Re: Public Comment: Draft Advisory on the Effect of Registrar Accreditation Agreement (RAA) Subsection 22.214.171.124]
When we address claims of harm we should distinguish between those which have only legal effect from those which have an operational effect.
The use of a proxy'd registration as a vector for exploits that target operating systems and applications products is very distinct from the use of the same assets as a vector for some eventual, and quite hypothetical dilution claim, or the more proximal, but effects measurement resistant claims of user confusion.
It is imprudent to collapse the notice-to-effect time for what are harms that take significant multiples of the notice period to manifest noticeable harm, and ignore the necessity to act on harms with a temporal horizon comparable to, and significantly less than, the notice period contemplated in this draft.
Let me be clear. The reduced time is unimportant. Reducing time for the wrong harm is important, and an error.
This comment is offered in my individual capacity. Eric