Registrar Constituency Position on Fast Flux Hosting Initial Report
February 15, 2009
Registrar Constituency Position on Fast Flux Hosting Initial Report
BACKGROUND
In January 2009, the Registrar Constituency ("RC") was asked to provide
feedback regarding the Initial Report on Fast Flux Hosting ("Initial Report").
This Position Paper captures the overall sentiment expressed by the RC Members
who provided feedback about this matter. Due to time constraints, however, no
formal vote regarding this Position Paper was taken.
RC POSITION
In the Initial Report, the Fast Flux Working Group ("WG") has drawn interim
conclusions and provided a number of possibilities for next steps in dealing
with fast flux issues. After considering the possible next steps proposed, the
RC strongly encourages the Council to explore other means to address the fast
flux issues instead of initiating a Policy Development Process ("PDP"). In the
RC's view, a PDP is not well suited to
address the issue of fast flux.
As the WG quickly came to appreciate, flux hosting, flux techniques, and flux
facilitated attacks change rapidly over time. In fact, flux activities
continued to evolve during the WG's study period.
Additionally, the WG acknowledged that fast flux and similar techniques are
merely components in the larger issue of Internet fraud and abuse and are only
part of a vast and constantly evolving toolkit for attackers. It is clear that
mitigating any one technique in the attackers' toolkit would not eliminate
Internet fraud and abuse.
Because of the rapidly evolving nature of fast flux, combined with the minimal
effect new policy would likely have on Internet fraud and abuse, a PDP is not
well suited to address the issue of fast flux. Accordingly, the RC believes
that any mitigation efforts are best left to organizations and parties outside
of ICANN.
Notwithstanding the RC's preference that no PDP be initiated, if the Council
decides to pursue a PDP in this area, then the RC recommends that these next
steps, as suggested by the WG, occur in the following order:
1. Further work/study to determine which solutions/recommendations are
best addressed by best practices, industry solutions, or policy development.
The RC prefers development of best practices and industry solutions with policy
development reserved as a last resort.
2. Include flux hosting, flux techniques and flux facilitated attacks
as part of the work now being done on registration abuse and take-down policies.
3. If the Council pursues policy development specifically for fast
flux, the Council should redefine the issue and scope to address some of the
problems encountered by the WG and to develop a narrower and more sharply
focused charter. This can only be done by first following the WG advice on
additional research and fact-finding to address the questions and issues raised
in the Initial Report.
CONCLUSION
The opinions expressed by the RC in this Position Paper should not be
interpreted to reflect the individual opinion of any particular RC member.
Attachment:
RC Position - Fast Flux Initial Report v1-2.pdf |