As the comment period for the Name Collision report comes to an end there were plenty of comments submitted by applicants and others.
May of the comments simply endorsed the letter of NTAG to ICANN submitted during the comment period, while others siply asked for the comment period to be extended
Here are some of the more interesting submitted comments:
The Afnic/CORE consortium, the registry service provider for the .paris TLD. submitted this comment on behalf of the City of Paris, applicant for the .paris TLD.:
“In the Interisle study, .paris TLD was categorized as a “uncalculated risk” in ICANN’s Proposal to Mitigate Name Collision Risks. ”
“This seems to be based on the following findings:
1) In the 2013 DITL data contains 80,000 occurrences of the string “paris” as a TLD;
2) In the list of internal X.509 certificates issued by well-known certification authorities involving an applied-for TLD on the top level, there are three involving “.paris”, two of which expire in 2013 and the remaining one in 2015.
“We find that it is necessary to state – even before any further analysis of the data is performed – that the label “uncalculated risk” is unfortunate in that it overstates by several orders of magnitude any conceivable security risk to any party.
”
“In particular, it must be noted that DITL data for recent introductions of new TLDs (such as .asia) prior to their launch had proportionally higher “as-TLD” counts. None of these TLD introductions have caused any problem.”
“The threshold below which the Interisle study applies the “low risk” category is a count of 50,000 “as-TLD” queries in the 2013 DITL data. The .paris TLD has 90,000, whereas applied-for TLDs with a count of up to 19.8 million – i.e more than 200 times higher – are in the same category.”
“We understand that the point arbitrarily selected to set the threshold was the one dividing the statistical population between 80% and 20% of the applied-for TLD strings. A look at the data suggests, however, that it would have been much more appropriate to put the threshold at a point where the typical step change in the underlying measurement value from one rank to the next is more significant.”
“This would be the case, for instance, with a 95/5 or with a 97/3 split.”
“At that point, the typical step of change in the underlying measurement value from one rank to the next is in the order of 2%-3% f the category maximum.”
B) Comment on the mitigation proposal
There are many ways to improve the present Mitigation Proposal for the low-risk category without additional risk.…
