[Gnso-newgtld-wg-wt4] ICANN Compliance x Name Collisions

Aikman-Scalese, Anne AAikman at lrrc.com
Wed Sep 13 00:38:40 UTC 2017

Thank you Rubens.  It would indeed be good to know how many back-end providers are involved in these instances of name collision.

Regarding the requests for informal technical advice on the name collisions issue, I look forward to receiving copies of the full responses  – hopefully all in one shot (rather than digging through e-mail archives) prior to any final formulation of a recommendation from Work Track 4.

I certainly applaud the idea of name collision risk being reviewed up front before any other aspect of technical evaluation – in order to save time and money for applicants and others.  I really don’t have a sense as to whether the “three categories” are appropriate or how this approach was developed.  Could you please advise?  Who exactly determines the category of name collision risk on a case-by-case basis?  What standards do they use?  Is a Technical Panel involved?

Depending on the answers, and as noted on a previous call, it seems to me more formal technical advice may be needed on the proposed name collision framework (as was done in the 2012 round).  I am also uncomfortable with the idea that “mitigation of name collision risk”  would become a matter to be addressed individually by the registry working with ICANN staff prior to delegation. That seems very time consuming for staff and may suffer from a lack of transparency as well.  (This appeared to me to be part of the current Straw Proposal.)

I would favor a system which requires name collision risk to be judged according to a generally applicable Framework and which involves technical evaluation independent of the contracting party negotiation with ICANN staff prior to delegation.  Ideally an independent third party would advise on a formal basis as to the appropriate name collision framework for the next round so that objective standards are established and apparent to the Community.  Certainly there would be no problem with ICANN staff working to mitigate name collision incidents which continue to occur post-delegation so I agree with you there.

Thank you,

Anne E. Aikman-Scalese

Of Counsel

520.629.4428 office

520.879.4725 fax

AAikman at lrrc.com<mailto:AAikman at lrrc.com>


[cid:image003.png at 01D32BED.F71CA710]

Lewis Roca Rothgerber Christie LLP

One South Church Avenue, Suite 700

Tucson, Arizona 85701-1611


From: gnso-newgtld-wg-wt4-bounces at icann.org [mailto:gnso-newgtld-wg-wt4-bounces at icann.org] On Behalf Of Rubens Kuhl
Sent: Tuesday, September 12, 2017 5:07 PM
To: gnso-newgtld-wg-wt4 at icann.org
Subject: [Gnso-newgtld-wg-wt4] ICANN Compliance x Name Collisions


At the end of page 3:
"This quarter, the ICANN Contractual Compliance team also processed referrals from ICANN Technical Services regarding controlled interruption wildcard record violations. Approximately 45 TLDs were found to have activated names (other than nic.tld) in the DNS, while controlled interruption wildcard records continued to exist in their zone file."

It seems a high number of TLDs are still having issues with the 2012-round Name Collision Framework, long after delegation. This specific data point suggests that one of the suggested modifications, having ICANN or an ICANN contractor run the process before the TLD is delegated to the approved applicant, would not only address the time-to-market problem seen by registries but also improve compliance with the framework as designed.

We should note though that this report doesn't mention distribution by registry service provider; all 45 TLDs could share a single back-end for all we know.



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