ICANN seeks public comments on Fast Flux

[mauro@xxxxxxxxxx]

Dear Sir/Madam,
I'm writing in response to the public consultation on the Initial Report
on Fast Flux Hosting. I would like to thanks ICANN for this initial report
and for the engagement in this matter.

As private citizen running is own web/mail servers on a dynamic IP range
I'm already suffering a lot of problems. For instance my emails
(direct-to-mx) are sometimes refused do, for instance, to the Spamhaus PBL
list. The block of port 25 is another very irritating problem. I am
planning to start my own dns server. I would do that for learning purpose
and because I consider that my information belong to me (I have to have
the possibility to manage my information). I think that active engagement
like the one of charging a premium for dynamic name server domains (page
45) are going against the basics of the Internet. If I want to run my own
structure (for different reasons, like costs, freedom,...) I do not have
to pay the bill because a little part of user are misusing the Internet.

As a cybercrime's analyst (I work for the Reporting and Analysis Centre
for Information Assurance MELANI, www.melani.admin.ch, the Swiss GovCERT
is part of MELANI too), I am daily engaged on the fight against fast flux
domains. I have to admit that we have problems to make take downs in
Switzerland with ccTLDs .ch. The fact is, that our registrar is, by law,
not able to do a take down without a permission coming from a judge. I
would like to stress the fact that the registrar should have more freedom
in acting against fast flux domains. I think that adopting accelerated
domain suspension processing in collaboration with certified
investigators/responders should be a must in the fight against fast flux
domains. (The impossible would be an international list of accredited
investigators/responders and registrar contact points)

Many thanks for your attention
Best regards
Mauro