Fast Flux: Summary of Initial Reoprt

["Jeffrey A. Williams" <jwkckid1@xxxxxxxxxxxxx>]

To whom it may or should concern,

  The Fast Flux working group, which I was a member of has
sense it's formation been censored from open and transparent
participation, as I am as spokesman for our members, not
allowed to actively participate on the WG list.  Sense that
time, the tenor of the discussion which formulated this Initial
report has gone in directions that do not accurately reflect what
our members have reported to CERT and DHS regarding Fast-flux,
Phishing, and other resulting errant and/or illegal activities.

  This broadly stated, the Initial Fact Flux report makes some
not factually based assumptions as to who benefits and who does
not from Fast Flux, and why.  Advocacy groups and free speech
groups do not benefit what so ever from Fast Flux, and in fact are
to a degree undermined by same.  And such an assumption given
our data and observation bares this out.

  The single most non ccTLD based Email Phishing and other errant
or illegal activities we have noticed and reported to the relevant
law enforcement organizations has been Google.com's Gmail and
Yahoo.com originated.  Yahoo has done a fair job in addressing these
complaints our members including myself have sent in online, but
Google seems to continue to deny that Gmail is one of their service
products when complaints are sent in accordingly, and Gmail spam,
phishing attempts, and other Gmail originated errant and illegal Email
activities continue and have been on the increase.

  This Initial report seems to be pushing down the actual responsibility

from ICANN's accredited Registrars and Registries, down to Registrants,
which is partly justified, and ISP's, which is not justified as far as
determining
a comprehensive solution.  Certainly ISP's can help, and many do, but
they are not the originator nor are the responsible party by which a
solution can be effected.

  Another assumption made in this Initial Report that is a false
positive,
is one that WG members seem to be repeating the clarion calls by
ICANN staff that making some modifications to RAA's for Registrars
to strengthen Registrant verification and identification processes as
a means by which Fast Fluxing can be mitigated more effectively.
Nothing could be further from the truth, and would entail a reduction
of privacy protection for Registrants opening them up to potential
significant exposure to other criminal activities accordingly.  Rather
a better approach our members did at one time outline which I
did communicate when I was able to actively participate in the WG
mailing list, was that Registrars, and to a lessor degree need to
build detecting mechanisms of a technical nature that will detect
when Fast Flux of DNS is evident, and than generate a Email
alert to CERT, other law enforcement agencies, contracted reporting
agencies, and ICANN staff that this activity has been recognized.
We have tested such a system, and continue to do so, and have
had significant success.

  In conclusion, until or unless ICANN with such efforts such as this
decides to do so in an honest, open and transparent manner, solutions
to these problems and issues will never be fully resolved or resolved
at all.

Regards,

Spokesman for INEGroup LLA. - (Over 284k members/stakeholders strong!)
"Obedience of the law is the greatest freedom" -
   Abraham Lincoln
"YES WE CAN!"  Barack ( Berry ) Obama

"Credit should go with the performance of duty and not with what is
very often the accident of glory" - Theodore Roosevelt

"If the probability be called P; the injury, L; and the burden, B;
liability depends upon whether B is less than L multiplied by
P: i.e., whether B is less than PL."
United States v. Carroll Towing  (159 F.2d 169 [2d Cir. 1947]
===============================================================
Updated 1/26/04
CSO/DIR. Internet Network Eng. SR. Eng. Network data security IDNS.
div. of Information Network Eng.  INEG. INC.
ABA member in good standing member ID 01257402 E-Mail
jwkckid1@xxxxxxxxxxxxx
My Phone: 214-244-4827