Dear ICANN, The Internet Service Providers and Connectivity Providers constituency (ISPCP) respectfully submits the following comments on ICANN's August 5 Proposal to Mitigate Name Collision Risks. We are available to respond to any questions or comments. Best regards, Mike O'Connor -- ISPCP Rapporteur - - - - - ISPCP Comment Whereas: the potential for name collision may be substantial Whereas: the potential for name collision often arises from well-established policies and practices in private network environments Whereas: the risk associated with delegating a new TLD label arises from the potentially harmful consequences of name collision, not the collision itself Whereas: name collision in general may threaten the assumption that an identifier containing a DNS domain name will always point to the same thing Whereas: the opportunity for X.509 public key certificates to be erroneously accepted as valid is an especially troubling consequence of name collision Whereas: designation of any applied-for string as “high risk” or “low risk” with respect to delegation as a new gTLD depends on both policy and analysis -- activities which have not yet been completed Whereas: the analysis to evaluate the nature and impact of name-collision risk has not been completed Whereas: corporations, ISPs and connectivity providers may bear the brunt of the security and customer-experience issues resulting from adverse (as yet un-analyzed) impacts from name collision Whereas: those same corporations are in large part not active participants in the ICANN community and are only just becoming aware of these issues Whereas: these issues, due to their security and customer-experience aspects, fall outside the remit of people who normally participate in the ICANN process, requiring extensive wide-ranging briefings even in corporations that do participate actively in the ICANN process Therefore, the ISPCP requests the following. -- that ICANN complete further study of name-collision issues to understand their nature and impact, following the recommendations made in the InterIsle report -- That the initial public comment period be placed on hold until such a study is completed, or if that is deemed infeasible, at least extended for 60 days to allow a more detailed assessment of the important issues raised