[gnso-ff-pdp-may08] Rod Rasmussen Statement of Interest - Redux

[Rod Rasmussen <rod.rasmussen@xxxxxxxxxxxxxxxxxxxx>]

Apologies if some of you have this from before, but it appears it's  
not in the "official" tally, so I don't want to get kicked out!  I've  
updated this for "financial interest" disclosure as well.
Rod

Rod Rasmussen
President and CTO, Internet Identity
Co-Chair, Anti-Phishing Working Group: Internet Policy Committee (APWG  
IPC)
Neither myself or my company have any ICANN/GNSO constituency  
membership at this time - we're trying not to "pick sides" on these  
abuse issues that affect all constituencies!
Statement of interest:

Both my company and the various industry organizations I am a leader  
and/or active within (APWG, MAAWG, Digital Phish-net, AOTA) are very  
concerned with the rapid rise in DNS manipulation techniques being  
used by phishers and e-criminals to perpetuate fraud, crime, and wide  
abuse across the Internet.  Fast Flux, and various other types of DNS  
"flux" techniques are being used by the largest proliferators of spam,  
phishing, and other net abuse, and are tied to organized crime  
elements throughout the world.  The nature of these attacks makes  
mitigation and prevention nearly impossible without the close  
involvement of the domain registration community, and their use is  
growing rapidly, with thousands of fraudulently registered domains in- 
use daily utilizing them.  We wish to engage this community to work on  
policies to address these types of abuse in a manner that will be  
highly effective, sustainable, and flexible enough to work as the  
criminals change their tactics.  At the same time, we realize that  
there are drawbacks and costs associated with any new policy and those  
need to be balanced to come up with solutions that work for all.
I am one of the principal partners of Internet Identity with a very  
large (but non-majority) portion of its ownership, and am thus  
materially impacted by the company's financial performance.  Our  
clients are primarily in the financial services and e-commerce sectors  
and they and their customers are the victims of phishing and other  
online crime attacks.  A large percentage of these clients are  
directly impacted by fast-flux based phishing attacks and part of the  
work we are paid to perform on their behalf is mitigating the actual  
attacks and working towards long-term solutions for these problems.   
Successfully addressing these issues from a policy perspective is both  
a potential financial gain and loss, as the benefits of our long-term  
role would be to some extent offset by lost revenue "opportunities"  
individual fast flux attacks present to our company's mitigation  
service.  Due to the nature of our work, many of our clients fall into  
the Business and/or IP constituency area of the GNSO umbrella (and  
several companies who employ us are members), but we also perform  
substantial work for domain registrars, domain registries, and ISPs,  
all of whom have membership within their respective GNSO constituencies.