ARI Registry Services comments on Name Collision

[Donna Austin <donna.austin@xxxxxxxxxxxxxxxxxx>]

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/>

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