Objection and Dispute Resolution Procedures as Denial of Service attack

[Avri Doria <avri@xxxxxxx>]

The objection procedures as currently defined could act as a Denial of Service, 
or even a Distributed Denial of Service attack against an applicant.

In the case of an applicant who is challenged by many similar objections, while 
it is possible for them to be consolidated, there is no provision for an 
extension of time while the consolidation is being considered.  Even seven days 
while waiting for the consolidation decision is 1/4 of the time available to 
respond. In the case of a very large number of objections, this may be punitive 
in effect and may prevent the applicant from completing all the responses in 
the required time.

Additionally if a very large number of similar but non consolidated objections 
are submitted, it may be impossible for the applicant to respond to all of the 
objections, with each one requiring a separate response and a separate fee; i.e 
the DDOS attack.  The many to one relationship between possible objectors and a 
single applicant is an inherent scaling problem in the application process that 
needs to be addressed with modified time limits and batch costing.

Avri Doria
Individual Comment