Report of Public Comments for the Proposal to Mitigate Name Collision
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Report of Public Comments Title: Proposal to Mitigate Name Collision Risks Publication Date: 5 August 2013 Prepared By: Francisco Arias & Russ Weinstein Comment & Reply Period: Important Information Links Comment Open Date: 5 August 2013 Comment Close Date: 27 August 2013 Announcement Reply Open Date: 28 August 2013 PuBlic Comment Box Reply Close Date: 17 SeptemBer 2013 View Comments SuBmitted Report of PuBlic Comments Time (UTC): 23:59 Staff Contact: Cyrus Namazi Email: [email protected] Section I: General Overview and Next Steps ICANN solicited puBlic comment from 5 August to 17 SeptemBer on the proposal to mitigate the collision risks Between new gTLDs and existing private uses of the same strings. ICANN received over 70 comments in the period from a range of sources, including applicants and those affiliated with applicants, corporations not affiliated with applicants, various non-DNS related industry organizations, and various DNS related industry organizations. Some key themes expressed in the comments included: The approach or methodology of the study “Name Collisions in the DNS” The categorization of the TLD’s into the risk profiles The assessment of the risks of name collision in the study “Name Collisions in the DNS” Support or criticism of the proposed risk mitigation tactics Alternative methods for risk mitigation The next steps will Be for ICANN to consider refining the proposal Based on the input from the community and for the ICANN Board New gTLD Program Committee (NGPC) to consider the issue. Section II: Contributors At the time this report was prepared, a total of eighty one (81) community submissions had been posted to the Forum. The contributors, both individuals and organizations/groups, are listed below in chronological order by posting date with initials noted. To the extent that quotations are used in the foregoing narrative (Section III), such citations will reference the contributor’s initials. Organizations and Groups: Name Submitted by Initials New gTLD Applicant Group (NTAG) Tim Switzer, Chair TS H.J. Heinz Company (Heinz) Sabrina J. Hudson SJH 1 DotGreen Community (DotGreen) Annalisa Roger, Founder/CEO AR Commonwealth Bank of Australia Cate CoBBy, Online Channel CC, AK Development Manager & Alban Kwan, New gTLD Manager, Asia Pacific Verizon Sarah B. Deutsch SBD Top Level Design LLC (Top Level Design) Andrew Merriam, Business AM Development Coordinator ARI Registry Services Yasmin Omer, Policy & Industry YO Affairs Officer CloudNames AS (CloudNames) Michael B. Halvorsen, VP Product MBH and Services dotBERLIN GmBH & Co. KG (dotBERLIN) Dirk Krischenowski, Founder and DK CEO TLDDOT GmBH (.GMBH) Dirk Krischenowski, Managing DK Director Registries Stakeholder Group (RySG) & Verisign Keith Drazek, Chair KD Minority Statement to RySG DotHome Inc. Brihesh Joshi BJ Radix Registry Brihesh Joshi BJ General Electric Company (GE) Kathryn Barrett Park , Senior KBP Counsel, Advertising and Brand Management American Insurance Association (AIA) Angela Gleason, Associate Counsel AG Internet Service Providers and Connectivity Mike O’Connor, Rapporteur MO Providers (ISPCP) Intellectual Property Owners Association (IPO) HerBert C. Wamsley, Executive SJ Director Neustar, Inc. (Neustar) Jeffrey J. Neuman, Vice President, JJN Business Affairs HOTEL Top-Level-Domain S.a.r.l. (HOTEL Top- Johannes Lenz-Hawliczek, Managing JL Level-Domain) Director Association of National Advertisers (ANA) Daniel L. Jaffe, Group EVP, DLJ Government Relations Afnic/CORE on Behalf of City of Paris (AFNIC/ Werner StauB WS CORE) Association for Competitive Technology (ACT) Jonathan V. Zuck, President JVZ At-Large Advisory Committee (ALAC) Heidi Ullrich, et al. HU et al. Verisign Inc. (Verisign-PSK & CG) Chuck Gomes, VP Policy PSK, CG Verisign Inc (Verisign-PSK & RHG) Patrick S. Kane, Senior Vice PSK, RHG President, Naming Services, and Richard H. Goshorn, Senior Vice 2 President, General Counsel & Secretary Uniregistry Corp. (Uniregistry) Bret A. Fausett BAF Fundacio puntCAT Nacho Amadoz, Legal Manager NA Verisign Inc. (Verisign-DM) Danny McPherson, CSO DM Donuts Paul Stahura PS Artemis, Big Room Inc., Charleston Road Reg Levy RL Registry, CORE Association, Donuts, Dot Registry LLC, Minds + Machines, NIC.Br, Top Level Design, United TLD, XYZ.com (Joint Comments of Artemis et al.) XYZ.com LLC (XYZ.com) Grant Carpenter, General Counsel GC .CluB Domains LLC (.CluB Domains) Colin CampBell, CEO and Chairman CC DigiCert, Inc. (DigiCert) Jeremy Rowley JR NetChoice Steve DelBianco., Executive Director SD Verisign, Inc. (Verisign-EO) Eric Osterwell, Ph.D, Principal EO Scientist Verisign, Inc. (Verisign-PSK, TCI & DM) Patrick S. Kane, Senior Vice PSK, TCI, President; Thomas C. Indelicarto, DM Vice President & Associate General Counsel, & Danny McPherson, Chief Security Officer .CluB Domains LLC (.CluB Domains) Dirk Bhagat, Chief Technology DB Officer Association of National Advertisers (ANA) Dan Jaffe, Group Executive Vice President, Government Relations Monash University Fiona Andrewartha, Project Manager FA Online Trust Alliance (OTA) Craig Spiezle, Executive Director & CS President Internet Service Provider and Connectivity Tony Holmes, Chairman TH Providers Constituency (ISPCP) Association for Competitive Technology (ACT) Jonathan V. Zuck, President JVZ Business Constituency (BC) Steve DelBianco, Vice Chair for Policy SD Coordination U.S. Council for International Business (USCIB) BarBara P. Wanner, Vice President, BPW ICT Policy eco VerBand der deutschen Internetwirtshcaft Klaus Landefeld & Thomas Rickert KL, TR (eco) Internet Service Provider and Connectivity Mikey O’Connor MO Providers Constituency (ISPCP) US Telecom Kevin G. Rupy, Senior Director, Policy KGR 3 Verizon Sarah B. Deutsch, Vice President & SBD Deputy General Counsel DotGreen Community, Inc. (DotGreen) Annalisa Roger, Founder/CEO AR Neustar, Inc. (Neustar) J. Beckwith Burr, Deputy General JBB Counsel New Mexico Electric Cooperatives Eli D. EilBott, Counsel EDE Top Level Design LLC (Top Level Design) Andrew Merriam, Business AM Development Coordinator United TLD Wayne MacLaurin, Senior Vice WM President of Technology JAS GloBal Advisors & simMachines Jeff Schmidt & Arnoldo Muller- JS, AMM Molina Verisign, Inc. (Verisign-EO) Eric Osterwell, Ph.D, Principal EO Scientist The Chertoff Group Michael Chertoff, Chairman LLW Uniregistry, Corp. (Uniregistry) Bret Fausett BF New TLD Applicant Group MemBers (NTAG Tim Switzer, Chair TS MemBers) Microsoft Corporation, Verisign, Inc. and David Tennenhouse, Corporate Vice DT, PSK, Yahoo! Inc. (Microsoft-Verisign-Yahoo Joint President, Technology Policy, JSE Comments ) Microsoft; Patrick S. Kane, Senior Vice President, Naming and Directory Services, Verisign; J. Scott Evans, Head of GloBal Brand, Domain & Copyright, Yahoo! Intellectual Property Constituency (IPC) Claudio DiGangi, IPC Secretary CD Donuts Chris Cowherd, CTP CC Google Inc. Ben Fried, Vice President and Chief BF Information Officer Artemis Internet Inc. (Artemis) Alex Stamos, CTO AS .CluB Domains LLC (.CluB Domains) Dirk Bhagat DB Afilias Limited (Afilias) John Kane, Vice President JK Individuals: Name Affiliation (if provided) Initials Andrew Snow (A. Snow) AS Scott Golightly (S. Golightly) SG Daniel KarrenBerg (D. KarrenBerg) Chief Scientist, RIPE NCC DK Glen Gulyas (G. Gulyas) Affinity Discount Stores, Inc. GG Stephen Forte (S. Forte) SF Jeffrey Broer (J. Broer) Grayscale Ltd. Hong Kong JB 4 Mikey O’Connor (M. O’Connor) MO Warren Kumari & Danny McPherson (W. WK, DM Kumari & D. McPherson) Damir Tomicic (D. Tomicic) Chief Executive Officer, Axinom DT Andrew Sullivan et al. (A. Sullivan et al.) Dyn, Inc. AS Section III: Summary of Comments General Disclaimer: This section is intended to broadly and comprehensively summarize the comments submitted to this Forum, but not to address every specific position stated by each contributor. Staff recommends that readers interested in specific aspects of any of the summarized comments, or the full context of others, refer directly to the specific contributions at the link referenced above (View Comments Submitted). Comments on Study and Staff Proposal Timing ALAC remains concerned that this matter is Being dealt with at such a late stage of the New gTLD Process. ALAC urges the Board to investigate how and why this crucial issue could have Been ignored for so long and how similar occurrences may be prevented in the future. ALAC (27 Aug. 2013) While IPC welcomes ICANN’s identification of the name space collision issue and proposals for mitigation, ICANN’s actions at this late stage reduce external institutional confidence in ICANN, inject a degree of douBt into, and magnify potential security risks associated with, the new gTLD process. IPC (17 Sept. 2013) It is difficult to understand why the Interisle report was rushed at the last minute, when the collision issue and other stability issues have Been so thoroughly examined for so long over the more than 8- year process leading to new TLDs. Staff has inexplicably migrated to a new process; the community was denied the opportunity to contriBute to the discussion Before any report was produced and implemented (demonstrated By the unilateral decision to delay contracting for TLDs in the 20%). Instead the community was presented with a fait accompli statement aBout what should happen and what is happening without sufficient regard for accurate data due to the rushed nature. Donuts (27 Aug. 2013); Joint Comments of Artemis et al. (27 Aug. 2013) A last-minute challenge to new gTLD applications,