[bc-gnso] RE: LAST CALL: BC comment on Proposal to Mitigate Name Collision Risks (filing deadline 17-Sep)

[Deutsch, Sarah B]

All,

Per my suggestion below, I attach a few small edits to our BC comments.

Thanks,

Sarah

From: owner-bc-gnso at icann.org [mailto:owner-bc-gnso at icann.org] On Behalf Of Deutsch, Sarah B
Sent: Sunday, September 15, 2013 11:36 PM
To: Steve DelBianco; bc-gnso at icann.org list
Subject: [bc-gnso] RE: LAST CALL: BC comment on Proposal to Mitigate Name Collision Risks (filing deadline 17-Sep)

Steve, All:

Thanks so much for circulating the BC comments and for adding your edits.  The BC concerns are confirmed by a report Verisign just released today (attached).

Verisign did a deep dive into just one of the new gTLDs  -- .CBA, which was applied for by the Commonwealth Bank of Australia.  The bank wrote a letter to ICANN complaining that .cba had been improperly categorized by ICANN as "uncalculated risk" and asked to be changed to the "low risk" category.  They said that any name collision that the Interisle report reported as coming from this string was their own traffic and they could remediate it.

In fact, the Verisign report showed that Commonwealth Bank of Australia at best controls 6% of the root server traffic associated with the .cba string.  The rest of the traffic, which, presents numerous risks of collision, was coming from over 170 countries including a significant portion of traffic from Japan.  The traffic comes from a variety of servers, smart home devices, offices, residences, etc.

This small snapshot of one new gTLD shouts out for ICANN to do a deeper dive into the new gTLDs to really understand these risks.  The .cba string (unlike. .corp or .home) is not one that anyone would intuitively think could result in collisions.  But in a global environment, it highlights that we really have no idea what different cultures have previously named their internal servers and devices.  How many of these enterprises even know ICANN and the new gTLD launch exists?  Also, the study shows ICANN cannot rely (as they are intending to do today) solely on their applicants to provide evidence of "acceptable" risk.

I hope the BC comments can add a line or two about this report to flag the risks to large and small BC members and our customers.

Thanks,

Sarah


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