.CLUB response to Verisign

[Dirk Bhagat <dirk.bhagat@xxxxxxxxx>]

*In response to the comment filed by Verisign “Illustrating the Need to
Undertake Qualitative Impact Assessments for Applied-For Strings: .WEBSITE,
.COFFEE, and .CLUB.”
We find it interesting that Verisign has chosen to single out .CLUB given
the fact that .CLUB represents a fraction of a percent of the query volume
of the high risk names.  Further, Verisign makes claims based on data that
is only available to Verisign, and not the DITL data provided by Interisle,
an independent third-party.

Nothing in the Verisign comment changes the fact that, as per ICANN’s
original instructions, and using the same Interisle data that ICANN used
for it’s analysis, .CLUB has clearly demonstrated that it has the ability
to mitigate risk to well within the “low risk” benchmarks provided by ICANN
by blocking the 50 most queried SLD’s.  There is nothing contained in
Verisign’s comment that would change the fact that blocking the top 50
queried SLD’s would sufficiently mitigate any potential risk.
*