Dotless Domains Have a Place in a Free and Open Internet

[Nic Steinbach <nic@xxxxxxxx>]

Hello,

While we appreciate SSAC's thorough undertaking into investigating how
dotless domains work today, the report is fundamentally flawed in three
ways in respect to any policy recommendations concerning the new gTLDs.
First, the report fails to consider the impact that current and future new
gTLDs will have on the current online landscape. Secondly, it lacks
definitive statements and a definitive conclusion. Finally, the study does
not justify the need for the proposed recommendation.

The entire paper relies on the current status quo in regards to dotless
domains. On the advent of the first new gTLD launch, when 1000+ new gTLDs
will enter the root zone, SSAC's failure to acknowledge a changing
landscape is troubling at best. For example, it is true that currently web
browsers have trouble recognizing dotless domains. However, if the status
quo changes and dotless domains became prevalent, it is not only likely but
probable that web browsers and other online applications will adapt  (Its
worth pointing out that in the case of web browser at least one TLD
applicant - Google - can actively influence this evolution.) The SSAC
report is riddled with statements like "Today it is common" or "All of the
most commonly used Internet applications." Relying on these types of facts
as a basis for policy recommendations ignores that the Internet as we know
it is constantly changing, adapting and moving forward. Attempting to stunt
this type of innovation stands in direct opposition to ICANN's stated goals.

Along with ignoring the Internet's current and historical ability to adapt,
the paper is based on predictions masquerading as definitive technical
analysis. This is probably best highlighted in the final conclusion
presented by SSAC. "The result could be anything from fully expected
behavior to a security incident…" and "Additionally, this ambiguous
behavior could be used to...". It is important to note that those
statements are not "The result is anything from fully expected behavior to
a security incident…" or "Additionally, this ambiguous behavior will be
used to..."  When taken apart, SSAC's paper is based on a series of
presumptions that ultimately results in an inconclusive result. The word
"may" is used 11 times in the nine page paper. It or an equivalent can be
found in every section, including the conclusion. When the recommendation
is to stifle innovation, there is no room for maybe.

Finally and most importantly, there is no solid justification for ICANN
enacting or enforcing this regulation. SSAC acknowledges that "There
currently exist TLDs that attempt to resolve dotless domain names." Their
report includes zero incidents where this practice resulted in a security
breach or anything more than inconvenience for the address operator or
Internet user looking for the address. If the only problem is that the
address and email sometimes won't work, why does ICANN need to become
involved with additional formal regulations? A free and open Internet will
sort this problem one way or the other. Technology and public knowledge/use
will catch up to dotless domains. Or they won't and the use of dotless
domains will not be prevalent. Either way, it is not appropriate for ICANN
to decide these types of policies and take away any freedoms of choice and
innovation. Doing so based on a report that is inconclusive and fails to
even consider how the landscape might change is irresponsible,
inappropriate and a step down a dangerous road away that leads away from a
free and open Internet.

Sincerely,

Nic Steinbach

Operations Coordinator
Name.com
+1.720.633.9083