Response Comment on ICANN FY 14 Security, Stability and Resiliency Framework

["Winterfeldt, Brian" <bwinterfeldt@xxxxxxxxxxx>]

Dear Patrick:

Thank you very much for the opportunity to comment on the FY 14 Security, 
Stability & Resiliency ("SSR") Framework.

I write in a personal capacity to second Dr. Crocker's suggestion in this 
public comment forum that ICANN assess the number of ccTLDs that need or are 
likely to need technical training, as well as determine their specific level of 
competence and security needs.  Over the past year, the Steptoe Internet 
governance team has worked with clients targeted by the escalation in threats 
detailed in the FY 14 SSR Framework.  In light of this work, we fully concur 
with the suggestion for a proactive approach, aimed directly at the most 
operationally vulnerable ccTLDs.  We also concur with the observation that such 
vulnerabilities typically exploit smaller operators who are not generally 
active participants in the community.

Finally, we hope to assuage any concern about the inclusion of major brands as 
somehow making this approach less effective or shifting its focus toward 
corporate needs rather than achieving results for the ccTLDs.  Well-known 
brands are common targets for attacks exploiting vulnerabilities within the 
exclusive control of ccTLD operators.  Thus, enhanced technical training and 
security competencies for ccTLDs benefit all parties-and should be considered 
as community, corporate and ccTLD operator needs.  The continued outreach and 
leadership of ICANN in mitigating / eliminating security vulnerabilities is 
greatly appreciated, yet it need not accomplish these goals alone.

Best regards,

Brian

Brian J. Winterfeldt
Partner
bwinterfeldt@xxxxxxxxxxx<mailto:bwinterfeldt@xxxxxxxxxxx>
Steptoe

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