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Registrar Constituency Position on Fast Flux Hosting Initial Report

  • To: "fast-flux-initial-report@xxxxxxxxx" <fast-flux-initial-report@xxxxxxxxx>
  • Subject: Registrar Constituency Position on Fast Flux Hosting Initial Report
  • From: "Clarke D. Walton" <clarke.walton@xxxxxxxxxxxxxx>
  • Date: Sat, 14 Feb 2009 23:29:01 -0500

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
Description: RC Position - Fast Flux Initial Report v1-2.pdf



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