A More Broadly Based Approach Is Needed
Comments on the The Anti-Spam Community Registry's .mail Proposal Alleviating the spam problem is certainly a worthy goal. But ICANN should be very wary of this proposal to establish a .mail TLD and delegate that TLD, as well as policy-making authority, to the proponents. As other commentators have remarked, there are many technical doubts as to the feasibility of this proposal. Just as importantly, there is scant reason to implement the mechanisms in the proposal in a TLD, particularly one with as generic a name as ?.mail?. The main thrust of this proposal is to establish an anti-spam database in the DNS that shadows existing TLDs for use in automated look-ups by scripts and programs. That function could as easily be done in an SLD, in the form KEY.example.org (where KEY is the shadowed SLD.TLD). In view of the lack of technical need for a TLD to implement the described anti-spam features, this proposal must be viewed as mainly an effort to gain ICANN?s endorsement for the described anti-spam proposals and for the proponents. ICANN should be very wary of providing such an endorsement because: 1. There are many, many efforts currently underway to address the spam problem. The IETF and IRTF currently have efforts underway, as do many other technical organizations concerned with the Internet. Governmental and intergovernmental organizations also have ongoing initiatives, as do many ad-hoc anti-spam groups other than the proponents. While Spamhaus.org has contributed to the overall efforts of the community, its activities have involved very significant controversy. In this environment, ICANN should be quite cautious in acting in a way that appears to endorse any single faction or
approach. Endorsement of one faction will effectively hinder or discourage others, and ICANN is not in a position to judge the relative merits of the various factions and approaches. 2. As its Chairman and President have repeated often in the recent context of UN-ICT and WSIS, ICANN has a limited mission. Control of spam, hate speech, pornography, libel, cyberterrorism, and similar issues are not in ICANN?s mission. Making an endorsement of a particular faction of the anti-spam movement would inappropriately involve ICANN in a matter outside its mission. In the ?Add new value to the Internet name space? section, the proponents discuss (in the four paragraphs beginning ?Part of this sTLD?s mission . . .?) reasons why they would prefer a TLD-rooted anti-spam database to an SLD-rooted database. Those reasons relate to the supposedly higher reliability of an entry in the root zone than an entry in a TLD zone. The reasons, however, are far-fetched. Even if they had more factual basis, the underlying concerns could be addressed well by other means. The proponents could, for example, make their technical case (perhaps by demonstrating the feasibility of the database with an extended test under spamhaus.org) to the IETF (the recognized technical-standards authority for the Internet), and thereby possibly earn an entry under .arpa, which is h!
andled
similarly to, and enjoys the same ultra-high reliability as, the root. The unresolved technical issues raised by this proposal, coupled with the apparent and inappropriate endorsing effect ICANN?s approval would give, indicates that the proponents should demonstrate the viability and efficacy of their proposed anti-spam database in an extended sub-TLD demonstration before ICANN establishes a TLD (or the IETF establishes an .arpa subdomain) for this purpose. Even then, the permitted name should not be so generic as .mail, to minimize the endorsing effect. (This would follow the precedent of the change of the name of the .air TLD to .aero.)
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