ARI Registry Services comments on Name Collision
ARI Registry Services welcomes the study report by JAS Global Advisors "Mitigating the Risk of DNS Namespace Collisions". The report is sound and for the most part, ARI Registry Services supports the recommendations, with the exception of Recommendations 6 and 7 which call for a 120 day controlled interruption periods. RECOMMENDATION 6: ICANN require new TLD registries to publish the controlled interruption zone immediately upon delegation in the root zone. After the 120 day period, there shall be no further collision related restrictions on the registry. RECOMMENDATION 7: ICANN require registries that have elected the "alternative path to delegation," rather than a wildcard, instead publish appropriate A and SRV resource records for the labels in the ICANN 2LD Block List to the TLD's zone with the 127.0.53.53 address for a period of 120 days. After the 120 day period, there shall be no further collision related restrictions on the registry. The report provides no valid reason for requiring the 120 day controlled interruption period except that it is consistent with the benchmark set by 120 day CA Revocation period, which the report acknowledges is overly conservative. In public sessions, JAS has also explained the reason for the 120 day period is that controlled Interruption impacts different systems differently; and there is a wide variance in time required for detection and remediation. They have also explained that they are conscious of quarterly batching processing cycles. Given that JAS has acknowledged that the 120 day period is overly conservative and that quarterly cycles are 90 days, there does not appear to be solid justification for the 120 day controlled interruption periods, rather it seems that the 120 day period is arbitrary at best and not able to be substantiated in any legitimate way. We would ask that consideration be given to reducing the controlled interruption period to 38 days based on the following rationale. The Expired Registration Recovery Policy (ERRP) requires that Registrars interrupt resolution for domains which in all probability are receiving legitimate traffic right up until the moment the Registrar activates its required interruption. This period is analogous to the controlled interruption period JAS advocates in Recommendations 6 and 7. In both cases there is an education component to the interruption and a mechanism to remedy. Note however, that in the case of the ERRP after 8 days, the expired domain is removed from the TLD zone when the Registrar deletes the name. While the Registry must provide an opportunity for the Registrant, through the Registrar, to redeem the domain via a 30 day Redemption Grace Period (RGP), the consumer education element of ERRP (via DNS interruption) has already ceased by this time. So in the case of ERRP, while the opportunity to remedy lasts 38 days for the domain owner, the education component lasts just 8 days within that period. As a measure of what is acceptable from a risk and education point of view, for consumers and owners of domain names, the ERRP provides a valuable insight. In comparison, the 120 day interruption periods covered in Recommendations 6 and 7 are excessively generous to consumers. Therefore we would suggest that the periods of interruption in Recommendation 6 and 7 be brought into line with the ERRP and set at 38 days. As both education and remedy opportunities will last the full 38 days, this suggestion is still more generous than the ERRP, but not excessively so. New gTLD Applicants have been severely penalised by many elements of the new gTLD implementation process that have imposed delays or changes to the process under which applicants applied: as the proposed remedy for name collisions affects all applicants, we would request that in considering the length of the controlled interruption period, consideration be given to the impact this further delay will have on applicants. Rather than applying an overly conservative timeframe, we would ask that a more realistic and objective timeframe, of 38 days, be applied to the controlled interruption period. Regards, Donna [Description: Description: Description: ARI Logo]DONNA AUSTIN Policy and Industry Affairs Officer ARI REGISTRY SERVICES Melbourne | Los Angeles P +1 310 890 9655 P +61 3 9866 3710 E donna.austin@xxxxxxxxxxxxxxx<mailto:donna.austin@xxxxxxxxxxxxxxx> W www.ariservices.com<http://www.ariservices.com/> Follow us on Twitter<https://twitter.com/ARIservices> The information contained in this communication is intended for the named recipients only. It is subject to copyright and may contain legally privileged and confidential information and if you are not an intended recipient you must not use, copy, distribute or take any action in reliance on it. If you have received this communication in error, please delete all copies from your system and notify us immediately.