Report on the Transfer of the .LB (Lebanon) top-level domain to the Internet Society Lebanon

21 January 2024

This report is a summary of the materials reviewed as part of the process for the transfer of the .LB (Lebanon) top-level domain. It includes details regarding the proposed transfer, evaluation of the documentation pertinent to the request, and actions undertaken in connection with processing the transfer.

Factual Information

Country

The “LB” ISO 3166-1 code from which the application’s eligibility derives is designated for use to represent Lebanon.

Chronology of Events

In 1993, the .LB top-level domain was delegated by IANA to Nabil Bukhalid at the American University of Beirut (AUB). For nearly thirty years, the domain’s management was led by Mr. Bukhalid, who reported to us that he was supported by volunteers from AUB and the technical contact, Randy Bush.

On 3 February 2008, the Lebanese Council of Ministers issued Decree No. 103/86 and approved a request from the Ministry of Telecom to transfer .LB from AUB to Ogero, a state-owned telecommunications operator. However, Ogero never sought a transfer from IANA and AUB remained the designated manager of the .LB top-level domain.

On 20 December 2011, the Internet Society Lebanon (also known as “ISOC-LB” or “مجتمع الانترنت في لبنان” in Arabic), was established as an association by Notice Statement No. 2073, published in the Lebanese Official Gazette.

In 2012, the E-Transaction draft law was issued under Decree No. 9341, giving the Ministry of Economy and Trade (MoET) the role of sponsoring the .LB domain registry. As a result, MoET and Mr. Bukhalid reportedly established a formal relationship and updated the .LB top-level domain’s registration policies. They also began discussions around developing a more sustainable structure for the .LB registry with multistakeholder governance.

In August 2012, Mr. Bukhalid left AUB and informed MoET that AUB would continue hosting the .LB database while he would manage its operations.

In February 2013, Fadi Chehadé, ICANN’s then CEO, met with several members of the Lebanese government and other Internet stakeholders in Lebanon. Among the topics discussed were the benefits of moving to a bottom-up, multistakeholder model of administration for the .LB top-level domain.

After a year of comprehensive discussions, the Lebanese Internet community ratified general bylaws and internal bylaws for a not-for-profit association to manage the .LB top-level domain. On 2 June 2014, the Lebanese Internet Center (LINC) was established as an association for this purpose at the Ministry of Interior.

On 13 June 2014, LINC’s first board was elected and it appointed Mr. Bukhalid as its CEO. LINC intended to submit a transfer request to IANA and apply for an Arabic-script ccTLD. However, it informed IANA it was ultimately unable to operate in Lebanon due to recognition issues within the country under government regulations.

On 16 June 2017, AUB notified Mr. Bukhalid that it did not want to continue hosting .LB’s servers and associated infrastructure. Subsequently, AUB provided IANA with a letter of consent for the transfer of the .LB top-level domain from AUB to either LINC or ISOC-LB.

In October 2018, Law No. 81/2018 Relating to Electronic Transactions and Personal Data was ratified and published in the official gazette. Articles 79 and 80 of Part IV of the Law address the management of the .LB top-level domain:

“Under the present Law, a body shall be established under the name of the ‘Lebanese Domain Name Registry’ (LBDR). LBDR's mandate is to manage and register the names of websites, including websites featuring the Lebanese domains (.lb) and (.‫ (ﻟﺒﻨﺎن‬in their names…LBDR shall be comprised of representatives from the Ministry of Telecommunications, the Ministry of Economy and Trade, the Ministry of Finance, the Ministry of Justice, the Minister of State for Administrative Development, the Telecommunications Regulatory Authority, the Federation of Chambers of Commerce, Industry and Agriculture, the Bar Association and representatives of three to five associations operating in this sector…LBDR shall define the administrative and technical terms and conditions for granting and managing the Lebanese domain names and accredited registrars subject to the rules set out by the international domain name registration bodies.”‬‬

On 7 June 2020, AUB announced that it would stop hosting .LB’s infrastructure. Mr. Bukhalid consulted with LINC’s Board and the Prime Minister's Office and was directed to work with the Office of the Minister of Administrative Reform (OMSAR) on a plan to transfer the .LB top-level domain to LINC.

On 30 June 2020, AUB, ISOC-LB, and Mr. Bukhalid informed OMSAR of the urgent need to transfer the .LB top-level domain to a multistakeholder entity and relocate .LB’s infrastructure away from AUB. Given challenging political events at that time in Lebanon, they concluded that the best option would be to again try to establish LINC. OMSAR worked with MoET, the Ministry of Telecommunication, and the Ministry of Interior on this project. At the same time, Mr. Bukhalid was tasked with developing a roadmap to transfer .LB’s infrastructure to a cloud-hosted registry system and anycast DNS services, and preparing the transfer application for the .LB top-level domain to LINC.

In July 2020, AUB reportedly terminated the contracts of its two employees who had volunteered part of their time to help manage the .LB top-level domain and notified Mr. Bukhalid that they considered him the responsible party for the management of the .LB top-level domain.

In early September 2020, Mr. Bukhalid reportedly was informed by OMSAR that they could not proceed with establishing LINC and that Mr. Bukhalid would continue to be responsible for the administration of the .LB top-level domain.

On 23 September 2020, AUB notified Mr. Bukhalid and OMSAR that it would be decommissioning the services hosted on AUB infrastructure no later than 30 September 2020. Mr. Bukhalid stated he negotiated an extension with AUB to retain some infrastructure until 30 May 2021 and began migrating .LB’s services to a third-party registry service provider, COCCA.

On 12 October 2020, the President of the Republic of Lebanon and the Prime Minister gave Mr. Bukhalid exceptional approval for “securing the management and hosting of the Government domain name data with entities that he enters into contractual agreement with on his responsibility, similar to the other (.lb) domain zones.”

In December 2020, the migration of .LB’s infrastructure to COCCA was completed. AUB retained some infrastructure that was supporting .LB at this time.

In 2021, Mr. Bukhalid incorporated LBDR LLC in the United States as a limited liability company.

In 2021, AUB asked IANA to remove its contact information from .LB’s delegation record in the IANA database, given their lack of involvement in its current operation. It also asked IANA to work with Mr. Bukhalid to transfer .LB to LBDR LLC.

On 3 January 2023, Mr. Bukhalid passed away unexpectedly and the request to transfer .LB to LBDR LLC was withdrawn. Known associates of Mr. Bukhalid notified IANA that they would continue operating the domain. As circumstances clarified, ISOC-LB was identified as a potential place to rehome these operations on a permanent basis.

In March 2023, the last remaining infrastructure that had been hosted by AUB was moved to Beirut-IX.

On 7 March 2023, the Minister of State for Administrative Development sent a request to the attention of the General Secretariat of the Council of Ministers regarding the continuity of managing and hosting the data of Lebanese domain names. The request noted that Mr. Bukhalid, a Vice President of ISOC-LB, had managed .LB from its inception until he passed away. It also noted that the circumstances in Lebanon have prevented the establishment of a committee to manage .LB according to the e-transaction law. Given these circumstances, she suggested the extraordinary approval of transferring the duties of managing .LB to Mr. Jacques George Bakaev, the Secretary of ISOC-LB. On 4 May 2023, the Prime Minister of Lebanon approved this request.

AUB wrote to IANA again and asked to be removed from the .LB delegation record. In response, IANA explored with ICANN and key community stakeholders how such a request could be implemented in compliance with policies. ICANN approved IANA’s proposal in May subject to some additional engagement with stakeholders.

On 13 July 2023, ISOC-LB formally submitted its transfer request to IANA.

On 14 July 2023, IANA finalized removing AUB from the .LB delegation record and placed the domain in “Caretaker Operations”. In external communications around this topic, IANA confirmed that this was a temporary measure until such time as a transfer could be successfully completed.

Proposed Manager and Contacts

The proposed manager is the Internet Society Lebanon.

The proposed administrative contact is Jacques Bakaev, Secretary of ISOC-LB.

Randy Bush will continue in his role as the technical contact.

Evaluation of the Request

String Eligibility

The top-level domain is eligible for transfer as the string for Lebanon is presently listed in the ISO 3166-1 standard.

Incumbent Consent

The previous manager is the American University of Beirut. Informed consent for the transfer of the .LB top-level domain to ISOC-LB was provided by Yousif Asfour, the Chief Innovation and Transformation Officer at AUB.

Public Interest

Najib Mikati, the Prime Minister of Lebanon, has granted exceptional approval for the transfer to ISOC-LB.

Statements of support were also provided by the following:

Camille Moukarzel, President of the Professional Computer Association of Lebanon (PCA). PCA is a Lebanese association made up of companies representing the ICT industry in Lebanon.
Roula Mikhael, the Founder and Executive Director of the Maharat Foundation, a Beirut based non-governmental organization working on advancing freedom of expression, media freedom, and promoting information integrity offline and online.
Mohamad Najem, President of Social Media Exchange, a regional digital rights organization based in Beirut.
Maroun N. Chammas, President and CEO of Berytech, a business incubation and innovation center that provides a conducive environment and technical assistance to more than 50 startups over three campuses in Beirut.
Fadi Khoneisser, Administrator of the Beirut Internet eXchange Point (Beirut-IX). Beirut-IX is an IXP whose objectives are to remain a neutral, open Internet exchange where service providers and content providers can connect and peer with each other, stimulating economic growth, prosperity, and stability for Lebanon.

The proposed manager undertakes the responsibility to operate the domain in a fair and equitable manner.

Based in Country

The proposed manager is constituted in Beirut, Lebanon.

The proposed administrative contact is a resident of Lebanon.

Stability

The .LB top-level domain is currently operated by former associates of Bukhalid who will continue to do so under ISOC-LB. Given AUB has already disavowed its participation in operating .LB, a comprehensive transfer plan was not necessary. The registry's physical infrastructure is based on cloud infrastructure, hosted by COCCA.

The application is not known to be contested in a manner that would require significantly interested parties to reach agreement amongst themselves prior to proceeding.

Competency

The application has provided information on the technical and operational infrastructures and expertise that will be used to operate the domain.

Proposed policies for management of the domain have also been tendered.

Evaluation Procedure

PTI is tasked with coordinating the Domain Name System root zone as part of a set of functions governed by a contract with ICANN. This includes accepting and evaluating requests for delegation and transfer of top-level domains.

A subset of top-level domains are designated for the significantly interested parties in countries to operate in a way that best suits their local needs. These are known as country-code top-level domains (ccTLDs), and are assigned to responsible managers that meet a number of public-interest criteria for eligibility. These criteria largely relate to the level of support the manager has from its local Internet community, its capacity to ensure stable operation of the domain, and its applicability under any relevant local laws.

Through the IANA functions performed by PTI, requests are received for delegating new ccTLDs, and transferring or revoking existing ccTLDs. An investigation is performed on the circumstances pertinent to those requests, and the requests are implemented where they are found to meet the criteria.

Purpose of Evaluations

The evaluation of eligibility for ccTLDs, and of evaluating responsible managers charged with operating them, is guided by a number of principles. The objective of the assessment is that the action enhances the secure and stable operation of the Internet’s unique identifier systems.

In considering requests to delegate or transfer ccTLDs, input is sought regarding the proposed new manager, as well as from persons and organizations that may be significantly affected by the change, particularly those within the nation or territory to which the ccTLD is designated.

The assessment is focused on the capacity for the proposed manager to meet the following criteria:

The domain should be operated within the country, including having its manager and administrative contact based in the country.
The domain should be operated in a way that is fair and equitable to all groups in the local Internet community.
Significantly interested parties in the domain should agree that the prospective manager is the appropriate party to be responsible for the domain, with the desires of the national government taken very seriously.
The domain must be operated competently, both technically and operationally. Management of the domain should adhere to relevant technical standards and community best practices.
Risks to the stability of the Internet addressing system must be adequately considered and addressed, particularly with regard to how existing identifiers will continue to function.

Method of Evaluation

To assess these criteria, information is requested from the applicant regarding the proposed manager and method of operation. In summary, a request template is sought specifying the exact details of the delegation being sought in the root zone. In addition, various documentation is sought describing: the views of the local internet community on the application; the competencies and skills of the manager to operate the domain; the legal authenticity, status and character of the proposed manager; and the nature of government support for the proposal.

After receiving this documentation and input, it is analyzed in relation to existing root zone management procedures, seeking input from parties both related to as well as independent of the proposed manager should the information provided in the original application be deficient. The applicant is given the opportunity to cure any deficiencies before a final assessment is made.

Once all the documentation has been received, various technical checks are performed on the proposed manager’s DNS infrastructure to ensure name servers are properly configured and are able to respond to queries correctly. Should any anomalies be detected, PTI will work with the applicant to address the issues.

Assuming all issues are resolved, an assessment is compiled providing all relevant details regarding the proposed manager and its suitability to operate the relevant top-level domain.