- Comments-ncap-1-proposed-final-report-08may20

NCAP Study 1
by Austin, Donna 18 Jun '20

18 Jun '20

Neustar welcomes the opportunity to comment on the very detailed NCAP study 1 report conducted by Karen Scarfone, Scarfone Cybersecurity. As a back-end registry operator, Neustar supports over 220 gTLDs and ccTLDs. We concur with Ms Scarfone's conclusion that controlled interruption has been effective in mitigating name collision in the TLDs that we support as a result of the 2012 new gTLD application process and as such we do not believe that any additional name collision studies should be a pre-requisite for any subsequent new gTLD application process/es. Donna Austin Donna Austin Neustar, Inc. / Senior Policy Manager, Registry Solutions Mobile: +1 310 890 9655 donna.austin(a)team.neustar<mailto:donna.austin@team.neustar> / Website: home.neustar<https://urldefense.com/v3/__http://www.home.neustar/__;!!N14HnBHF!uSVcXlZEI… > Follow Neustar: LinkedIn<https://urldefense.com/v3/__http://www.linkedin.com/company/5349__;!!N14HnB… > / Twitter<https://urldefense.com/v3/__http://www.twitter.com/neustar__;!!N14HnBHF!uSV… > Reduce your environmental footprint. Print only if necessary. ________________________________ The information contained in this email message is intended only for the use of the recipient(s) named above and may contain confidential and/or privileged information. If you are not the intended recipient you have received this email message in error and any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately and delete the original message.

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JAS Global Advisors comments on Name Collision Analysis Project (NCAP) Study 1 document
by Jeff Schmidt 17 Jun '20

17 Jun '20

JAS Global Advisors was contracted by ICANN to research the collisions phenomena and provide recommendations on how to safely delegate new TLDs. JAS research and recommendations lead directly to ICANN's Name Collision Occurrence Management Framework which resulted in the safe delegation of > 1,200 new TLDs to date. JAS supports the Scarfone Cybersecurity findings and conclusions contained within the Name Collision Analysis Project (NCAP) Study 1 document. In particular, the Scarfone document reminds us of several important truths regarding namespace collisions: (1) Collisions are well understood and have been researched since the 1990s. Problematic - even dangerous - collisions may occur now or in the future, and whether ICANN delegates new TLDs or not. But the root causes are well understood as well as the available mitigation strategies. Collisions will never be "zero" and that must not be our goal. (2) Policy makers must understand that Collisions (as defined by the SSAC in SAC62 and SAC66) are a DNS problem, not a New gTLD problem. They can and do occur throughout the global Internet DNS Namespace and in every TLD. Collisions also occur in every other large namespace including telephone numbers and postal addresses. (3) What ICANN (collectively) did during the 2012 New gTLD Round worked. By every conceivable definition of "worked." (a) ICANN delegated more than 1,200 New TLD strings with only a tiny handful of collision issues reported, none serious. Policy makers interested in namespace collisions must review and understand the implications of Figure 1 in the Scarfone document. (b) Multiple parties (including Scarfone) have scoured the Internet looking for evidence of unreported serious collision-related issues and found none. Several of the largest tech companies in the world are represented on NCAP and SSAC. The individuals serving on NCAP and SSAC are some of the smartest, most informed, and well-connected technologists in the world. If there were widespread serious collision problems, it is unreasonable to think they would not be known five plus years after delegating > 1,200 new TLDs. (c) Based on a string-by-string analysis of applied-for strings, delegation of three dangerous strings (corp, home, mail) was (correctly) blocked based on discovering and analyzing their unique situations. (d) Controlled Interruption worked as intended; again, multiple parties (including Scarfone) have scoured the Internet and identified references to 127.0.53.53 directing administrators to helpful information. All major search engines provide helpful content when searching for 127.0.53.53. Most browsers provide appropriate messaging when they encounter 127.0.53.53. The investment we collectively have made in the 127.0.53.53 signaling has been effective. Many systems are better now as a result of corrections made following controlled interruption. (e) Zero litigation and zero privacy/regulatory issues resulted from ICANN's handling of collisions in the 2012 New gTLD Round. In summary, if ICANN were to consider delegating additional strings to the root at some future point, there is no reason to do anything differently than what it did in 2012. If ICANN or the ICANN Community are unhappy with how collisions were eventually handled in the 2012 New gTLD Round, it must state a specific problem to be addressed.

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NCAP Study 1 - Proposed Final Report: BRG Comment
by Martin Sutton 17 Jun '20

17 Jun '20

The Brand Registry Group (BRG) is grateful for the opportunity to provide comments on the Name Collision Analysis Project (NCAP) Study 1 - Proposed Final Report. We appreciate the extensive work of the NCAP Discussion Group and the contractor to fulfil the objectives of Study 1, providing a valuable resource on the topic of name collision based on existing knowledge and understanding from prior work in the area. The conclusions and recommendations presented in Study 1 strongly indicate that controlled interruption was an appropriate and effective mitigation in the 2012 round of New gTLDs and should continue. Whilst further but more focused studies may be warranted, for example, in relation to .home, .corp, and .mail, the BRG believes that these should not be a cause of delay for any subsequent application rounds. As such, future studies must be well-defined, scoped and prioritised effectively, with recommended and approved enhancements taken forward as part of a continuous programme of improvements. With regards, Martin Martin Sutton martin(a)brandregistrygroup.org<mailto:martin@brandregistrygroup.org> Brand Registry Group The Association for Brands at the Top Level www.brandregistrygroup.org<http://www.brandregistrygroup.org/> LinkedIn<https://www.linkedin.com/company/brand-registry-group> Twitter<https://twitter.com/BrandRegistries> Facebook<https://www.facebook.com/dotBrands> The contents of this email message and any attachments are intended solely for the addressee(s) and may contain confidential and/or privileged information and may be legally protected from disclosure. If you are not the intended recipient of this message or their agent, or if this message has been addressed to you in error, please immediately alert the sender by reply email and then delete this message and any attachments. If you are not the intended recipient, you are hereby notified that any use, dissemination, copying, or storage of this message or its attachments is strictly prohibited.

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Valideus Comments on NCAP Study 1 Draft Report
by Susan Payne 17 Jun '20

17 Jun '20

Please see our attached comments. Susan Payne Head of Legal Policy Valideus 28-30 Little Russell Street London WC1A 2HN United Kingdom [cid:image003.jpg@01D644E8.7B14F200] ________________________________ The contents of this email and any attachments are confidential to the intended recipient. They may not be disclosed, used by or copied in any way by anyone other than the intended recipient. If you have received this message in error, please return it to the sender (deleting the body of the email and attachments in your reply) and immediately and permanently delete it. Please note that the Com Laude Group does not accept any responsibility for viruses and it is your responsibility to scan or otherwise check this email and any attachments. The Com Laude Group does not accept liability for statements which are clearly the sender's own and not made on behalf of the group or one of its member entities. The Com Laude Group includes Nom-IQ Limited t/a Com Laude, a company registered in England and Wales with company number 5047655 and registered office at 28-30 Little Russell Street, London, WC1A 2HN England; Valideus Limited, a company registered in England and Wales with company number 06181291 and registered office at 28-30 Little Russell Street, London, WC1A 2HN England; Demys Limited, a company registered in Scotland with company number SC197176, having its registered office at 33 Melville Street, Edinburgh, Lothian, EH3 7JF Scotland; Consonum, Inc. dba Com Laude USA and Valideus USA, headquartered at 1751 Pinnacle Drive, Suite 600, McLean, VA 22102, USA; Com Laude (Japan) Corporation, a company registered in Japan having its registered office at Suite 319,1-3-21 Shinkawa, Chuo-ku, Tokyo, 104-0033, Japan. For further information see www.comlaude.com<https://comlaude.com>

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Ratified: ALAC Statement on Name Collision Analysis Project (NCAP) Study 1: Proposed Final Report
by ICANN At-Large Staff 17 Jun '20

17 Jun '20

Dear All, Please find attached the final ALAC Statement on Name Collision Analysis Project (NCAP) Study 1: Proposed Final Report<https://community.icann.org/x/boQEC>. Ratification information is included on the cover page. Kind Regards, ICANN Policy Staff in support of the At-Large Community Website: atlarge.icann.org<https://atlarge.icann.org/> Facebook: facebook.com/icann<https://www.facebook.com/icannatlarge>atlarge<https://www.facebook.com/icannatlarge> Twitter: @<https://twitter.com/ICANNAtLarge>ICANNAtLarge<https://twitter.com/ICANNAtLarge>

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NCAP Study 1 Proposed Final Report
by Nick Wenban-Smith 17 Jun '20

17 Jun '20

On behalf of Nominet UK I am pleased to provide our comments on the Name Collision Analysis Project Study 1 Proposed Final Report. The proposed Final Report provides a very clear and accessible overview of the subject of Name Collisions. The Study 1 goals, namely to: 1. Document prior work on name collisions; 2. Assess name collision datasets; and 3. Recommend whether or not proposed further studies 2 and 3 should be performed all appear to have been delivered upon in the proposed Final Report. The clear conclusions of the proposed Final Report are that Name Collisions are a diminishing issue. The lack of new published research in the area in the past three years, and the success of the controlled intervention as a mitigation, should give the ICANN community considerable comfort that Name Collision is no longer a pressing issue in terms of the stability and security of the DNS. Going forwards, due to the absence of any datasets containing root causes, Study 2 seems redundant. We agree that the Name Collision risks for proposed new TLDs, including any new ccTLDs since this issue is not restricted to gTLDs, be investigated on a case by case basis. Similarly Study 3 and the outstanding questions around corp, home and mail as TLDs whilst unresolved, are a discreet problem which need not delay further rounds of new gTLDs as envisaged by the Subsequent Procedures PDP. Best wishes Nick Nick Wenban-Smith General Counsel and Head of Stakeholder Relations [UK Domain] Website<http://www.nominet.uk/> | Twitter<https://twitter.com/Nominet> | Facebook<https://www.facebook.com/nominet/> DD: +44 (0)1865 332287 E: nick.wenban-smith(a)nominet.uk<mailto:nick.wenban-smith@nominet.uk> Minerva House, Edmund Halley Road, Oxford Science Park, Oxford, OX4 4DQ, United Kingdom Nominet UK. Registered in England and Wales No. 3203859 This message is intended exclusively for the individual(s) to whom it is addressed and may contain information that is privileged, or confidential. If you are not the addressee, you must not read, use or disclose the contents of this e-mail. If you receive this e-mail in error, please advise us immediately and delete the e-mail. Nominet UK has taken every reasonable precaution to ensure that any attachment to this e-mail has been swept for viruses. However, Nominet cannot accept liability for any damage sustained as a result of software viruses and would advise that you carry out your own virus checks before opening any attachment

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Verisign comments on "Name Collision Analysis Project (NCAP) Study 1 Final Report"
by Kaliski, Burt 16 Jun '20

16 Jun '20

Verisign is pleased to provide the attached comments on the Name Collision Analysis Project (NCAP) Study 1 Final Report. We would welcome the opportunity to offer further assistance to ICANN on its work in this important area. * Burt Burt Kaliski Senior Vice President Chief Technology Officer bkaliski(a)verisign.com<mailto:bkaliski@verisign.com> 12061 Bluemont Way Reston, VA 20190 t: 703-948-4664 m: 571-528-2679 Verisign.com<https://www.verisign.com/>

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