CBA Comments on ICANN Name Collision Report

[Alban Kwan <alban.kwan@xxxxxxxxxxxxxxxxxx>]

To the ICANN Board,

Commonwealth Bank of Australia, the applicant .cba, .netbank and .commbank, are 
greatly concerned about the delay caused by the Name Collision report.   We 
believe that the .cba TLD should not pose a "high risk" to the internet 
security and would like to discuss directly with ICANN/SSAC on the risk 
assessment.  After some internal investigation, we would like to comment that:



1.       CBA believes that the '.cba' gTLD should be categorised as low risk



2.       The high number of .cba references observed at the root DNS level is 
due to:



a.       CBA internal systems and applications make extensive use of '.cba' as 
a strictly internal domain.



b.      Externally signed '.cba' certificates for CBA internal use



3.       As the cause of the name collision is primarily from CBA internal 
systems and associated certificate use, it is within the CBA realm of control 
to detect and remediate said systems and internal certificate use.



4.       CBA will undertake internal investigation to verify the origins of the 
'.cba' request and specifically how these requests are flowing into the 
Internet. appropriate remediation will occur upon completion of these 
investigation to resolve the collisions.



5.       As the owner of the '.cba' gTLD as well as the internal application 
systems and certificates noted above, CBA is strongly motivated to identify and 
remediation the sources of name collision in a timely manner.


Submitted on Behalf of:
Cate Cobby

Online Channel Development Manager

Commonwealth Bank of Australia

Alban Kwan
New gTLD Manager, Asia Pacific
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