Hi All, Section 3 of this document re Initial Assessment needs to be fleshed out, a lot, please. The prefaces are important: Sec. 1 - The delegation of almost any new generic top-level domain carries some risk of Name Collision... Sec. 2 - Applicants should note that the metrics for an applied-for string are only one of several factors, both quantitative and qualitative in nature, that will be considered when assessing the risk associated with that string. Applicants should not assume that if the datasets indicate a low volume of name collision occurrences that the string will be assessed as safe to be delegated. Then, INITIAL ASSESSMENT: Sec. 3 - Each applied-for string will undergo an initial risk assessment by an expert evaluator using relevant data sets [examples given] ... and additional qualitative evidence data that can help deduce the severity of harm. The purpose of this assessment is to preliminarily identify *high-risk strings*. Strings assessed to be high-risk will be placed on the Collision String List (see Section 5 [docs.google.com] <https://urldefense.com/v3/__https:/docs.google.com/document/d/17VZM1Jx9Waw7q...>) and any applications for these strings will not proceed until a High-Risk String Mitigation Plan has been completed. Initial Assessment will take place following the [String Confirmation Day]. ICANN will publish a report describing the assessment, its methodology, and findings, once completed. ________________ And that's it. This seems incredibly arbitrary on its face, and likely will result in a very significant expense and delay for any application identified as high-risk. So again I have some questions (some repeated, some new)... What specific and objective criteria will be used by the sole "expert evaluator" to decide whether any string is high-risk? How will anyone be a competent expert at this anyway, and how will they be chosen? How will any decision be challenged? How will any Risk Mitigation Plan be monitored if it is kept secret by ICANN? What really is the risk of undetectable malicious interference, which is the only purported reason to keep these Plans secret? Also, 3 months to come up with an acceptable Risk Mitigation Plan may not be enough. There appears to be very few people who understand any of this, much less can competently come up with a plan acceptable to whatever panel of experts ICANN hires, based on who knows what criteria. Those few people are likely to be in very high demand. There needs to be either a longer deadline, or at least an opportunity for an extension if applicant is making reasonable efforts towards developing a Plan. [image: Image removed by sender. Logo] *Mike Rodenbaugh* *Rodenbaugh Law LLC* *email:* mike@rodenbaugh.com *phone:* +1 (415) 738-8087 On Tue, Jan 14, 2025 at 10:15 AM Elisa Busetto via SubPro-IRT < subpro-irt@icann.org> wrote: Hi everybody, We have updated the Name Collision language [docs.google.com] <https://urldefense.com/v3/__https:/docs.google.com/document/d/17VZM1Jx9Waw7q...> based on your feedback and will go through the changes during meeting #104 <https://community.icann.org/x/UACcG>. Best, Elisa *From: *Elisa Busetto <elisa.busetto@icann.org> *Date: *Wednesday, 8 January 2025 at 10:39 *To: *"subpro-irt@icann.org" <subpro-irt@icann.org> *Subject: *Name Collision Dear all, Happy New Year! Please find the proposed language [docs.google.com] <https://urldefense.com/v3/__https:/docs.google.com/document/d/17VZM1Jx9Waw7q...> for Topic 29: Name Collision, which we will discuss today <https://community.icann.org/x/BgBWGQ>, 8 January at 13:00 UTC. Best regards, Elisa _______________________________________________ SubPro-IRT mailing list -- subpro-irt@icann.org To unsubscribe send an email to subpro-irt-leave@icann.org _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.