comments from .SAARLAND

[Alexander Siffrin <asiffrin@xxxxxxxxxxxxxxx>]

Dear Madam or Sir,

dotSaarland GmbH hereby thanks ICANN for the opportunity to comment on the 
study report and the recommendations for a better plan to mitigate the risks of 
DNS Namespace Collisions. We also thank JAS Global Advisors for their work so 
far and their thoughtful insights into the nature of the Name Collision

The current stop-gap solution detailed in the Collision Occurence Management 
Plan removes from activation in a zone many strings critical for the success of 
the new gTLDs. Especially for geographic TLDs, the elimination of important 
strings of government body names, names of regions or cities, or common 
occupations, services or products from activation for an undefined term 
constitutes a factor that will impact the success of the TLD in internet user 
adoption to no small degree. For example, if  domain names such as the name of 
the capital city of the state the TLD string stands for remains unavailable 
indefinitely in the TLD, consumer confidence in the TLD may suffer. On the 
other hand, there has so far not been any conclusive evidence that the 
activation of any of these names poses an actual risk for third party harm.

Therefore we appreciate the recommendations of the study as a solution that 
allows for an activation of the affected strings in the DNS while providing a 
clearer, more targetted approach to identify actual risks as opposed to a 
blanket prohibition of all potential, but probably non-existing risk. Both the 
test-activation in the zone and the wildcard solution proposed in the report 
show a more measured approach that will help identify those cases where an 
actual harm is manifest and a blocking from activation is warranted versus 
those cases where an activation poses no actual risk for harm.

We hope that the final report be produced as soon as possible and the proposed 
recommendations are quickly implemented to allow for a clear path to activation 
for those strings currently blocked by the current Collision Occurence 
Management Plan.

Sincerely,

Alexander Siffrin
CEO, dotSaarland GmbH