The numbers appear overstated. After a first pass, I don't see the complete list of all 268 of the marks they studied (maybe I missed it), but several (Amazon, Adobe, Delta, Yahoo) still appear to be dictionary words where it would be false to claim that Mark+Dictionary word is automatically "bad." Indeed, when you look at table 7 at the top right of page 11, they classify 86.6% of the so-called "combosquatting pages" as "Unknown", and only 13.39% as "Malicious". And of those alleged "malicious" ones, 69.9% were an ambiguous "trademark abuse" (not phishing, social engineering, or "affiliate abuse"), which seems likely to yield even more false positives. Their attempt at detecting "false positives" leaves much to be desired, i.e. whitelisting only the top 10,000 Alexa domains (see page 4, Alexa list). My company's math.com domain name wouldn't get white-listed by that standard (and it gets millions of visitors/year). Neither would school.com. Alexa Top 10,000 sites get enormous traffic --- many legitimate but lower traffic sites wouldn't be whitelisted by their methodology. Importantly, they didn't seem to use WHOIS or Zone Files in their data sets (see page 4, section 3.2). i.e. they trumpet the "468 billion DNS records" (many DNS requests and website visits are generated by bots, not human beings, these days), but there are perhaps roughly 150 million gTLD domain names for which ICANN makes policy. And it would seem, by their methodology, that they might even count defensive registrations by brand owners themselves as "combo squatting". e.g. if Microsoft owns MicrosoftOffice.com, does that get accounted for properly? 2.7 million domains divided by 268 marks equals 10,074 domains/mark, which sounds like a lot, but Microsoft already owns tens of thousands of domains, according to DomainTools: https://whois.domaintools.com/microsoft.com as do many of the other markholders like Google, Yahoo, etc. I hope those weren't counted improperly. I think seeing the results by TLD would also be useful (e.g. .TK domains are free, and openly abused), as well as what effect the "promos" from new gTLDs has had (e.g. domains under $1/yr), and whether historic domain tasting might have also accounted for some of the measurements. Not saying the problem doesn't exist, as there are lots of bad actors. But, if it was a "growing threat" as claimed, the evidence would be directly observable via increased lawsuits, increased UDRP filings, etc. More important would be to discern whether there is an increase in the number of bad actors, rather than just measuring things by domains. e.g. 2.7 million bad actors registering one domain name each is a lot different than 10 bad actors registering 270,000 bad domains each. I think the latter situation is to be preferred, from a policy perspective (i.e. better to have tools to handle the industrial-cybersquatter, where the incidence of false positives and collateral damage from policymaking will be lower). Others might correct me, but it's my sense from media reports that more of the bad actors have shifted their focus to social media and apps abuse, rather than domain abuse, to generate traffic (e.g. Facebook, Android apps, etc.). Due to tools like Chrome "Safebrowing" blacklists, rarely do I ever actually encounter abusive domains these days. Sincerely, George Kirikos 416-588-0269 http://www.leap.com/