Uniregistry Comment on Names

[Bret Fausett <bret@xxxxxxxxxxxx>]

Thank you for the opportunity to comment on the Proposal to Mitigate Name 
Collision Risks, published on August 5, 2013. This comment is submitted on 
behalf of Uniregistry Corp., an applicant for over fifty top-level domains.

At the outset, we wish to commend the work performed by Interisle Consulting 
Group. The Interisle research was well done, and the study addresses issues 
squarely within ICANN’s remit.

At the same time, after reviewing the report and the underlying data, we 
believe it is necessary to separate the data from the conclusions to be taken 
from that data and the recommendations on how to handle any concerns. The data, 
while accurate, may not support the recommendations on how to handle issues 
arising from that data.

The data does not suggest any answer to whether the concerns raised by the 
report are actual threats (i.e. that they will happen and will harm people), 
conjectural threats (i.e. that they could happen but it is unclear whether they 
will happen either by accident or intent or whether anyone would be harmed), 
hypothetical threats, or not threats at all. DNS-traffic does not equal a 
“security problem.”

The sole fact that queries are being received at the root level does not itself 
present a security risk, especially after the release to the public of the list 
of applied-for strings.

Our proposal, is to continue to move forward with the current timeline, and 
include a trial delegation in an ICANN controlled environment with external 
observers. This will allow for additional traffic collection which would lead 
to a real assessment of the risks associated with the new TLD and to the 
implementation of reasonable measures to mitigate them. This can all be done in 
a timely manner with minimal or no impact on the current timeline.

Thank you for the opportunity to comment, and we expect to file additional 
comments during the Reply period.

Bret A. Fausett
Counsel to Uniregistry, Corp.