and regularly verifies the accuracy of its licensing data; or

3.2.3.5 Formation as an entity or organization, or a unit of a larger organization that provides health-related services or is organized for such a purpose, and/or has a significant portion of professional employees or members who satisfy one of the above criteria, and registers on behalf of such entity or organization.

The above list of qualifications, however, is subject to change by the Registry Operator in consultation with the Advisory Board once it is established, provided that the qualifications reasonably ensure conformity with the basic scope defined in Subsection 3.2.1 of this Appendix L.

3.2.4 Verification. Qualification of applicants for Registered Names within the medical profession PS-SLD will be verified according to the process described in Section 8 of this Appendix L.

3.3 Accountancy.

3.3.1 Basic scope. The accounting category includes credentialed providers of accounting and accountancy-related services (including companies employing such providers). Examples are certified public accountants, chartered accounts, accounting firms, accounting associations, accounting departments of other organizations, and accounting publications and publishers.

3.3.2 SLD codes. At introduction, the following SLD labels are authorized to be used for the accountancy profession PS-SLD: .cpa.pro, .aaa.pro., aca.pro, .acct.pro. Additional SLD labels may be introduced through the consultation, notification, and approval process described in Section 6 of this Appendix L.

3.3.3 Registration Qualifications. The following qualifications will be initially required for the accountancy profession PS-SLD:

3.3.3.1 Admission or licensing by, and good standing with, a certification body, such as the Hong Kong Society of Accountants;

3.3.3.2 Holding a license to prepare and sign clients' tax returns;

3.3.3.3 Membership in a professional association which requires that its members be licensed or admitted to a certifying or licensing entity and regularly verifies the accuracy of its licensing data (such as the Hong Kong Law Society for barristers) ; or

3.3.3.4 Formation as an entity or organization, or a unit of a larger organization that provides accountancy-related services or is organized for such a purpose, and/or has a significant portion of professional employees or members who satisfy one of the above criteria, and registers on behalf of such entity or organization.

The above list of qualifications, however, is subject to change by the Registry Operator in consultation with the Advisory Board once it is established, provided that the qualifications reasonably ensure conformity with the basic scope defined in Subsection 3.3.1 of this Appendix L.

3.3.4 Verification. Qualification of applicants for Registered Names within the accountancy profession PS-SLD will be verified according to the process described in Section 8 of this Appendix L.

4. Subsequent-Phase PS-SLDs.

4.1 Proposal. The Registry Operator may propose to ICANN the introduction of PS-SLDs for additional professions. Before making the proposal, the Registry Operator will consult with the Advisory Board. The proposal will be submitted in writing to ICANN and will consist of the following:

4.1.1 A statement of the basic scope of the proposed PS-SLD, including a statement of the definition of the professional category to be served by the PS-SLD in a format similar to the definition contained in Subsection 3.1.1 of this Appendix L.

4.1.2 An explanation of why the additional PS-SLD is consistent with the overall development of .pro as a TLD restricted to persons and entities that are credentialed by appropriate entities (such as through governmental bodies and professional organizations) to provide professional services.

4.1.3 A statement of the second-level label(s) to be used under .pro to designate the PS-SLD, together with an explanation of why the label(s) is an (are) appropriate designator(s).

4.1.4 A description of the registration qualifications initially to be applied in the PS-SLD. (See Subsection 3.1.3 of this Appendix L for an example.)

4.1.5 A description of the procedures for verification of qualifications, which may consist of a reference to Section 8 of this Appendix L.

4.1.6 A start-up documentation package describing the arrangements for start-up of the PS-SLD, including the proposed schedule, details on any sunrise period, and details on registrar training.

4.1.7 A description of any Sub-Advisory Board proposed to be established for the PS-SLD, including a statement of the procedures for selecting members of the Sub-Advisory Board and, if available, a listing of its proposed initial members. If the Advisory Board has not yet become large enough to be sub-divided, the proposal shall include a listing of the members representing the PS-SLD to be invited to join the Advisory Board.

4.1.8 Evidence of support for establishment of the PS-SLD among professionals and their associations, both generally and within the professional category.

4.1.9 A written statement of views by the Advisory Board, including any minority or supplemental statements.

4.2 Evaluation of Proposal. ICANN's evaluation of the proposal will include at least the following considerations:

4.2.1 The extent to which the proposed PS-SLD is consistent with the overall development of .pro as a TLD restricted to persons and entities that are credentialed by appropriate entities (such as through governmental bodies and professional organizations) to provide professional services.

4.2.2 The extent to which qualifications can be fairly and consistently applied.

4.2.3 The extent of support among professionals generally and specifically within the professional category.

4.2.4 The adequacy of the Advisory Board and any proposed Sub-Advisory Board to provide advice from the viewpoint of the professional category on the operation of the PS-SLD.

4.3 Approval. To become effective, the proposal must be approved in writing by ICANN, provided that in the event the proposal is submitted with a resolution of support approved by a majority vote of the Advisory Board then the proposal shall be deemed approved by ICANN unless ICANN provides the Registry Operator written notice of its objection to the proposal within sixty days after the proposal's submission to ICANN. If ICANN does not act on a proposal of the Registry Operator under Subsection 4.1 of this Appendix L within ninety days, it will provide the Registry Operator a written report on the status of its consideration.

4.4 Changes to Registration Qualifications. Qualifications for registration in subsequent-phase PS-SLDs are subject to change by the Registry Operator in consultation with the Advisory Board (or, where there is a Sub-Advisory Board in operation for the PS-SLD, in consultation with that Sub-Advisory Board), provided that the qualifications reasonably ensure conformity with the basic scope approved by ICANN under Subsection 4.2 of this Appendix L.

5. Advisory Board and Sub-Advisory Boards.

5.1 Advisory Board.

5.1.1 The Registry Operator will, no later than the Commencement-of-Service Date, create an Advisory Board to contribute to the development and implementation of the new .pro TLD. The Advisory Board will initially be composed of representatives of professional associations that are representative of the legal, medical, and accountancy professions. As more PS-SLDs are added to .pro, representatives of professional associations in those professional categories will be invited to join the Advisory Board. While the initial Advisory Board is intended to be approximately 9 members, the Advisory Board is likely to increase in size as new PS-SLDs are added.

5.1.2 The Advisory Board will meet (in person or by telephone) no less frequently than quarterly. Its functions include:

5.1.2.1 assistance in identifying relevant professional associations;

5.1.2.2 help in identifying new PS-SLDs and formulating review proposals for their establishment under Section 4 of this Appendix L;

5.1.2.3 help in formulating proposals for establishment of and adjustment to registration restrictions and verification procedures, including designation of professional organizations as members of the RPGA, membership in which meets particular registration requirements (see, for example, Subsection 3.3.3.3 of this Appendix L);

5.1.2.4 providing recommendations on any proposal by the Registry Operator to introduce the option of allowing registrants to register two-label .pro domain names (such a proposal must be approved in writing by ICANN under Subsection 2.6 of this Appendix L);

5.1.2.5 providing recommendations on the establishment or discontinuance of Sub-Advisory Boards according to Subsection 5.2 of this Appendix L;

5.1.2.6 providing recommendations on additional labels for PS-SLDs according to Section 6 of this Appendix L; and

5.1.2.7 otherwise providing advice to the Registry Operator on the policies on the operation of the .pro TLD.
The Advisory Board will direct its recommendations to the management of the Registry Operator; if the Advisory Board finds that the Registry Operator's management is taking actions that will violate the restrictions of the .pro TLD or its PS-SLDs, the Advisory Board may send written notice of its recommendation regarding such action to the Registry Operator's Board of Directors and to ICANN.

5.2 Sub-Advisory Boards.

5.2.1 The Registry Operator may propose the establishment of a Sub-Advisory Board for a particular PS-SLD, either at or after the time the PS-SLD is proposed for introduction. In either case, the Registry Operator will first consult with the Advisory Board. The proposal will be made in writing to ICANN and will include a statement of the procedures for selecting members of the Sub-Advisory Board and, if available, a listing of its proposed initial members, as well as a written statement from the Advisory Board of its views (including any minority or supplemental statements) on the appropriateness of the Sub-Advisory Board.

5.2.2 The Registry Operator may also propose to ICANN in writing the discontinuation of an existing Sub-Advisory Board. A discontinuation proposal will be accompanied by statements of views (including any minority or supplemental statements) of the Advisory Board and the Sub-Advisory Board to be discontinued.

5.2.3 To become effective, a proposal to establish or discontinue a Sub-Advisory Board must be approved in writing by ICANN, provided that in the event the proposal is submitted with a resolution of support approved by a majority vote of the Advisory Board then the proposal shall be deemed approved by ICANN unless ICANN provides the Registry Operator written notice of its objection to the proposal within thirty days after the proposal's submission to ICANN. If ICANN does not act on a proposal of the Registry Operator under this Subsection 5.2.3 within sixty days, it will provide the Registry Operator a written report on the status of its consideration.

5.2.4 Each Sub-Advisory Board will operate in the same manner as the Advisory Board, except the Sub-Advisory Board's scope of responsibility will be limited to the PS-SLD for which it was established. The various Sub-Advisory Boards may act in concert, between themselves or with the Advisory Board, from time to time.

6. Additional Labels for PS-SLDs. The Registry Operator may propose additional second-level labels to be used in connection with any already-established PS-SLD. These labels may indicate, for example, a professional sub-category within the launched professional sector (such as .nurse.pro for registered nurses) or a label signifying the profession or professional subcategory in an additional language (such as .avocat.pro for lawyers in France).

Before making the proposal, the Registry Operator will consult with the Advisory Board and, if one is in operation, the Sub-Advisory Board for the PS-SLD involved. The proposal will be submitted in writing to ICANN and will include an explanation of the reasons supporting the proposal and copies of any written comments (including any minority or supplemental statements) of the Advisory Board or Sub-Advisory Board on the proposal. To become effective, the proposal must be approved in writing by ICANN, provided that in the event the proposal is submitted with a resolution of support approved by a majority vote of the Advisory Board (or, where there is a Sub-Advisory Board in operation for the PS-SLD, approved by a majority vote of the Sub-Advisory Board) then the proposal shall be deemed approved by ICANN unless ICANN provides the Registry Operator written notice of its objection to the proposal within thirty days after the proposal's submission to ICANN. If ICANN does not act on a proposal of the Registry Operator under this Section 6 within sixty days, it will provide the Registry Operator a written report on the status of its consideration.

7. Registration Requirements. All registrants of Registered Names in the .pro TLD must enter into an electronic or paper registration agreement with the Authorized Registrar that sponsors their name within the registry (Appendix F). (As used in this Appendix L, the term "Authorized Registrar" refers to a registrar accredited by ICANN for the .pro TLD that has entered into, and has currently in effect, the Registry-Registrar Agreement (Appendix F).) The electronic or paper registration agreement shall include (in addition to terms otherwise required in the Authorized Registrar's Registrar Accreditation Agreement with ICANN) the following:

7.1 the registrant represents and warrants that he, she, or it meets the registration requirements for the PS-SLD in which the Registered Name is being registered;

7.2 the registrant agrees to notify the Authorized Registrar promptly of any change in circumstances that causes the registrant no longer to meet the registration requirements for the PS-SLD in which the Registered Name is being registered;

7.3 the registrant represents and warrants that the registrant and qualification data and other data required for the issuance of a digital certificate that he, she, or it is submitting is true and accurate;

7.4 the registrant agrees to provide to the Authorized Registrar prompt corrections and updates to the registrant's contact details throughout the term of the Registered Name registration,

7.5 in the case that a domain name is being registered in the name of an organization or other entity, the person acting on behalf of such organization or entity is authorized to do so;

7.6 the registrant agrees to be subject to and abide by the Sunrise and Verification, Sunrise Challenge Procedures, Qualification Challenge Procedures (as set forth in Appendices J and M), and the UDRP; and

7.7 violation of any of the provisions described in Subsections 7.1 through 7.6 of this Appendix L shall be grounds for termination to the registration, without any refund of fees to the registrant.

8. Verification Process.

8.1 General Information. Authorized Registrars shall enforce the registration restrictions described in this Appendix L and verify all registrants' right to register in the applicable PS-SLD as a condition of registration. Authorized Registrars may either carry out the verification manually (as set forth in Subsection 8.2 of this Appendix L), have the Registry Operator conduct the verification (as set forth in Subsections 8.2 or 8.3 of this Appendix L), or have an association or other entity conduct the verification (but only if such verification complies with the process set forth in Subsection 8.3 of this Appendix L). These verification procedures may be modified or supplemented by the procedures described in Section 5 of this Appendix L.

8.2 Manual Registration Verification. The Manual Verification will proceed as follows:

8.2.1 When an applicant applies for a .pro domain name through an Authorized Registrar, the Qualifications Menu for the appropriate PS-SLD will appear in a drop-down window in the Authorized Registrar's domain-name registration system.

8.2.2 The applicant will be required to check off one of the qualifications and provide supporting evidence of such qualification to the Authorized Registrar in order to register the requested domain name.

8.2.3 The Authorized Registrar will be required to comply with the following verification policies:

8.2.3.1 Obtain evidence of the applicable restriction (e.g., copy of a certificate of passage of a U.S. state bar exam);

8.2.3.2 Verify that the evidence submitted meets the required qualifications for the PS-SLD (such as being a type of evidence allowed in the qualification menu);

8.2.3.3 Compare the evidentiary information to the information in the applicant's application to verify that the evidence is representative of the particular applicant (e.g., does the name on the certificate match the applicant's name?);

8.2.3.4 Verify that the evidence is a current, accurate, and true representation of the qualification;

8.2.3.5 Obtain certification of the same from applicant;

8.2.3.6 Verify the registrant's identity or obtain information required by a CCA for the issuance of a digital certificate or other digital security products associated with such domain name (see Section 9); and

8.2.3.7 Agree to indemnify the Registry Operator against any challenges based on registrar's willful, negligent, or other non-compliance with above policies.

8.2.4 The Authorized Registrar will confirm to the Registry Operator receipt and verification of the evidence, and the Registry Operator will process the registration.

8.2.5 The relevant qualification of the registrant (basis of qualification, such as "medical license", and jurisdiction such as "NY-USA") will be provided by the Authorized Registrar to the Registry Operator and will appear in the Registry Operator's Whois record of the domain name registration.

8.2.6 The Authorized Registrar will retain the authoritative copy of the submitted and verified evidence for the period stated in its Registrar Accreditation Agreement, will transfer the evidence to a new repository in the event it ceases to be an Authorized Registrar as also stated in its Registrar Accreditation Agreement, and will also provide a copy to the Registry Operator.

8.2.7 In cases where the Registry Operator is providing the Manual Verification service to the Authorized Registrar, the Registry Operator will follow the process outlined in Subsections 8.2.2 - 8.2.6, except that the Registry Operator will provide the notices to the Authorized Registrar where such notice would be required from the Authorized Registrar to the Registry Operator and will retain the authoritative copy of the submitted evidence.

8.3 Verification Toolkit. The Registry Operator may offer Authorized Registrars the option to utilize verification services provided by Registry Operator ("Verification Toolkit") or by another entity to streamline the verification process. The procedure for the Verification Toolkit or such other entity is as follows:

8.3.1 When an applicant applies for a .pro domain name through an Authorized Registrar, the Qualifications Menu for the appropriate PS-SLD will appear in the Authorized Registrar's domain name registration system. An Authorized Registrar offering domain names in only one or a limited number of the PS-SLDs may provide a menu for only such PS-SLDs. An Authorized Registrar that is using the Verification Toolkit may indicate in that window the contact information for the Registry Operator. An Authorized Registrar that is using only one of the qualification methods for a PS-SLD is allowed to provide only that qualification in its registration system (instead of a full Qualification Menu). The applicant will be required to check off one of the qualifications and provide supporting evidence of that qualification in order to register the requested domain name. The supporting information will be provided either directly to the Registry Operator if the Authorized Registrar has included direct contact information (as set forth above) or to the Authorized Registrar. In the latter case, the Authorized Registrar will forward the applicant's application and evidence of qualification to the Registry Operator by electronic or other means.

8.3.1.1 The information provided to the Registry Operator shall include data required by a CCA for the issuance of a digital certificate or other digital security products associated with the domain name (see Section 9).

8.3.2 The Verification Toolkit will verify the registration application and qualification evidence under any of the following methods:

8.3.2.1 The applicant's standing will be verified with an appropriate credentialing organization, association, or entity providing verification services.

8.3.2.2 For an applicant who is a member of one of the associations in the RGPA (the RegistryPro Global Partnership of Associations, a group of professional associations, the members of which meet registration requirements as established according to this Appendix L), the applicant will provide his, her, or its membership identification in that association. The membership will be verified against the RGPA network of organizations' databases (and the name and identity of the applicant confirmed.)

8.3.3 The Registry Operator will notify the Authorized Registrar upon completion of the verification.

8.3.4 The relevant qualification of the registrant will appear in the Registry Operator's Whois record of the domain-name registration and the authoritative copy of the evidence will be maintained by the Authorized Registrar as required by its Registrar Accreditation Agreement.

8.3.5 The Verification Toolkit may be amended from time to time to include additional or revised professional categories, non-English abbreviations of professional categories, and qualifications that can be verified through the Verification Toolkit, provided that it performs a reasonably sound verification of the qualifications that are required for registration in the PS-SLDs. In the event that verification requirements or procedures are modified or supplemented, the Registry Operator will update the Verification Toolkit on the schedule specified in connection with the modification or supplementation, and consistent with the requirements of the Registry-Registrar Agreement (Appendix F).

8.3.6 Authorizing Toolkit Providers. Entities other than the Registry Operator may provide toolkits with functionality equivalent to the Verification Toolkit ("Competitor Verification Toolkits"), provided that they meet the requirements of Subsections 8.3.1 to 8.3.5 of this Appendix L. Competitor Verification Toolkit Providers must apply to the Registry Operator for approval.

8.3.6.1 Audits. Within a commercially reasonable amount of time an independent third party auditor designated by ICANN after consultation with the Registry Operator ("Independent Verification Auditor") or, on terms (including price and protection of trade secrets) approved by ICANN in writing where appropriate services of such an independent third-party auditor are not readily available, the Registry Operator (or a sub-contractor) will conduct a review of the Competitor Verification Toolkit Provider to verify that it complies with the .pro eligibility policies.

8.3.6.2 If the entity meets all required criteria, the Registry Operator will promptly authorize it as a Competitor Verification Toolkit Provider.

8.3.6.3 In the event that the entity does not pass this audit, the entity will be informed as to the reason it does not meet the criteria and be given the chance to correct the flaw and re-apply at a later date.

8.3.7 From time to time, at least annually, a compliance review will be conducted of the Competitor Verification Toolkit Provider to ensure that it continues to meet these criteria. The compliance review shall be performed by an Independent Verification Auditor or, on terms (including price and protection of trade secrets) approved by ICANN in writing where appropriate services of such an independent third-party auditor are not readily available, the Registry Operator or a sub-contractor.

8.3.8 Verification of Equal Treatment of Competitor Verification Toolkit Providers. The Registry Operator shall apply the same standards in an equal manner to all companies and other entities (including itself) acting as Verification Toolkit Providers or seeking to act as Verification Toolkit Providers. Among other aspects, this equal-treatment requirement means that the Registry Operator must ensure that Competitor Verification Toolkit Providers have equal access to becoming or designating members of the RGPA. The Registry Operator shall provide ICANN with access all documents requested by ICANN that are reasonably calculated to be used by ICANN in verification that this equal-treatment requirement has been met.

8.3.9 Insurance. All companies and other entities (including Registry Operator) acting as Verification Toolkit Providers shall maintain, from the date on which they are first approved to provide Verification Toolkits and for the duration of their approval, insurance from an insurance provider with an AM Best rating of "A" or better covering at least all claims (whenever made) arising from, in connection with, or related to the Verification Toolkit or any service provided by the provider in connection with the Verification Toolkit or its use. The insurance maintained by Competitor Verification Toolkit Providers shall name Registry Operator as an additional insured. The initially required minimum limits of the insurance shall be US$2,000,000 per occurrence and US$2,000,000 aggregate per policy year. Registry Operator may alter those minimum required limits uniformly for all Verification Toolkit Providers with ICANN's written consent by providing at least ninety days written notice to all Verification Toolkit Providers. (Any increase shall apply only to occurrences arising after the effective date of the increase.) Competitor Verification Toolkit Providers shall on Registry Operator's written request provide a copy of the insurance policy(ies) to the Registry Operator. Registry Operator shall upon ICANN's written request provide a copy of the insurance policy(ies) to ICANN.

8.4 Continued Professional Standing. The Registry Operator will require the Authorized Registrar sponsoring each .pro Registered Name periodically to re-verify continued qualifications of Registered Name Holders. Periodic re-verification may proceed under any of the methods described in Subsections 8.2 and 8.3 of this Appendix L.

8.4.1 Under Manual Verification, each registrant's qualification for the applicable PS-SLD must be verified on the anniversary of the registration date.

8.4.2 In cases of Toolkit Verification or Competitor Toolkit Verification, each registrant's qualification for the applicable PS-SLD must be verified on the anniversary of the registration date, using one of the methods allowed under Subsection 8.3.

8.4.3 At the time of Verification under 8.4.1 or 8.4.2, the information related to the issuance of the digital certificate or other digital security product associated with such domain name will be verified for continued accuracy.

8.4.4 A sponsoring Authorized Registrar that finds through the periodic verification or otherwise that a Registered Name Holder no longer qualifies for his, her, or its registration within a PS-SLD (including the digital security product requirements) must provide electronic and written notice to the Registered Name Holder and to the Registry Operator within seven days after such a finding.

8.4.5 A Competitor Verification Toolkit Provider that finds through the periodic verification that a Registered Name Holder no longer qualifies for his, her, or its registration within a PS-SLD (including the digital security product requirements) must provide electronic notice within seven days to the Sponsoring Registrar, which shall provide notice to the Registered Name Holder and to the Registry Operator according to the first sentence of Subsection 8.4.4.

8.4.6 If the Registry Operator (a) finds during a periodic verification process or is notified by an Authorized Registrar (see Subsection 8.4.3 above) that a Registered Name Holder no longer qualifies for a registration within a PS-SLD (including the digital security requirements), or (b) is notified by an Authorized Registrar of a reasonable basis to believe that any information in the Registry Operator's Whois database regarding a .pro domain name that the Authroized Registrar is sponsoring in the Registry is not accurate or reliable, the Registry Operator will within a commercially reasonable time lock down the domain name of such registrant so that it cannot be modified ("Registry Lock"). The Registry Operator will send an e-mail notice to the Registered Name Holder (at the contact e-mail address(es) shown in Whois) and the sponsoring Authorized Registrar that Registry Lock has been placed.

8.4.7 A Registered Name Holder whose domain name has been placed on Registry Lock will have fourteen days from the date e-mail notice of the lock has been sent to provide accurate information or otherwise respond to the finding set forth in Subsections 8.4.4 through 8.4.6 of this Appendix L. The following procedure will apply:

(i) In the case of a periodic verification by a sponsoring Authorized Registrar according to Subsection 8.4.4 or notification of inaccurate Whois information under Subsection 10.1,2, the Authorized Registrar will instruct the Registered Name Holder to direct his, her, or its response to the sponsoring Authorized Registrar. If the Registered Name Holder does not update the information or respond to the satisfaction of the sponsoring Authorized Registrar during the fourteen day period, or if the updated information does not pass the Registrar's verification, the registration will be cancelled and the Registered Name Holder forfeits all registration and associated fees.

(ii) In the case of a Registry Lock resulting from information from any source other than from a sponsoring Authorized Registrar, the Registered Name Holder will be directed by the Registry Operator to send his, her, or its response to the Registry Operator. If the Registered Name Holder does not update the information or respond to the satisfaction of the Registry Operator during the fourteen day period, or if the updated information does not pass verification, the registration will be cancelled and the Registered Name Holder forfeits all registration and associated fees.

8.4.8 Periodic Verification Fees. There may be a fee to the Registered Name Holder associated with a periodic verification, as determined by the sponsoring Authorized Registrar. There may be a fee to the sponsoring Authorized Registrar associated with a periodic verification performed with a Verification Toolkit, as determined by the supplier of the toolkit.

9. Digital Credentials. To enhance the security and trust of .pro domain names, the Registry Operator will require Authorized Registrars to provide digital certificates and other digital security services associated with each domain name.

9.1 Digital Credentials. Certificates serve as digital credentials and can be used to secure websites, e-mail communication, and other applications. Due to the unique nature of the .pro domain, these digital credentials are intended to assure that the domain name holder's identity has been verified and that the domain name holder has been verified to meet the qualifications in accordance with the guidelines described in this Appendix L. To ensure that all .pro digital security services meet these criteria and that consumers can easily establish a chain of trust, the Registry Operator will require that all certificates issued in conjunction with a .pro domain name chain back to a common certificate root, which will be administered by the Registry Operator. Commercial certificate authorities ("CCAs") that provide comparable services and comply with certificate issuing policies defined by the Registry Operator will be permitted to create certificate roots that chain back to the common .pro certificate root and provide the associated digital security services.

9.2 CCA Protocol. Due to the significant trust conveyed by the .pro digital security services, the Registry Operator will require that CCAs comply with the following baseline certificate issuing practices. This list is not intended to be comprehensive and the Registry Operator may modify the requirements for the provision of digital certificates and other digital security services in the future upon sixty days prior written notice to the Authorized Registrars and to ICANN. These requirements will apply equally to all providers (including the Registry Operator) seeking to provide digital certificates chaining back to the common .pro certificate root. Registry Operator's compliance with this equality requirement will be subject to verification as provided in Subsection 9.4 of this Appendix L.

9.2.1 CCAs must verify the identity of the individual or organization requesting the certificate. Certain trusted third parties may perform this function, provided that such all parties comply with the verification guidelines issued by the Registry Operator and certify they have done so to the Registry Operator.

9.2.2 For organizations, CCAs must verify that the request for the certificate is appropriately authorized. Certain trusted third parties may perform this function, provided that such all parties comply with the verification guidelines issued by the Registry Operator and certify they have done so to the Registry Operator.

9.2.3 CCAs must perform independent call-backs ("out-of-band" communications) to the individual or organization to validate certificate information.

9.2.4 CCAs will verify that the individual or organization requesting the certificate meets the registration requirements defined in this Appendix L. Certain trusted third parties may perform this function, provided that such all parties comply with the verification guidelines issued by the Registry Operator and certify they have done so to the Registry Operator.

9.2.5 CCA initial key size will be at least 1024 bits.

9.2.6 A trusted hardware device (FIPS 140-1 Level 3 certifiable) must be used to create, protect, and destroy the CCAs' private keys.

9.2.7 CCAs must have a clear "certificate policy", as defined by X.509 Amendment 1 to ISO/IEC 9594-8:1995.

9.2.8 CCAs must issue certificates complying with the X.509 standard.

9.2.9 CCAs must be capable of issuing both X.509 v1 and X.509 v3 type certificates.

9.2.10 CCAs must provide appropriate warranties and indemnities in respect of certificate issuing/verification and confirming credentials.

9.2.11 Upon notification from (a) the Registry Operator that the .pro domain name associated with a certificate is subject to a transfer request or has been transferred to another registrant or has been deleted, or (b) the Registry Operator or a trusted third party used to validate some of the requirements for certificate issuance that those requirements are no longer met, the CCA must revoke the certificate. The CCA must maintain a publicly available revocation list, and must transmit its revocation list to the Registry Operator at least daily, or such CCA may operate a real-time server that maintains a continuously updated list of revoked certificates.

9.3 Issuing Certificates. CCAs meeting these criteria may issue, manage and revoke certificates to .pro domain registrants. CCAs cannot authorize any other party to issue .pro digital certificates, although the certificates can be transmitted to the registrant either by the CCA or by the sponsoring Authorized Registrar for the .pro domain name associated with the certificate. CCAs desiring to issue .pro certificates must apply to the Registry Operator for approval.

9.3.1 Audits. Within a commercially reasonable amount of time, an independent third party auditor designated by ICANN upon consultation with the Registry Operator that provides auditing services in the digital security industry ("CCA Auditor") will conduct a review of the CCA to verify that it complies with the .pro certification policies.

9.3.2 If the auditor determines that the CCA meets all required criteria, the Registry Operator will promptly use the .pro CA root key to sign the CCA's key used for .pro certificates.

9.3.3 In the event that the CCA does not pass this audit, the CCA will be informed as to the reason it does not meet the criteria and be given the chance to correct the flaw and re-apply at a later date.

9.3.4 From time to time, at least annually, a CCA Auditor will conduct a review of the CCA to ensure that it continues to meet this criteria.

9.4 Verification of Equal Treatment of CCAs. The Registry Operator shall apply the same standards in an equal manner to all companies (including itself) acting as CCAs or seeking to act as CCAs. The Registry Operator shall provide ICANN with access all documents requested by ICANN that are reasonably calculated to be used by ICANN in verification that this requirement has been met.

9.5 Chaining Fee. The Registry Operator may charge sponsoring Accredited Registrars a chaining fee associated with each certificate to cover administrative, licensing and associated costs born by the Registry Operator, provided that such chaining fee may be billed by the Registry Operator to the CCAs. The chaining fee will be charged in compliance with Subsection 3.4.3 of the Registry Agreement.

10. Implementation by Authorized Registrars. Authorized Registrars will be required to (a) collect and verify evidence of professional credentials from all registrants showing their qualification for the professional category in which they wish to register (see Section 8 of this Appendix L), (b) provide digital certificates and other digital security services associated with each domain name, and (c) examine trademark information for Sunrise Registrations (see Appendix J), before the Registry Operator will process domain name applications.

10.1 Compliance by Authorized Registrars.

10.1.1 Each Authorized Registrar will be required to comply with the restrictions, requirements, and policies in Appendices J, L, and M, as well as other matters covered in its Registrar Accreditation Agreement with ICANN and in its Registry-Registrar Agreement ("RRA") (Appendix F) with the Registry Operator.

10.1.2 If an Authorized Registrar learns of a reasonable basis to believe that any information in the Registry Operator's Whois database regarding a .pro domain name that it is sponsoring in the Registry is not accurate or reliable, the Authorized Registrar shall provide electronic and written notice to the Registered Name Holder and to the Registry Operator within seven days after learning of that basis. See Subsection 8.4.6 for follow-up procedures.

10.1.3 Each Authorized Registrar will be required to verify continued eligibility of a registrant no less frequently than on an annual basis.

10.1.4 If it comes to the Registry Operator's attention that an Authorized Registrar is not complying with the restrictions and policies described in Subsections 10.1.1 to 10.1.3 of this Appendix L, the Registry Operator will send prompt electronic and written notice to the Authorized Registrar, with a copy by the same method to ICANN, describing the restrictions and policies being violated. The ensuing procedure concerning the Authorized Registrar's eligibility to continue to sponsor Registered Names (including suspension and de-accrediation) in the .pro registry is governed by the RRA (Appendix F) and the Registrar Accreditation Agreement.

10.2 Domain Names Sponsored by Ineligible Authorized Registrars. If an Authorized Registrar's accreditation by ICANN for .pro is terminated or expires without renewal, or its RRA is terminated or expires without renewal, the following procedure will be followed:

10.2.1 The domain names already registered up to that point in time will remain registered in the .pro TLD. Those domain names, together with the verification documentation or information for such domain name held by the Ineligible Authorized Registrar, will be transferred to another Authorized Registrar upon proper transfer notice made by the gaining Authorized Registrar or, in the absence of such notice, designated by ICANN.

10.2.2 Applicants for .pro names working with such Ineligible Authorized Registrar will be notified to switch to another Authorized Registrar. The Ineligible Authorized Registrar is required to send the eligibility documentation submitted by each applicant to the new Authorized Registrar chosen by such applicant.

11. Disclaimer. The provisions of this Registry Agreement (including Appendices J, L, and M) shall not create any actual or potential liability on the part of Registry Operator to any person or entity other than ICANN in connection with any dispute concerning any Registered Name or other Registry Service, including the decision of any dispute resolution proceeding related to any of the foregoing.

Earlier draft:

14 February 2002