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Name Collision Comments - Top Level Design, LLC

  • To: comments-name-collision-05aug13@xxxxxxxxx
  • Subject: Name Collision Comments - Top Level Design, LLC
  • From: Andrew P Merriam <andrew@xxxxxxxxxxx>
  • Date: Mon, 26 Aug 2013 13:42:14 -0700

Top Level Design LLC, an applicant for 9 TLDs, would like to note its
strong support of the NTAG letter submitted on August 15th.

We must underscore that using the 2013 DITL data detailed by Interisle to
support the recommendations put forth in the “New gTLD Collision Risk
Mitigation Proposal” is misguided; many individuals have noted the way in
which this data may have been affected by the list of applied for TLDs
being published on “Reveal Day.”

We were dismayed to read the recommendations for delay in the “New gTLD
Collision Risk Mitigation Proposal” and stress that, excluding queries for
.home and .corp, ALL other applied for new TLDs represent a combined 0.016%
of the total query rate in the 2012 DITL data provided by Interise. This
figure simply does not warrant mitigation through a 3 - 6 month delay. We
note the NTAG letter clearly demonstrates that .sx was delegated in 2012
with a higher NXDOMAIN query rate than all but five of the currently
applied for TLDs. There is simply no precedent nor valid rationale for this
type of widespread delay.

We implore ICANN to move quickly to address the 20% that are currently
classified as “uncalculated risk” in order to allow them to proceed as
their priority numbers dictate and not be subject to vague and unfair
delays. The NTAG’s recommendations here should be a sufficient
baseline. Further
research should not impact any of the new TLDs outside of .home and .corp;
this research can be undertaken concurrently with other contracting and
delegation processes.

We further recommend that ICANN does not wait until TLD contracting to
notify the CA/Browser Forum of forthcoming TLDs; it was noted by a
certificate authority expert at the TLD Security Forum hosted by Artemis
Internet Inc., held on August 22nd in San Francisco, that many CAs continue
to issue certificates for forthcoming TLDs because some believe that new
TLDs are not likely to be implemented, among other reasons. This is a
messaging failure on ICANN’s part and we recommend that ICANN communicate a
list of all TLDs that have passed Initial Evaluation to the CA/Browser
Forum immediately, noting that there is a strong likelihood that these TLDs
will be implemented in the coming two years. ICANN can then provide a
confirmation to the CA/Browser Forum once a TLD has been successfully

Top Level Design LLC is hopeful that it will be able to research and
publish more information on its affected TLDs through the “reply” phase of
this public comment period. We believe that other applicants are likely to
do the same and that this body of evidence will further corroborate the
NTAG’s position that all TLDs other than .home and .corp must continue with
their contracting and delegation processes unhindered.

Respectfully yours,

Andrew Merriam

Andrew Merriam
Business Development Coordinator
Top Level Design, LLC

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